Judge: Armen Tamzarian, Case: 24STCV05990, Date: 2024-10-08 Tentative Ruling
Case Number: 24STCV05990 Hearing Date: October 8, 2024 Dept: 52
Order to Show Cause Re: Entry of Default
Judgment
Plaintiff David Calderon requests court judgment by default against
defendants Spacex Construction, Inc. and Marco Antonio Diazdelarosa. The application for default judgment has
three defects.
First,
plaintiff did not request dismissal of Does 1-100. A request for default judgment must include
“[a] dismissal of all parties against whom judgment is not sought or an
application for separate judgment against specified parties under Code of Civil
Procedure section 579, supported by a showing of grounds for each
judgment.” (Cal. Rules of Court, rule
3.1800(a)(7).) Plaintiff does not seek
default judgment against the Doe defendants and therefore must dismiss them.
Second,
plaintiff did not submit a proper proposed judgment. Plaintiff submitted a proposed “order for
judgment and court’s acceptance of copies in lieu of originals.” Plaintiff does not identify the copies referred
to. No such order is necessary. The court will require plaintiff to submit a
proposed judgment on Judicial Council form JUD-100.
Third,
plaintiff requests excessive attorney fees of $69,810. Attorney fees for a default judgment are
generally limited to a specified schedule based on the amount of the judgment. (Local Rules 3.207(a), 3.214(a).) For a judgment from “$10,000.01 to $50,000,”
the schedule provides for fees of “$690 plus 3% of the excess over $10,000. (Local Rule 3.214(a).) Under this schedule, plaintiff may recover
$1,699.15 in attorney fees.
A
plaintiff may recover “a fee greater
than listed in the [default] schedule because of extraordinary services.” (3.214(d).)
Plaintiff does not show extraordinary services justifying a fee greater
than the schedule.
Even
if the court found plaintiff may recover fees greater than the schedule,
plaintiff’s lodestar is unreasonable.
For example, the lodestar includes “$26,000 for 40 hours” anticipated
for “follow-up work for the Request for Court Judgment … and efforts to enforce
the judgment.” (Gonzalez Decl., ¶
41.) Plaintiff cannot recover tens of
thousands of dollars for attorney fees anticipated enforcing a judgment that
has not been entered. After plaintiff
obtains judgment, he may enforce it, then move for attorney fees as permitted
under the Enforcement of Judgments Law.
Plaintiff’s
request for default judgment is denied without prejudice. The court hereby continues the order
to show cause re: entry of default judgment to December 5, 2024, at 8:30
a.m. Plaintiff shall submit a revised
application for default judgment that corrects the above issues no later than
November 18, 2024.