Judge: Ashfaq G. Chowdhury, Case: 24NNCV00432, Date: 2024-08-09 Tentative Ruling

Case Number: 24NNCV00432    Hearing Date: August 9, 2024    Dept: E

Case No: 24NNCV00432
Hearing 08/09/2024 – 11:00am

Trial Date: UNSET

Case Name: OG PASADENA, LLC, a California limited liability company v. WILLIAM D. HOYMAN, an individual; ALL OTHER PERSONS UNKNOWN, CLAIMING ANY RIGHT TITLE, ESTATE, LIEN OR INTEREST IN THE REAL PROPERTY DESCRIBED IN THE COMPLAINT, ADVERSE TO PLAINTIFFS’ OWNERSHIP INTEREST OR ANY CLOUD ON PLAINTIFFS’ TITLE THERETO; and DOES 1-50, inclusive

 

MOTION 1

TENTATIVE RULING MOTION 1

A motion to strike ending with the Res ID 8374 is on calendar for 8/9/2024. This motion to strike (Res ID 8374) is DENIED as moot. It was filed on 6/27/2024 and is directed at Plaintiff’s original complaint filed on 3/22/2024. However, after the filing of this motion to strike on 6/27/2024, a First Amended Verified Complaint for Unlawful Detainer was filed on 7/10/2024.

MOTION 2
The instant motion to strike was filed on 7/23/2024 and is Defendant’s Motion to Strike Plaintiff’s First Amended Complaint for Unlawful Detainer After Foreclosure. This motion was originally scheduled for 8/30/2024; however, on 8/5/2024, this Court granted Plaintiff’s ex parte application for an order shortening time to hear Defendant’s Motion to Strike Plaintiff’s First Amended Complaint for Unlawful Detainer After Foreclosure. The 8/5/2024 Minute Order noted that the instant hearing on the instant motion to strike is scheduled for 08/09/2024.

PROCEDURAL ANALYSIS

Moving Party: Defendant, William D. Hoyman

Responding Party: Plaintiff, OG Pasadena, LLC

Moving Papers: Notice/Motion

Opposition Papers: Opposition

Reply Papers: No Reply submitted

Proof of Service Timely Filed (CRC Rule 3.1300): Ok
16/21 Court Days Lapsed (CCP § 1005(b)): Ok – the Court granted Plaintiff’s ex parte to hear this motion on the instant date.
Proper Address (CCP § 1013, § 1013a, § 1013b): Ok

RELIEF REQUESTED
Defendant, William D. Hoyman, moves pursuant to CCP §§ 435 and 436 to strike Plaintiff’s FAC on the grounds that it is not drawn in conformity with the laws of this state, in that it does not state in the caption “Action based on Code of Civil Procedure Section 1161a.”

The motion will be based on this notice of motion and motion, on the declaration of Defendant William D. Hoyman and the supporting memorandum served and filed with this notice and motion, on the records and file herein, and on such evidence as may be presented at the hearing of the motion.

Meet and Confer

Before filing a motion to strike pursuant to this chapter, the moving party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to the motion to strike for the purpose of determining if an agreement can be reached that resolves the objections to be raised in the motion to strike. If an amended pleading is filed, the responding party shall meet and confer again with the party who filed the amended pleading before filing a motion to strike the amended pleading. (CCP § 435.5(a).)

Here, in the Hoyman declaration, Hoyman makes no indication that he attempted to meet and confer.

“A determination by the court that the meet and confer process was insufficient shall not be grounds to grant or deny the motion to strike.” (CCP § 435.5(a)(4).)

LEGAL STANDARD – MOTION TO STRIKE
The court may, upon a motion, or at any time in its discretion, and upon terms it deems proper, strike any irrelevant, false, or improper matter inserted in any pleading. (Code Civ. Proc. § 436(a).) The court may also strike all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court. (Code Civ. Proc. § 436(b).) A motion to strike cannot be based upon the grounds that a complaint fails to state facts sufficient to constitute a cause of action, but instead is properly based on grounds of superfluous or abusive allegations, or improprieties in form or procedure. (Ferraro v. Camarlinghi (2008) 161 Cal.App.4th 509, 528-29.)   

The grounds for moving to strike must appear on the face of the pleading or by way of judicial notice. (Code. Civ. Proc. § 437; Turman v. Turning Point of Central California, Inc. (2010) 191 Cal.App.4th 53, 63 [“judges read allegations of a pleading subject to a motion to strike as a whole, all parts in their context, and assume their truth”].)   

Further, CCP § 431.10(a)-(c) states as follows:

(a) A material allegation in a pleading is one essential to the claim or defense and which could not be stricken from the pleading without leaving it insufficient as to that claim or defense.

(b) An immaterial allegation in a pleading is any of the following:

(1) An allegation that is not essential to the statement of a claim or defense.

(2) An allegation that is neither pertinent to nor supported by an otherwise sufficient claim or defense.

(3) A demand for judgment requesting relief not supported by the allegations of the complaint or cross-complaint.

(c) An “immaterial allegation” means “irrelevant matter” as that term is used in Section 436.

 

(CCP §§ 431.10(a)-(c).)

 

TENTATIVE RULING MOTION 2

 

Filing Fees

As a preliminary matter, this motion does not have a CRS #.

 

“[P]ayment of filing fees is both mandatory and jurisdictional.” (Hu vs. Silgan Containers Corp. (1999) 70 Cal. App. 4th 1261, 1269.) 

 

If Defendant wants this motion heard, Defenant is ordered to pay the filing fees prior to the hearing on this motion.

 

CCP § 1166(c)
“In an action regarding residential real property based on Section 1161a, the plaintiff shall state in the caption of the complaint “Action based on Code of Civil Procedure Section 1161a.”” (CCP § 1166(c).)

 

Defendant argues that under CCP §§ 435 and 436 the Court must enter an order striking Plaintiff’s FAC because it was not drawn in conformity with the laws of this state because Plaintiff did not state in its caption, “Action based on Code of Civil Procedure Section 1161a.”

 

The Court will hear argument.

 

First, even though Defendant argues that the Court “must” enter an order striking Plaintiff’s FAC on the grounds that the FAC is not drawn in conformity with the laws of this state, this Court notes how the language of CCP § 436 does not say “shall” or “must.” In relevant part, “The court may, upon a motion made pursuant to 435, or at any time in its discretion, and upon terms it deems proper…” (CCP § 436, emph. added.)

 

Further, the Court will hear argument because it is not entirely clear what Plaintiff’s position is in the Opposition with respect to CCP § 1161a.

 

On the one hand, Plaintiff argues that CCP § 1166(c) does not apply because the FAC does not allege that the real property at issue is residential real estate. Plaintiff points out that the FAC alleges that the subject property is being operated as an unlicensed boutique hotel/bed and breakfast commonly known as The Bissell House by Hoyman. Plaintiff argues that the subject property is thus a commercial operation, and therefore since this action is not based on residential property, 1166(c) doesn’t apply and Plaintiff does not have to state in its caption that this is an “Action based on Code of Civil Procedure Section 1161a.”

 

On the other hand, Plaintiff acknowledges that the FAC’s caption indicates it is an action based on 1161(a), instead of indicating that it is an action based on 1161a, no parentheses. Plaintiff thus argues that rather than striking the entire FAC for this minor infraction, the Court should strike only the parentheses surrounding the a in § 1161(a) so that the only remaining portion is § 1161a instead of § 1161(a).

 

Tentatively, the Court seems to agree that striking just the parentheses surrounding the a in § 1161(a) would be a more appropriate manner to handle the defect that Defendant is complaining about.

 

However, this raises the question: if the Court strikes the parentheses, is the Plaintiff in fact alleging that this is an action regarding residential real property based on section § 1161a, or is it not?

 

It seems as if Plaintiff should be the one to know this answer, since Plaintiff is the one bringing this action.

 

Further, even if this Court strikes only the parentheses, it still appears as if the Court would need to strike the parentheses and then grant leave to amend to file a second amended complaint so that Plaintiff can file the SAC that does not include the parentheses.

 

Because if the Court strikes the parentheses and Plaintiff doesn’t file an amended complaint without the parentheses, and this FAC becomes the operative complaint, the Court will not be able to tell that the parentheses were previously stricken from the FAC unless it is pointed out to the Court by one of the parties.

 

Further, the Court notes that this entire motion could have likely been avoided if Defendant Hoyman had complied with its obligations under CCP § 435.5 and met and conferred with Plaintiff.

 

MOTION 3 and MOTION 4

Motion 3 is Plaintiff’s motion that ends with the Res ID 6461. Motion 3 was filed on 6/20/2024.

 

In this motion, Plaintiff seeks an order to compel Defendant, William D. Hoyman, to appear for and attend his deposition along with the production of documents; for an order to compel inspection and access of the subject real property (201 Orange Grove Avenue, South Pasadena, CA) by Plaintiff, and for the imposition of monetary sanctions in the sum of $1,960.00.

 

Exhibit 1 of Motion 3 is Plaintiff’s notice of taking the deposition of Defendant and request for production of documents. This notice was served on May 31, 2024. This notice indicates that the deposition is to occur on June 20, 2024, and that Defendant is required to produce the documents that are requested in the 20 requests for production that are listed in this deposition notice.

 

Exhibit 2 of Motion 3 is Plaintiff’s demand for physical inspection of 201 Orange Grove Avenue, South Pasadena, A. The Demand for Inspection of Property in Exhibit 2 states:

 

Plaintiff, OG Pasadena, LLC, (“Asking Party” or “Plaintiff”), demand to Defendant, WILLIAM D. HOYMAN, to make available, without objection, Plaintiff’s statutory right to inspect and enter any portion (interior and exterior) of real property, located at 201 Orange Grove Avenue, South Pasadena, California for the purpose of inspecting, measuring, surveying, photographing, videotaping, taking inventory any portion of said property on the date of June 19, 2024, between the hours of 10:00 a.m. and 3:00 p.m. Said inspection, measuring, surveying, inventory and photographing will be done by visual inspection, photography, videography, tape measurement, and measurement by laser. Said inspection, measuring, surveying, taking inventory, and photographing may include opening doors, closing doors, or moving objects that are obstructing access to any portion of the premises. Access to all rooms, basements, appurtenant structures, garages, buildings, sheds, storage units, pool areas and the like shall be unlocked and immediately accessible to Plaintiff, its agents, attorneys, inspectors and contractors. The activities will not permanently alter or destroy the land, buildings or any items involved. However, the Plaintiff may and intends to install permanent security cameras at various locations on the property during the inspection. To complete this task, it may require multiple visit by licensed contractors to complete installation.

 

(Exhibit 2, Motion 3.)

This demand for inspection indicates that it was served on May 31, 2024 and that the inspection was to occur on June 19, 2024.

Motion 4 is Plaintiff’s motion that ends with the Res ID 0588. Motion 4 was filed on 7/11/2024.

The relief requested in Motion 4 states:

Plaintiff OG PASADENA, LLC (“Plaintiff”), will and hereby does apply to this Court, for an Order to further compel Defendant WILLIAM D. HOYMAN to appear for and attend his deposition with documents as previously ordered by this court and without objection; for an order to compel inspection and access of the subject real property located at 201 Orange Grove Avenue, South Pasadena, California, without objection or interference and for the imposition of monetary sanctions in the sum of $53,682.30.

This Application is based on this notice, the accompanying Memorandum of Points and Authorities, the Declaration of Daniel A. Nassie and any Exhibits attached thereto, and whatever oral and documentary evidence may be presented at the hearing on this matter.

(Pl. Mot. p. 2.)

ANALYSIS
As a preliminary matter, it is unclear if Motion 3 has been heard and ruled on based on Plaintiff’s arguments and based on the lack of clarity in the 6/24/2024 Minute Order.

Plaintiff’s Motion 3 was filed on 6/20/2024, and on 6/21/2024 Plaintiff filed an ex parte application for an order shortening time to hear Plaintiff’s Motion 3.

Confusingly, in the 6/24/2024 Minute Order [the date the Court heard Plaintiff’s ex parte application for an order shortening time to hear Plaintiff’s Motion 3], the Court not only granted the ex parte to shorten time to hear Plaintiff’s Motion 3, but the Court also noted that, “The deposition of defendant is ordered to proceed within the next five business days. The inspection of the property is ordered to proceed within the next five business days. Court notes the defendant’s objections. Plaintiff to file Proposed Order for Court to sign.” (Min. Order, 6/24/2024, p. 2.)

This is confusing because despite the fact that the ex parte was for shortening time to hear Motion 3, it appears as if the 6/24/2024 Minute Order compelled the deposition and the inspection of property, which was the relief that was actually sought in Motion 3, not the ex parte. Or to phrase it differently, it seems as if the 6/24/2024 Minute Order ruled on matters brought up in Motion 3, and not just on the issue of shortening time, which is what the ex parte was about.

Further, if the 6/24/2024 did in fact rule on matters brought up in Motion 3, the Court did not mention anything with respect to the request for production of documents. Motion 3, in relevant part, sought to compel the deposition, along with document requests in the deposition notice, and an inspection of the property. The 6/24/2024 Minute Order only commented on the deposition and inspection of property, not the document requests.

To add further confusion, in Plaintiff’s Motion 4 that was filed on 7/11/2024, Plaintiff indicates that on 6/24/2024, this Court granted Plaintiff’s ex parte application to compel the deposition of Defendant and for inspection of the subject real property. This adds further confusion because the ex parte was titled as an ex parte for an order shortening time to hear Motion 3, not an ex parte to actually compel the deposition and inspection of property.

Therefore, the Court will hear argument as to whether or not Motion 3 was ruled on, and what the ex parte hearing on 6/24/2024 did and did not rule on. The ex parte on 6/24/2024 did not discuss the production of documents in the deposition notice.

Further, the Court is uncertain as to what Plaintiff’s Motion 4 is.

Plaintiff’s Motion 4 requests this Court for an order to “further compel Defendant WILLIAM D. HOYMAN to appear for and attend his deposition with documents as previously ordered by this court and without objection; for an order to compel inspection and access of the subject real property located at 201 Orange Grove Avenue, South Pasadena, California, without objection or interference and for the imposition of monetary sanctions in the sum of $53,682.30.” (Pl. Mot 4, p. 2.)

This request is confusing because if Plaintiff is requesting Defendant to comply with the Court’s previous order to attend the deposition and allow inspection of the property, then it appears as if Plaintiff’s Motion 4 should have been brought under CCP § 2025.450(h) because that statute pertains to when a party deponent fails to obey a previous order to compel.

However, it is confusing if Plaintiff is in fact seeking an order based on Defendant failing to obey a previous order because Plaintiff’s Motion 4 also mentions how after the 6/24/2024 hearing on the ex parte, Plaintiff re-noticed the deposition and inspection to take place.

Therefore, it appears as if Plaintiff is basing Motion 4 on a different deposition notice than Motion 3, in which case it is possible that a motion to compel a deposition under 2025.450(a)-(b) would be more appropriate than moving to compel under 2025.450(h) for failing to comply with a prior order.

Overall
Setting aside whether or not Motion 3 was already ruled on, it is difficult to determine what should be done with respect to Motion 3 because it is difficult to determine the legal authority that Plaintiff is basing its request for relief in Motion 3.

The notice of Motion for Motion 3 does not indicate which statute Plaintiff is moving under. While the notice does not indicate which statute Plaintiff is moving under, the memorandum in Motion 3 does in fact cite to CCP § 2025.450. However, Plaintiff does not explain how it has satisfied the requirements of § 2025.450(a)-(b). For example, Motion 3 seeks not only to compel a deposition, but the deposition notice included requests for production. Under § 2025.450(b), the motion shall set forth specific facts showing good cause justifying the production for the things described in the deposition notice. (See CCP § 2025.450(b).) Nowhere in Motion 3 does Plaintiff address the requests for production; therefore, the Court fails to see how Plaintiff demonstrated good cause for the production requests.

Additionally, Motion 3 not only sought to compel the deposition and production requests as indicated from the deposition notice, but Motion 3 also sought an order to compel inspection and access of the subject real property.

It appears as if seeking to compel inspection of the subject property is an entirely different discovery tool. CCP § 2025.450(a) pertains to “after service of a deposition notice.” The demand for physical inspection has nothing to do with the deposition notice. In fact, the demand for physical inspection located in Exhibit 2 of Motion 3 cites to § 2031.010. Plaintiff’s Motion 3 does not cite any legal authority as to what statute applies to compelling a demand for physical inspection, nor does Plaintiff’s Motion 3 cite to how it met the applicable statutory requirements, whatever those may be. Additionally, since the demand for physical inspection appears to be a completely different discovery tool than the deposition notice, it appears as if Plaintiff’s Motion 3 should have been separated into two motions because a motion must be brought separately as to each discovery method at issue – here the deposition notice and the demand for physical inspection.

Therefore, the Court will hear argument as to if Motion 3 should have been separate into two motions. “[P]ayment of filing fees is both mandatory and jurisdictional.”  (Hu vs. Silgan Containers Corp. (1999) 70 Cal. App. 4th 1261, 1269.) 

Likewise, Motion 4 faces several of the same issues that Motion 3 faced. Motion 4 does not cite to any legal authority for the basis of its relief requested. Not only does the notice page in Motion 4 not cite the statutory basis, but the memorandum also does not cite to any statutory basis for the relief requested. Further, whatever statutory section is applicable here for Motion 4, Plaintiff makes no attempt to explain how it met those requirements, whatever they may be. Additionally, Motion 4 faces the same problem that Motion 3 faced with respect to not filing two separate motions for the two separate discovery tools – the deposition notice and the physical inspection demand.

To make matters even worse, not only are Motions 3 and 4 unclear and not rooted in argumentation being tied to legal authority, but Defendant’s opposition papers are equally as unclear.

Defendant filed a document on 7/23/2024 titled, “Defendant’s Objection And Notice of Non-Consent To Plaintiff’s Demand To Install Video Surveillliance [sic] Spy Technology Disguised As A Mere Inspection Of Real Property; Declaration of William D. Hoyman.” The Court notes that it is unclear if this document is directed at the Demand for Inspection of Property that was supposed to take place on June 19, 2024 or if it is directed at the amended Demand for Inspection of Property that was to take place on June 27, 2024.

Defendant also filed a document on 7/23/2024 that is an Opposition to Plaintiff’s Motion to Further Compel Defendant’s deposition with production of documents and order to compel inspection.

Defendant’s documents in Opposition are equally as difficult to decipher as Plaintiff’s motion because Defendant also fails to cite legal authority for its arguments on many occasions.

With respect to Defendant’s objection to Plaintiff’s demand to install video spy surveillance, Defendant states:

Pursuant to CCP § 1161a, in order to have occupants removed from the premises, Plaintiff OG Pasadena, LLC (“Plaintiff”) must prove:

a.       that the property was sold in accordance with CIV § 2924 under a power of sale in a deed of trust;

b.      that title under the sale has been duly perfected;

c.       that the occupant(s) were served a valid notice to quit; and,

d.      that the occupant(s) still occupies the premises after expiration of a valid notice to quit.

(Def. Objection p. 2.)

Confusingly, although Defendant states “pursuant to CCP § 1161a,” it is unclear where Defendant is getting the aforementioned language. CCP § 1161a consists of subsections (a)-(d), and Defendant does not cite a single subsection.

Setting that issue aside, Defendant admits he still occupies the premises and that there is no additional evidence needed by Plaintiff to “prove this element.”

Defendant argues that an inspection wouldn’t produce any relevant evidence in support of its allegations of a 2924-compliant sale, duly perfected title, or service of a valid notice to quit.

Defendant argues that the inspection of physical property is harassing and abusive because it requests that Plaintiff may and intends to install permanent security cameras. Defendant argues that this inspection goes beyond the legislative intent to allow alteration of property or install security cameras. Defenant argues the spy cameras violate his constitutional rights.

In Defendant’s Opposition to Plaintiff’s Motion to Further Compel Defendant’s deposition with production of documents and order to compel inspection, Defendant also asserts the same argument that it previously asserted in its objection document with respect to 1161a and how the inspection will not produce evidence to prove an essential element of Plaintiff’s claim because Defendant admits that it still occupies the subject property, so no additional evidence is needed. In this Opposition, Defendant cites CCP § 1161a(b) as the elements for Plaintiff’s cause of action.

While it is not entirely clear how Defendant is arriving at what the elements of § 1161a(b) are, the Court notes what § 1161a(b) states:

(b) In any of the following cases, a person who holds over and continues in possession of a manufactured home, mobile home, floating home, or real property after a three-day written notice to quit the property has been served upon the person, or if there is a subtenant in actual occupation of the premises, also upon such subtenant, as prescribed in Section 1162, may be removed therefrom as prescribed in this chapter:

(1) Where the property has been sold pursuant to a writ of execution against such person, or a person under whom such person claims, and the title under the sale has been duly perfected.

(2) Where the property has been sold pursuant to a writ of sale, upon the foreclosure by proceedings taken as prescribed in this code of a mortgage, or under an express power of sale contained therein, executed by such person, or a person under whom such person claims, and the title under the foreclosure has been duly perfected.

(3) Where the property has been sold in accordance with Section 2924 of the Civil Code, under a power of sale contained in a deed of trust executed by such person, or a person under whom such person claims, and the title under the sale has been duly perfected.

(4) Where the property has been sold by such person, or a person under whom such person claims, and the title under the sale has been duly perfected.

(5) Where the property has been sold in accordance with Section 18037.5 of the Health and Safety Code under the default provisions of a conditional sale contract or security agreement executed by such person, or a person under whom such person claims, and the title under the sale has been duly perfected.

(CCP § 1161a(b).)

The Court will hear arguments as to if an inspection of the property is needed.

Defendant also argues that Plaintiff cites no provision within CCP § 2013.010 that entitles Plaintiff to install spy cameras and make invasive alterations to the property.

Defendant also argues that since the discovery was served on May 31, 2024, there was no claim before the Court because the FAC was not filed until July 10, 2024. The Court does not find this argument availing. The original complaint was filed on 3/22/2024. On 5/29/2024, this Court denied Defendant’s motion to quash service of summons. Defendant provides no on point legal authority that there was no controversy before the Court and that Plaintiff’s lacked standing simply because an amended complaint was served after discovery was served, despite the fact that the Court denied Defendant’s motion to quash service of summons on 5/29/2024.

Defendant’s Opposition also argued that the deposition was unilaterally scheduled; however, Defendant cites no legal authority that this is grounds to deny a motion to compel a  deposition.

TENTATIVE RULING MOTIONS 3 and 4
The Court will hear argument. Both parties fail to explain their arguments in any type of comprehensible manner that is tied to legal authority. Both motions 3 and 4 requested sanctions. The Court will also hear argument on sanctions.