Judge: Ashfaq G. Chowdhury, Case: 24NNCV01884, Date: 2024-11-20 Tentative Ruling

Case Number: 24NNCV01884    Hearing Date: November 20, 2024    Dept: E

Hearing Date: 11/20/2024 – 8:30am
Case No. 24NNCV01884
Trial Date: UNSET
Case Name: ALLY BANK, a corporation; v. DANIELLE M. BALLINGER aka DANIELLE BALLINGER, an individual; DOES 1 through 10, inclusive

 

Application and Hearing for Claim and Delivery- Res ID 3966

RELIEF REQUESTED
Plaintiff, Ally Bank, a corporation, applies for a writ of possession after hearing (Code Civ. Proc. (CCP), § 512.010).

BACKGROUND
Plaintiff, Ally Bank, a corporation, filed a Complaint on 5/28/2024 against Defendant Danielle M. Ballinger aka Danielle Ballinger, an individual.

The caption of the Complaint lists the causes of action as “COMPLAINT FOR (1) CLAIM AND DELIVERY OF PERSONAL PROPERTY, FOR PRE-TRIAL WRIT OF POSSESSION, AND ORDER DIRECTING TRANSFER OF PERSONAL PROPERTY AND RESTRAINING ORDER, AND (2) MONEY DUE ON A CONTRACT.”

Plaintiff alleges that prior to the commencement of this action, pursuant to an assignment in writing, Plaintiff became and now is the owner of a written contract (“Contract”), pursuant to which Danielle M. Ballinger aka Danielle Ballinger purchased from Plaintiff’s assignor the subject 2021 Nissan Titan motor vehicle. (See Compl. ¶ 6.) Plaintiff alleges that it has been, and now is, the holder of a first priority security interest in the motor vehicle. (Id. at ¶ 7.) Plaintiff alleges that the Contract is in default because Ballinger failed to make the payment due and owing on 6/16/2023 or any of the regular monthly payments thereafter. (Id. at ¶ 8.)

PROCEDURAL

Moving Party: Plaintiff, Ally Bank, a corporation

Responding Party: No opposition by Defendant, Danielle M. Ballinger aka Danielle Ballinger

Moving Papers: Notice of Application for Writ of Possession and Hearing; Application for Writ of Possession after Hearing; Memorandum

Opposition Papers: No Opposition

Reply Papers: No Reply

ANALYSIS

Proof of Service Timely Filed (CRC, Rule 3.1300(c))
“Proof of service of the moving papers must be filed no later than five court days before the time appointed for the hearing.” (Cal Rules of  Court, Rule 3.1300(c).)

The moving papers for this motion appear to be the Notice of Application for Writ of Possession and Hearing, the Application for Writ of Possession after Hearing, and the Memorandum. The instant hearing is set for Wednesday, 11/20/2024. Five court days before the 11/20/2024 hearing would be 11/13/2024. Here, as of 11/18/2024 when the Court is drafting this tentative ruling, no proofs of service have been filed for any of the moving papers. Therefore, not only are there no proofs of service, even if a proof of service is filed before the hearing, the proof of service would be untimely.

16/21 Court Days Lapsed (CCP § 1005(b))
In relevant part of CCP § 1005(b), “Unless otherwise ordered or specifically provided by law, all moving and supporting papers shall be served and filed at least 16 court days before the hearing.” (Ibid.)

Here, the Court is unable to tell if the moving papers were timely served because no proof of service was filed to indicate when, or if, the moving papers were served upon Defendant. The moving papers were timely filed. However, the Court cannot tell if the moving papers were timely served due to the fact that no proof of service has been filed for any of the moving papers.

Proper Address
(CCP § 1013, § 1013a, § 1013b)
First, Plaintiff has not filed a proof of service for the moving papers for the Court to be able to determine what address Plaintiff served Defendant at. Second, the Court notes that it is unclear what the proper service address is for Defendant. Defendant has not appeared in the action. There is an Order to Show Cause Re: Failure to File Proof of Service currently set for 11/20/2024.

Service Related to Writ of Possession

“Upon the filing of the complaint or at any time thereafter, the plaintiff may apply pursuant to this chapter for a writ of possession by filing a written application for the writ with the court in which the action is brought.” (CCP § 512.010(a).)

Prior to the hearing required by CCP § 512.020(a), the defendant shall be served with all of the following:

 

(1) A copy of the summons and complaint.

(2) A Notice of Application and Hearing.

(3) A copy of the application and any affidavit in support thereof.

 

(CCP § 512.030(a).)

 

As previously explained, Plaintiff has not provided proof for meeting the requirements of CCP § 512.030(a)(2) and (a)(3) because Plaintiff has not provided a proof of service with its moving papers to indicate that the notice and application have been served.

 

Further, Plaintiff has not shown that the requirements of CCP § 512.030(a)(1) have been met. Not only has a proof of service not been filed to show service for the summons and complaint, but an order to show cause re: failure to file proof of service is currently set for 11/20/2024. Additionally, in the Case Management Statement filed on 11/6/2024 by Plaintiff, Plaintiff’s counsel appears to concede that the parties named in the complaint have not been served. (See CMC filed 11/6/2024, Section 3 titled “Service.”)

 

TENTATIVE RULING

 

Plaintiff has not provided proofs of service for any of the moving papers. Therefore, it is not clear if Defendant has received notice of this motion. Further, Plaintiff’s CMC Statement filed on 11/6/2024 appears to concede that Defendant has not been served the complaint.

Therefore, as a preliminary matter, Plaintiff has not met the requirements of CCP § 512.030.

The Court will hear argument as to if it should continue this hearing; however, as it stands right now, this motion must be denied.