Judge: Ashfaq G. Chowdhury, Case: EC065795, Date: 2023-12-22 Tentative Ruling

Case Number: EC065795    Hearing Date: December 22, 2023    Dept: E

Hearing Date: 12/22/2023 – 10:00am
Case No. EC065795
Trial Date: UNSET
Case Name: LEONID TEPLITSKY v. ILANA MALARAN

TENTATIVE RULING – MOTION TO MODIFY THE COURT’S JUNE 3, 2022 ORDER, OR BY ALLOWING THE RELASE OF SOME OF THE FUNDS HELD PURSUANT TO THAT ORDER

Moving Party:  Defendants, Ilana Malaran and Naralam, LLC

 

Responding Party: Plaintiff, Leonid Teplitsky

 

Moving Papers: Notice/Motion

 

Opposition Papers: Opposition; Evidentiary Objections to Declaration of Ilana Malaran

 

Reply: Reply

 

RELIEF REQUESTED¿ 
Defendants, Ilana Malaran and Naralam, LLC move the Court for an order modifying the Court’s June 3, 2022, or by allowing the release of some of the funds held pursuant to that order.

 

Defendants’ motion will be based upon this notice, the supporting declaration and exhibits thereto, the entire contents of the Court’s file, and such argument and evidence as the Court may permit.

 

BACKGROUND
The instant action involves two consolidated cases. In EC065795, Leonid Teplitsky alleged a cause of action for fraudulent conveyance against Ilana Malaran, Stanley Azrilyan, Deanna Azrilyan, Naralam LLC, and RX Ingredients, Inc. In LC105154, Leonid Teplitsky alleged causes of action for fraudulent conveyance and imposition of a constructive trust. In each of these consolidated cases, Plaintiff has alleged that RXI, Stanley, and/or Deanna fraudulently transferred their assets to Malaran/her companies to avoid having to pay a judgment they owed to Plaintiff. One of the fraudulent conveyances involved the property at 3184 Dona Sarita Place in Studio City and the other involved the property located at 4600 Burnet Avenue in Sherman Oaks.


ANALYSIS
Preliminary Matter
On 06/03/2022, this Court granted the motion to expunge the lis pendens filed by Ilana Malaran on 05/05/2022.

The Court stated, “The motion to expunge the lis pendens in both actions is GRANTED because claimant did not meet his burden by a preponderance of the evidence in establishing the probable validity of his claims. Further, no undertaking is ordered. If the claimant fails to meet his or her burden, the court must order that the notice be expunged and may not order an undertaking be given as a condition of expunging the notice. (CCP § 405.32.) However, the Court intends to Order that a complete and accurate Accounting be timely provided to all parties when any of the properties discussed herein are sold, conveyed, transferred, or otherwise encumbered, and that the proceeds of any such sale(s) remain in trust or escrow so long as these matters are pending.” (Min. Order 6/3/2022, p. 4.)

Further, after hearing argument, the Court noted, “The Court modifies its tentative, changing sanctions against Plaintiff and Plaintiff's counsel, to sanctions against Plaintiff and not Plaintiff's counsel. The tentative becomes the final order of the Court.” (Min. Order 6/3/2022, p.4-5.)

Legal Basis for the Motion
Movants’ motion does not cite or explain the legal authority by which they believe the Court can modify the Court’s 6/3/2022 Minute Order.

Their argument and theory as to why the Minute Order should be modified appears to be based on why the Movants personally think the order should be modified, based on changed circumstances in the case.

Movants state that since the time of the 6/3/2022 Minute Order, one of the properties at issue in this case – the 3184 Dona Sarita Property – was sold. Movants also state that the total proceeds to the Defendant now held in her counsel’s trust account are $2,035,724.80. Movants now wish to modify the 6/3/2022 Minute Order to allow the release of all but $700,000.00 of the currently held funds to Defendant Ilana Malaran, and that the June 3, 2022 order remain in effect as to the Burnet Property should it be sold during the pendency of this case.

Movants appear to believe that the amount held in her counsel’s trust account should be allowed to be reduced to $700,000 because:

1. At the time of the Court’s ruling, a trial date existed, but now the trial date is vacated. Further it is unclear whether matters in the criminal case will be sufficiently settled to allow a trial date to be set. Additionally, if the Court were inclined to set a bifurcated trial date in this matter, it is possible that no trial date will be available until well into 2024.

2. Since the time of the Court’s ruling, the Dona Sarita Property was sold, and the total proceeds to the Defendant, now held in her counsel’s trust account, are $2,035,724.80.

3. The other property in this case was recently appraised for $2,600,000.00.

4. The Court’s Order struck a balance between the parties’ interests and was not intended to be punitive towards Defendants’ interests.

5. According to Plaintiff’s 2/28/2023 Trial Brief, the current balance owed on the underlying judgment is $637,862.50. Therefore, the amount held in the trust is more than three times the current balance owed in Plaintiff’s 2/28/2023 Trial Brief. Further, the total value of the Burnet Property according to the recent appraisal is another four times that amount.

6. The Burnet Property and $700,000.00 would in effect equal approximately five times the amount of Plaintiff’s claim, rather than seven times the amount, and would thus strike a more equitable balance of the parties’ competing interests.

In Opposition, Plaintiff argues that the subject motion should be denied as an untimely motion for reconsideration of the June 3, 2022 Order. Plaintiff cites to CCP §1008(a), (b), and (e).

Discussion – Legal Basis for the Motion
Plaintiff’s argument that this motion is an untimely motion under CCP §1008(a) appears to be availing. CCP §1008(a) states, “When an application for an order has been made to a judge, or to a court, and refused in whole or in part, or granted, or granted conditionally, or on terms, any party affected by the order may, within 10 days after service upon the party of written notice of entry of the order and based upon new or different facts, circumstances, or law, make application to the same judge or court that made the order, to reconsider the matter and modify, amend, or revoke the prior order. The party making the application shall state by affidavit what application was made before, when and to what judge, what order or decisions were made, and what new or different facts, circumstances, or law are claimed to be shown.” (CCP §1008(a).)

This argument appears availing because Movants did not move within 10 days after service of written notice of entry of the order. Further, the Reply did not attack Opposition’s argument on this point.

As to whether this motion is untimely under 1008(b) and (e), the Court is unclear. The Court is unclear if this is untimely under 1008(e) because Opposition doesn’t explain why it is untimely under 1008(e). Further, Reply does not explain why this motion is timely under 1008(e). CCP §1008(e) states, “This section specifies the court’s jurisdiction with regard to applications for reconsideration of its orders and renewals of previous motions, and applies to all applications to reconsider any order of a judge or court, or for the renewal of a previous motion, whether the order deciding the previous matter or motion is interim or final. No application to reconsider any order or for the renewal of a previous motion may be considered by any judge or court unless made according to this section.” (CCP §1008(e).)

As to 1008(b), CCP §1008(b) states, “A party who originally made an application for an order which was refused in whole or part, or granted conditionally or on terms, may make a subsequent application for the same order upon new or different facts, circumstances, or law, in which case it shall be shown by affidavit what application was made before, when and to what judge, what order or decisions were made, and what new or different facts, circumstances, or law are claimed to be shown. For a failure to comply with this subdivision, any order made on a subsequent application may be revoked or set aside on ex parte motion.” (CCP §1008(b).)

As to 1008(b), Plaintiff’s Opposition argues:

CCP section 1008(b) is not an escape route for Malaran and Naralam because they are not seeking the "same order" in the Subject Motion as previously sought and there are no "new or different facts, circumstances, or law." The fact that the trial of this case was vacated on May 8, 2023 is not something that could not have been foreseen. Moreover, on May 8, 2023, when the Court asked counsel for Malaran and Naralam whether the trial date should be vacated because of the pending criminal proceedings against Stanley, Malaran's attorney responded in the affirmative.

 

In June, 2022 Malaran and Naralam had to know the value of the Dona Sarita and the Burnet Properties and the amount being claimed by plaintiff in this case. There is no evidence that the value of the Dona Sarita Property increased between June, 2022 and the date when Malaran entered into a contract to sell that property. Thus, Malaran and Naralam knew, or should have known, when the June 3, 2022 Order was entered how much equity Malaran had in that property and the value of the Burnet Property. Therefore, there are no changed circumstances.

 

(Oppo. p. 5-6.)

 

In Reply, it is unclear if the Reply is attacking Opposition’s argument on 1008(b). One portion of the Reply looks as if it may attack Opposition’s argument on 1008(b) and it states:

 

While Plaintiff argues – based purely upon supposition – that MALARAN and NARALAM, LLC “had to know the value” of the properties (Opposition, 6:2), a more important consideration would be, Did the Court know? And in fact, the Court had not solicited that information from the parties prior to its June 3, 2022, ruling, and neither party briefed the issue. As could be gleaned from a cursory reading of the motion to expunge, the opposition, etc., the value of the properties, was not addressed by either side. The Court’s June 3, 2022 ruling crafted an unusual compromise, one of the virtues of which was its originality. Code of Civil Procedure section 405.38, etc., does not propose the mechanism arrived at by the Court as a counterweight to expunging lis pendens.

 

[Footnote 1 state, “Moreover, the lis pendens had been in place by that point for close to six years, from the filing of this case in October 2016, to June, 2022. During that entire time the property was unmarketable – and real estate markets are notoriously fickle and dynamic. Suggesting that Defendant “had to know” ignores the circumstantial facts which Plaintiff himself helped shape.”]

 

While Plaintiff objects to Defendant indicating that she would like to use some of the money to open an education savings account for her child, the specificity of the objection misses the quite obvious point that ordinary people can think of countless good and useful things to do with their own money. Plaintiff’s suggestion to put the money into an interest-bearing account is similarly off the mark. Bank interest rates on deposits are universally pitiful, and as a basic principal of property rights, people should be able to use their money as they wish. As set forth in Article I, Section 1 of the California Constitution, the enumerated “inalienable rights” include acquiring and “possessing . . . property.”

 

(Reply p. 5-6.)

 

As to 1008(b), the Court finds Opposition’s argument persuasive, particularly that this motion is improper under 1008(b) because Movants don’t seek the same order. Further, in Reply, Movants don’t explain in any clear or understandable manner how 1008(b) applies. Most importantly, under 1008(b), it appears to be Movants’ burden to establish that 1008(b) has been met, and Movants do not do that in any type of understandable manner. Additionally, Movants didn’t even state that they were moving under 1008(b) in their moving papers. In fact, the moving papers did not cite any legal authority as to their basis for this motion.

 

In Reply, Movants cite to State of California v. Superior Court (Flynn) and argue that the constraints of 1008 do not apply to the matter sub judice. “Even without a change of law, a trial court has the inherent power to reconsider its prior rulings on its own motion at any time before entry of judgment.” (State of California v. Superior Court (Flynn) (2016) 4 Cal.App.5th 94, 100.)

 

As to this argument, Movants’ citation appears to be accurate. However, the Court has concerns about notice because Movants did not provide this as a basis under which they were seeking relief until their Reply. “A notice of motion must state in the opening paragraph the nature of the order being sought and the grounds for issuance of the order.” (CRC, Rule 3.110(a).)  At the hearing, the court will hear argument as to whether or not State of California v. Superior Court (Flynn) provides a legal basis for Movants to seek relief, and whether this grounds for relief was properly noticed before the Court.

 

In Reply, Movants also argue:

 

While the Court without a doubt crafted an original compromise on June 3, 2022, at the time of that ruling, a trial date had been set in this case. The June 3, 2022 ruling, at the time, did not appear to be what now amounts to the practically limitless withholding of more than two million dollars of a Defendant’s money – after she prevailed on her motion to expunge. Despite expunging the lis pendens, the Court effectively granted Plaintiff an attachment – though an actual attachment would require that Plaintiff show through competent evidence the probable validity of his claim (Code of Civ. Proc. §484.010), which the Court expressly found Plaintiff did not do, and would further require posting a bond (Code of Civ. Proc. §484.090(b)). None of the due process requirements which must be met for the issuance of a right to attach order were met.

 

(Reply p. 4-5.)

 

As to this argument, the Court finds it unavailing because Movants provide no legal authority to assess whether this argument has merit. Movants simply conclude that due process requirements were not met without providing a legal standard as to how they have established that argument.

 

Arguments Asserted by the Parties Not Rooted in Law
Both parties in Opposition and Reply assert arguments that don’t appear to be tied to any legal authority but according to their own equitable principles.

Opposition argues that the funds from the sale of the Dona Sarita Property need to remain in the trust account of the attorney for Malaran and Naralam to protect Plaintiff if he obtains a judgment against them and an award of punitive damages.

 

Opposition argues as follows:

 

The principal amount of the Judgment is $688,670.18. Thus, that is a component of the damages being claimed by plaintiff in each of the Subject Actions.

 

Punitive damages are requested in each of the Subject Actions. In cases such as the Subject Actions, a general measure of punitive damages if they are awarded would be a multiple of three of the general damages. This assumes that the defendants have the financial ability to pay such an amount but that appears to be the case with regard to Malaran and her companies.

 

If the general damages are $688,670.18, the punitive damages, if awarded, could likely be $2,066,010.54. That would result in a total judgment of $2,754,680.72 (the "Potential Judgment"). Therefore, that is the amount plaintiff believes is necessary to have reserved in accordance with the June 3, 2022 Order.

 

The Impounded Funds are less than the amount of the Potential Judgment. Therefore, those funds should not be released.  Otherwise, plaintiff will not have the protection that was to be afforded by the June 3, 2022 Order. This is especially important to plaintiff because of the history of this matter and Stanley's long history of felony convictions.

 

If the Burnet Property is sold, then plaintiff would then be willing to have the net sales proceeds received by the seller in excess of the difference between the amount of the Potential Judgment and the funds being held in connection with the sale of the Dona Sarita Property released to the seller provided that Malaran and her companies stipulate that the total Impounded Funds  from the sale of the two properties can be used to satisfy any judgment in favor of plaintiff in connection with either of the Subject Actions.

 

If Malaran and Naralam are concerned about the Impounded Funds being in a trust account where the interest is paid to the State Bar, that can be easily remedied by having the Impounded Funds deposited into a separate account where the interest will be paid to Malaran, not the State Bar.

 

As to Malaran's statement that she would like to use some of the Impounded Funds.to create an education savings account for her seven year old daughter, there is no evidence that those funds cannot be deposited from some other source or that they are now necessary.

 

(Oppo. p. 6-7.)

 

In Reply, Movants’ arguments as to this issue appear to be on pages 2-4 of the Reply

 

TENTATIVE RULING ON MOTION TO MODIFY THE 6/3/2022

MINUTE ORDER

The Court’s inclination is to grant the motion, if the Movants can appropriately address the notice issues discussed above.

 

The Court will hear argument as to the Plaintiff’s evidentiary objections.

 

TENTATIVE RULING – MOTION TO BIFURCATE TRIAL

Moving Party:  Defendants, Ilana Malaran, 4600 Group LLC, and Naralam LLC

 

Responding Party: Plaintiff, Leonid Teplitsky

 

Moving Papers: Notice/Motion

 

Opposition Papers: Opposition

 

Reply: Reply

 

RELIEF REQUESTED¿ 
Defendants, Ilana Malaran, 4600 Group, LLC, and Naralam, LLC  move the Court for an order bifurcating the trial – specifically, allowing the trial to proceed against all defendants except defendant Stanley Azrilyan, against whom a stay has been imposed.

 

Defendants’ motion will be based upon this notice, the supporting declaration and exhibits thereto, the entire contents of the Court’s file, and such argument and evidence as the Court may permit.


Legal Standard - Bifurcation

C.C.P. §598 provides as follows: 

The court may, when the convenience of witnesses, the ends of justice, or the economy and efficiency of handling the litigation would be promoted thereby, on motion of a party, after notice and hearing, make an order, no later than the close of pretrial conference in cases in which such pretrial conference is to be held, or, in other cases, no later than 30 days before the trial date, that the trial of any issue or any part thereof shall precede the trial of any other issue or any part thereof in the case, except for special defenses which may be tried first pursuant to Sections 597 and 597.5. The court, on its own motion, may make such an order at any time. Where trial of the issue of liability as to all causes of action precedes the trial of other issues or parts thereof, and the decision of the court, or the verdict of the jury upon such issue so tried is in favor of any party on whom liability is sought to be imposed, judgment in favor of such party shall thereupon be entered and no trial of other issues in the action as against such party shall be had unless such judgment shall be reversed upon appeal or otherwise set aside or vacated. If the decision of the court, or the verdict of the jury upon the issue of liability so tried shall be against any party on whom liability is sought to be imposed, or if the decision of the court or the verdict of the jury upon any other issue or part thereof so tried does not result in a judgment being entered pursuant to this chapter, then the trial of the other issues or parts thereof shall thereafter be had at such time, and if a jury trial, before the same or another jury, as ordered by the court either upon its own motion or upon the motion of any party, and judgment shall be entered in the same manner and with the same effect as if all the issues in the case had been tried at one time.

(CCP §598.)

 

C.C.P. §1048(b) provides, as follows, “  The court, in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial of any cause of action, including a cause of action asserted in a cross-complaint, or of any separate issue or of any number of causes of action or issues, preserving the right of trial by jury required by the Constitution or a statute of this state or of the United States.

“The major objective of bifurcated trials is to expedite and simplify the presentation of evidence.” (Foreman & Clark Corp. v. Fallon (1971) 3 Cal.3d 875, 888.)  

Bifurcation frequently occurs when the determination of one issue, such as an affirmative defense, renders other issues moot. (See, e.g., Buran Equipment v. H& C Investment Co. (1983) 142 Cal.App.3d 338, 343-344.) Trial courts also often bifurcate equitable and legal issues, resolving the issues of equity first in order to promote judicial economy. (Darbun Enters, Inc. v. San Fernando Community Hosp. (2015) 239 Cal.App.4th 399, 408-409.) 

TENTATIVE RULING MOTION TO BIFURCATE

The Court’s tentative is to grant this motion, but the Court will ask the parties to further address the issues.  In particular, the Court will ask the movants to explain how a bifurcated trial could be conducted without running afoul of the one-judgment rule and potentially conflicting findings.