Judge: Barbara M. Scheper, Case: 19STCV09932, Date: 2024-10-04 Tentative Ruling




Case Number: 19STCV09932    Hearing Date: October 4, 2024    Dept: 30

  

Dept. 30

Calendar No.

Verceles vs. Los Angeles Unified School District, et. al., Case No. 19STCV09932

 

Tentative Ruling re:  Defendant’s Motion for Attorney’s Fees or Cost of Proof Sanctions

 

Los Angeles Unified School District (Defendant) moves for an award of attorney’s fees and costs against Junnie Verceles (Plaintiff). The motion is granted in part. Attorney’s fees and costs are awarded to Defendant in the amount of $94,411.

 

“[A]s a general rule, attorney fees are not recoverable as costs unless they are authorized by statute or agreement.” (People ex rel. Dept. of Corporations v. Speedee Oil Change Systems, Inc. (2007) 147 Cal.App.4th 424, 429.) In actions under the Fair Employment and Housing Act (FEHA), “a prevailing defendant shall not be awarded fees and costs unless the court finds the action was frivolous, unreasonable, or groundless when brought, or the plaintiff continued to litigate after it clearly became so.” (Gov. Code, § 12965, subd. (c)(6).) Thus, a prevailing Defendant may successfully recover attorney’s fees if it can show that the action was frivolous when brought. (Cummings v. Benco Bldg. Services (1992) 11 Cal.App.4th 1383.)

 

Additionally, “[i]f a party fails to admit the genuineness of any document or the truth of any matter [in response to a request for admissions], and if the party requesting that admission thereafter proves the genuineness of that document or the truth of that matter, the party requesting the admission may move the court for an order requiring the party to whom the request was directed to pay the reasonable expenses incurred in making that proof, including reasonable attorney’s fees.” (Code Civ. Proc., 2033.420, subd. (a).” However, the party requesting admission is not entitled to fees if the admission sought was of no substantial importance, the party failing to make the admission had reasonable ground to believe they would prevail, or there was another good reason for the failure to admit. (Id. § 2033.420, subds. (b)(2)–(4).)

 

The attorney bears the burden of proof as to “reasonableness” of any fee claim. (Code Civ. Proc., § 1033.5, subd. (c)(5).) This burden requires competent evidence as to the nature and value of the services rendered. (Martino v. Denevi (1986) 182 Cal.App.3d 553, 559.) “Testimony of an attorney as to the number of hours worked on a particular case is sufficient evidence to support an award of attorney fees, even in the absence of detailed time records.” (Ibid.) 

 

A party’s verified billing invoices are prima facie evidence that the costs, expenses, and services listed were necessarily incurred. (See Hadley v. Krepel (1985) 167 Cal.App.3d 677, 682.) “In challenging attorney fees as excessive because too many hours of work are claimed, it is the burden of the challenging party to point to the specific items challenged, with a sufficient argument and citations to the evidence. General arguments that fees claimed are excessive, duplicative, or unrelated do not suffice.” (Lunada Biomedical v. Nunez (2014) 230 Cal.App.4th 459, 488, quoting Premier Medical Management Systems, Inc. v. California Ins. Guarantee Assn. (2008) 163 Cal.App.4th 550, 564.)

            In determining whether the requested attorney’s fees are “reasonable,” the Court’s “first step involves the lodestar figure—a calculation based on the number of hours reasonably expended multiplied by the lawyer’s hourly rate. The lodestar figure may then be adjusted, based on consideration of facts specific to the case, in order to fix the fee at the fair market value for the legal services provided.” (Gorman v. Tassajara Development Corp. (2008) 162 Cal.App.4th 770, 774 [internal citations omitted].) In determining whether to adjust the lodestar figure, the Court may consider the nature and difficulty of the litigation, the amount of money involved, the skill required and employed to handle the case, the attention given, the success or failure, and other circumstances in the case. (EnPalm LLC v. Teitler (2008) 162 Cal.App.4th 770, 774; PLCM Group, Inc. v. Drexler (2000) 22 Cal.4th 1084, 1095.)

 

            Defendant moves for an award of attorney’s fees in the amount of $295,503 pursuant to Government Code section 12965, subdivision (c)(6). Alternatively, Defendant requests cost of proof sanctions in the amount of $94,411 pursuant to Code of Civil Procedure section 2033.420, subdivision (a).

 

Defendant is not entitled to fees under Government Code section 12965.

            Defendant moves for an award of attorney’s fees on the ground that Plaintiff’s entire action was frivolous when instituted. To win an award under section 12965, subdivision (c)(6) based on the frivolousness of the plaintiff’s case, the defendant must show that “the plaintiff brought or continued litigating the action without an objective basis for believing it had potential merit.” (Lopez v. Routt, 17 Cal.App.5th 1006, 1011.) An action is not frivolous simply because plaintiff’s claim failed. (Baker v. Mulholland Security & Patrol, Inc. (2012) 204 Cal.App.4th 776, 784.)

 

            Here, Defendant asserts that Plaintiff admitted in his deposition that he sought to end his teacher dismissal hearing before it began because he believed he would be unsuccessful, thus barring any future civil claim on res judicata grounds. Defendant argues that such an admission demonstrates that Plaintiff did not believe his suit had any merit when he brought it. Plaintiff argues that this statement is misconstrued. Plaintiff contends that he sought to ensure he had access to comprehensive discovery and feared that an adverse decision at an administrative hearing would preclude that possibility. Plaintiff’s assertion is reasonable. Thus, Defendant has not demonstrated that Plaintiff’s case was frivolous based on his deposition testimony.

 

            Defendant also argues that the granting of its Anti-SLAPP motion, later overturned on appeal, demonstrates that Plaintiff’s lawsuit was frivolous. In that ruling, the Court determined that Plaintiff lacked evidence to support his claims. However, success on an Anti-SLAPP motion, at an early posture in a case before discovery is complete, does not itself show that a case is frivolous. Moreover, that ruling was later overturned on appeal.

 

            Finally, Defendant argues that Plaintiff’s case is frivolous because Plaintiff failed to survive summary judgment after five years of litigation. It is true that Plaintiff has amended his pleadings numerous times after sustained demurrers and opposed all of Defendant’s dispositive motions. However, unsuccessfully prosecuting a case does not demonstrate that the case started as, or later became, frivolous as Defendant suggests. Defendant does not win attorney’s fees simply because Plaintiff lost his case. (Robert v. Stanford University (2014) 224 Cal.App.4th 67, 70.) The length of Plaintiff’s case is in part attributable to the multiple Anti-SLAPP motions and appeals. Awarding attorney’s fees to defendants in long-lived cases would create perverse incentives for defendants and make it riskier for plaintiffs to fully prosecute cases under FEHA. Indeed, “assessing attorney’s fees against plaintiffs simply because they do not finally prevail would substantially add to the risks inhering in most litigation and would undercut the efforts of Congress to promote the vigorous enforcement of the provisions of Title VII.” (Cummings, supra, at p. 1388.)

 

            Thus, Defendant has not shown that Plaintiff brought or continued prosecuting his action without an objective basis for believing it had potential merit. Accordingly, Defendant’s request for attorney’s fees under Government Code section 12965, subdivision (c)(6) is denied.

 

Defendant is entitled to cost of proof sanctions.

            Defendant alternatively moves for an award of cost of proof sanctions under Code of Civil Procedure section 2033.420, subdivision (a). A party is entitled to fees under this provision if it proves a document’s genuineness or matter’s truth and the opposing party had failed to admit such when responding to an earlier request for admission. (Code Civ. Proc., § 2033.420, subd. (a).) A party may prove genuineness or truth through a successful motion for summary judgment. (Barnett v. Penske Truck Leasing (2001) 90 Cal.App.4th 494, 498.) However, sanctions are not to be awarded if the admissions sought were of no substantial importance or the party failing to make the admissions had reasonable ground to believe it would prevail. (Id., § 2033.420, subd. (b)(2), (3).) The party seeking to avoid sanctions has the burden of showing an exception applies. (Samsky v. State Farm Mutual Automobile Ins. Co. (2019) 37 Cal.App.5th 517, 523.)

 

            A discussion of the procedural history of the case is instructive here.  Plaintiff filed his complaint on March 21, 2019.  Defendant filed its first Anti-SLAAP motion on June 4, 2019, thus staying discovery.  The motion was granted on June 29, 2019.  Plaintiff appealed.  The Court of Appeals reversed, and the matter was returned to the trial court on July 16, 2021.  After Plaintiff filed his amended complaint, Defendant filed a second Anti-SLAAP motion on November 3, 2021, again staying discovery.  The Court denied the motion and Defendant appealed.  The Court of Appeals affirmed the Court’s ruling, and the matter was returned to the trial court on December 20, 2023.

            Shortly thereafter, Defendant served Plaintiff with ten requests for admission which Plaintiff denied for the most part on February 9, 2024.  Plaintiff sat for his deposition on February 28, 2024.

On May 13, 2024, Defendant filed its motion for summary judgment directed to the only remaining cause of action for retaliation in violation of FEHA.  The hearing on the motion was scheduled for July 30, 2024.  On July 8, 2024, Plaintiff applied ex parte for a continuance of the summary judgment hearing citing a need to conduct discovery.  The Court denied the ex parte on the grounds that Plaintiff had failed to satisfy the requirements of CCP Section 437c(h).

CCP Section 437c(h) provides:  “If it appears from the affidavits submitted in opposition to a motion for summary judgment or summary adjudication, or both, that facts essential to justify opposition may exist but cannot, for reasons stated, be presented, the court shall deny the motion, order a continuance to permit affidavits to be obtained or discovery to be had, or make any other order as may be just.”

            The declaration or affidavit in support of the request to continue must describe the discovery that is necessary to resist the motion.  (See Frazee v. Seeley (2002) 95 Cal.App.4th 627, 634-635.)  It is not sufficient merely to indicate that further discovery or investigation is contemplated.  (Bahl v. Bank of America (2001) 89 Cal.App.4th 389, 396-397.)  The declaration or affidavit must also make a good faith showing demonstrating that a continuance is necessary to obtain essential facts to oppose the motion.  The declaration should show (1) facts that establish a likelihood that controverting evidence may exist and why the information sought is essential to opposing the summary judgment motion, (2) specific reasons why this evidence cannot be presented at the present time, (3) an estimate of the time necessary to obtain this evidence, and (4) the specific steps or procedures that the party opposing the summary judgment motion intends to use to obtain this evidence.  (Johnson v. Alameda County. Med. Ctr. (2012) 205 Cal.App.4th 521, 532.)

            In exercising discretion under CCP Section 437c(h), a judge may properly consider the extent to which the requesting party’s failure to secure the contemplated evidence results from this party’s lack of diligence.  (Rodriquez v. Oto (2013) 212 Cal.App.4th 1020, 1038.)  A good faith showing that further discovery is needed to oppose summary judgment requires some justification as to why this discovery was not completed sooner.  (Cooksey v. Alexakis (2004) 123 Cal.App.4th 246, 257; Bushling v. Fremont Med. Ctr. (2004) 117 Cal.App.4th 493, 511-512.)

Plaintiff’s counsel’s declaration in support of the ex parte stated only that he had just served written discovery in June of 2024, had not received responses and had not noticed any depositions.  Plaintiff offered no explanation as to the evidence he believed existed or the depositions he wished to take.  Plaintiff did not address why he had not conducted this discovery sooner.

Plaintiff filed an untimely opposition to the motion for summary judgment but did not submit any evidence.  The Court granted the motion on July 30, 2024.

 

Turning to the requests for admissions, Plaintiff denied nine of the ten.  In particular, in request number 7, Plaintiff was asked to admit that he had no evidence to establish any retaliatory animus held by anyone at LAUSD towards Plaintiff Verceles for engaging in any activity protected by the Fair Employment and Housing Act.  Plaintiff denied this.  Yet weeks later he testified in deposition that he did not know or could not remember if anyone involved in the decision to terminate him even knew that he had filed a complaint with the DFEH.

Defendant successfully proved the truth of this request when the Court granted summary judgment on Plaintiff’s retaliation claim.  Accordingly, absent a showing by Plaintiff of an applicable exception, Defendant is entitled to fees.

            Plaintiff does not argue that an exception applies. Rather, Plaintiff contends that the requests for admissions themselves were improper, citing Universal Home Improvement, Inc. v. Robertson (2020) 51 Cal.App.5th 116 and Pappas v. Carolyn Chang (2022) 75 Cal.App.5th 975.

 

            In Universal Home, the court took issue with defendants serving requests for admissions at the start of a case seeking responses admitting that the plaintiff had no case, and later seeking to recover costs of proof fees when the plaintiff proved unsuccessful at trial. (Universal Home, supra at p. 130.) The court refused to award fees because the requests for admissions were vigorously contested at trial and because the defendants’ motion did not even refer to the trial court record. (Id. at p. 631.)

 

Here, Plaintiff’s responses to Defendant’s requests for admissions were served in February 2024 – almost five years after the action was commenced.  It is true that the action was stayed for significant periods of time as a result of the two Anti-SLAAP motions and subsequent appeals – the Court calculates that discovery was open for  approximately one year in total over the life of the case.  The Court also notes that the parties exchanged information and documents in connection with Plaintiff’s Skelly hearing that predated the filing of the lawsuit.

In addition, Plaintiff was deposed on February 28, 2024, less than a month after denying Defendant’s RFAs.  Plaintiff testified he had no knowledge or information demonstrating or even suggesting that anyone involved in the decision to terminate him even knew he had engaged in alleged protected activity by filing a complaint with the DFEH.

Finally, on July 8, 2024, Plaintiff applied ex parte for a continuance of the hearing on the motion for summary judgment then scheduled for July 30, 2024.  Plaintiff’s counsel’s declaration utterly failed to demonstrate any valid basis for a continuance.

 

            Based on the foregoing, this case is distinguishable from Universal Home and Pappas and therefore an award of fees and costs is appropriate.

 

Fee Calculation

Requested rates are reasonable if they are “within the range of reasonable rates charged by and judicially awarded comparable attorneys for comparable work.” (Children’s Hospital & Medical Center v. Bonta (2002) 97 Cal.App.4th 740, 783.) In calculating the lodestar rate, “the court may rely on its own knowledge and familiarity with the legal market, as well as the experience, skill, and reputation of the attorney requesting fees [Citation], the difficulty or complexity of the litigation to which that skill was applied [Citations], and affidavits from other attorneys regarding prevailing fees in the community and rate determinations in other cases. [Citation.]” (569 East County Boulevard LLC v. Backcountry Against the Dump, Inc. (2016) 6 Cal.App.5th 426, 437.)

           

            Defendant alleges that a reasonable award of fees under Code of Civil Procedure section 2033.420, subdivision (a) would be $94, 411. This includes $89,832 for attorney time and an additional $4,579 for the court reporting costs incurred while taking Plaintiff’s deposition. (Bejarano Decl. ¶ 13.) Defendant contends this deposition was critical for proving that Plaintiff’s denials were not reasonable. (Ibid.) Plaintiff argues that Defendant does not provide a declaration or billing statement describing the work done to justify such an award.

 

            Defendant’s counsel provides a declaration claiming that he has spent 152 hours since the denial of the requests for admissions to prove the matters within them as true. (Id. ¶ 10.) Defendant also contends that the Court has previously approved a $591 billing rate. (Id. ¶ 8.) A lodestar calculation using this hourly rate gives $89,832 in attorney’s fees. The declaration offered by defense counsel is sufficient to support such an award. (Martino, supra, at p. 559.)

 

            Accordingly, for 152 hours at a rate of $591 per hour, the Court awards attorney’s fees in the amount of $89,832, and an additional $4,579 in costs associated with taking Plaintiff’s deposition, totaling $94,411.