Judge: Barbara M. Scheper, Case: 23STCV25583, Date: 2024-03-04 Tentative Ruling




Case Number: 23STCV25583    Hearing Date: March 4, 2024    Dept: 30

Dept. 30

Calendar No.

Zheng vs. The Law Offices of Angela Swan, et. al., Case No. 23STCV25583

 

Tentative Ruling re:  Defendants’ Demurrer to Complaint; Motion to Strike

 

            Defendants Law Offices of Angela Swan and Angela Swan demur to Plaintiff’s complaint for professional negligence.  The demurrer is overruled.  Defendants are ordered to answer with ten (10) days of today’s date.

 

The party against whom a complaint has been filed may object to the pleading, by demurrer, on several grounds, including the ground that the pleading does not state facts sufficient to constitute a cause of action and it cannot be determined how, or in what manner, Defendants committed or can be liable for such cause of action. (Code Civ. Proc. §§ 430.10(e) and 430.10(f).)

“A demurrer tests the sufficiency of a complaint as a matter of law.”  (Durell v. Sharp Healthcare (2010) 183 Cal.App.4th 1350, 1358.) “[T]he court gives the complaint a reasonable interpretation, and treats the demurrer as admitting all material facts properly pleaded.”  (Ibid.) A demurrer accepts as true all well pleaded facts and those facts of which the court can take judicial notice but not deductions, contentions, or conclusions of law or fact. (Fox v. JAMDAT Mobile, Inc. (2010) 185 Cal.App.4th 1068, 1078.) Although courts construe pleadings liberally, sufficient facts must be alleged to support the allegations pled to survive a demurrer. (Rakestraw v. California Physicians' Serv. (2000) 81 Cal.App.4th 39, 43.) 

Where a demurrer is sustained, leave to amend must be allowed where there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 349.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Ibid.) “If there is any reasonable possibility that the plaintiff can state a good cause of action, it is error to sustain a demurrer without leave to amend.” (Youngman v. Nevada Irrigation Dist. (1969) 70 Cal.2d 240, 245.) 

 

Initially, the Court rejects Defendants’ contention that the complaint is ambiguous,

unintelligible, and uncertain as the complaint clearly sets forth the allegations against Defendants.

 

            “The elements of a cause of action in tort for professional negligence are: (1) the duty of the professional to use such skill, prudence, and diligence as other members of his profession commonly possess and exercise; (2) a breach of that duty; (3) a proximate causal connection between the negligent conduct and the resulting injury; and (4) actual loss or damage resulting from the professional’s negligence.” (Budd v. Nixen (1971) 6 Cal.3d 195, 200.)

 

            The Court finds that Plaintiff has sufficiently alleged a cause of action for professional negligence against Defendants. (Complaint, ¶¶ 6-21.)

 

            As to Defendants’ argument that the first cause of action is barred by the statute of limitations, the Court rejects such contention. “An action against an attorney for a wrongful act or omission . . . arising in the performance of professional services shall be commenced within one year after the plaintiff discovers, or through the use of reasonable diligence should have discovered, the facts constituting the wrongful act or omission, or four years from the date of the wrongful act or omission, whichever occurs first.” (Code Civ. Proc., § 340.6, subd. (a).) Here, Plaintiff alleges that he discovered Defendants’ wrongful actions on August 22, 2023 (Complaint, ¶ 20), and the complaint in this action was filed on October 19, 2023. Thus, the first cause of action is not barred by the statute of limitations.

 

            The Court finds that Defendants’ argument that Plaintiff failed to mitigate damages is inapposite to a determination of whether the first cause of action states sufficient facts to constitute a cause of action. Thus, Defendants’ citation to Shaffer v. Debbas (1993) 17 Cal.App.4th 33, 41 is inapposite.  

 

Motion to Strike

            Defendants move to strike Paragraph 21 from the complaint and argue that Defendant Angela Swan should be dismissed as she is an employee of The Law Offices of Angela Swan. (Motion, p. 10:1-11:13.)   

            “[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.” (Cal. Rules of Court, Rule 3.1110, subd. (a).) “A notice of motion to strike a portion of a pleading must quote in full the portions sought to be stricken except where the motion is to strike an entire paragraph, cause of action, count, or defense. Specifications in a notice must be numbered consecutively.” (Cal. Rules of Court, Rule 3.1322, subd. (a).)

Defendants filed a “Demurrer With Motion to Strike Plaintiff’s Complaint”; however, the notice of motion does not specifically reference grounds for the motion to strike or what portions of the complaint that Defendants seek to strike. Defendants merely provide a two-page argument included in the demurrer which requests that the Court strike damages from the first cause of action and dismiss Angela Swan as a defendant. Defendants have improperly combined their demurrer and motion to strike into one memorandum of points and authorities and have failed to give proper notice concerning the motion to strike.