Judge: Curtis A. Kin, Case: 24STCV14197, Date: 2025-02-11 Tentative Ruling

Case Number: 24STCV14197    Hearing Date: February 11, 2025    Dept: 86

APPLICATIONS (2) FOR RIGHT TO ATTACH ORDERS

 

Date:               2/11/25 (1:30 PM)

Case:                           Alber K. Karamanoukian et al. v. Mullen Technologies, Inc. et al. (24STCV14197)

 

 TENTATIVE RULING:

 

Plaintiff Alber K. Karamanoukian et al.’s application for right to attach order with respect to defendant Mullen Technologies, Inc. is GRANTED IN PART.

 

Plaintiff Alber K. Karamanoukian et al.’s application for right to attach order with respect to defendant David Michery is GRANTED IN PART.

 

I.                   FACTUAL BACKGROUND

 

On June 22, 2022, plaintiffs Albert K. Karamanoukian, as both an individual and trustee of the Alber Karamanoukian Trust (hereinafter “plaintiff”), and defendant Mullen Technologies, Inc. (“Mullen”) entered into a written commercial lease agreement (“Lease”), whereby Mullen leased premises located at 922 S. Myrtle Ave. and 133-135 E. Maple Ave. (collectively “Premises”), both in Monrovia. (Karamanoukian Decl. ¶ 7 & Ex. 1.) Defendant Michery guaranteed Mullen’s performance under the Lease. (Karamanoukian Decl. ¶ 8 & Ex. 2.) The term of the Lease is from August 15, 2022, to August 14, 2025. (Karamanoukian Decl. ¶ 7 & Ex. 1 at ¶ 1.3.)

 

According to plaintiff, defendants breached the Lease in two ways. First, on or about August 1, 2024, defendants abandoned the Premises without “providing a commercially reasonable level of security” or “reasonable assurances to minimize potential vandalism.” (Karamanoukian Decl. ¶¶ 14, 15 & Ex. 1 at ¶ 13.1(a).) Second, for the period commencing March 15, 2024, defendants have not paid rent due under the Lease. (Karamanoukian Decl. ¶¶ 17-22 & Ex. 1 at ¶ 13.1(b).)

 

In the instant applications, plaintiff seeks to attach $1,697,593.37, which includes the following: (1) $828,791.00 in principal base rent from March 15, 2024 to November 22, 2024, the date of filing of the instant applications (Karamanoukian Decl. ¶ 21); (2) $21,469.48 in interest through November 22, 2024 (Karamanoukian Decl. ¶¶ 12, 24); (3) $82,879.10 in late charges (Karamanoukian Decl. ¶¶ 11, 24); (4) $754,199.81 in future rent adjusted to present value (Karamanoukian Decl. ¶¶ 31, 32, 41); (5) $2,272.50 expended to re-let the Premises (Karamanoukian Decl. ¶ 34); and (6) $7,981.48 in attorney fees to enforce the Lease (Karamanoukian Decl. ¶¶ 36, 37, 39).

 

II.                ANALYSIS

 

Defendants’ evidentiary objections are OVERRULED.

 

Pursuant to CCP § 484.090, with respect to both applications, the Court finds:

 

  1. the claim is one upon which attachment may be issued;
  2. plaintiff has established the probable validity of at least part of the claim;
  3. attachment is not sought for any purpose other than recovery on the claim;
  4. the amount to be attached is greater than zero.

 

With respect to the probable validity of plaintiff’s claim, plaintiff demonstrates that the Lease provides for payment of rent and that Michery guarantied Mullen’s performance under the Lease. (Karamanoukian Decl. ¶¶ 8, 10 & Exs. 1 at ¶ 51(III), 2.) The Lease has an expiration date of August 14, 2025. (Karamanoukian Decl. ¶ 7 & Ex. 1 at ¶ 1.3.) Defendants stopped paying rent on March 15, 2024, before the expiration of the Lease. (Karamanoukian Decl. ¶¶ 20-22.) Unpaid rent remains outstanding under the Lease and Guaranty. (Karamanoukian Decl. ¶ 22.)

 

Defendants assert an affirmative defense based on failure to mitigate damages. (See Answer, Fifth Affirmative Defense.) “A plaintiff who suffers damage as a result of either a breach of contract…has a duty to take reasonable steps to mitigate those damages and will not be able to recover for any losses which could have been thus avoided.” (Shaffer v. Debbas (1993) 17 Cal.App.4th 33, 41.)

 

Defendants assert that plaintiff fails to provide sufficient evidence of reasonable efforts to mitigate. The Court agrees. Plaintiff declares: “Following Defendants’ unexcused abandonment of the Premises, Plaintiffs have actively pursued the re-letting of the Premises and have taken commercially reasonable measures to mitigate its damages, as more fully set forth in Paragraphs 34-35 below.” (Karamanoukian Decl. ¶ 16.) In paragraph 34 of plaintiffs’ declaration, he declares that, after defendants abandoned the Premises, he “engaged a real estate broker to market the Premises and used commercially reasonable efforts to re-let the Premises.” (Karamanoukian Decl. ¶ 34.) In paragraph 35, plaintiff declares: “As of the date of this declaration, Plaintiffs have been unable to re-let the Premises despite commercially reasonable efforts.” (Karamanoukian Decl. ¶ 35.) Plaintiff does not describe the efforts that he or the real estate broker took to market the Premises. Plaintiff’s conclusory averments do not allow the Court to determine whether plaintiff took reasonable steps to mitigate his damages.

 

On February 7, 2025, plaintiff Karamanoukian submitted a supplemental declaration stating that plaintiffs had entered into a new lease for a portion of the premises on February 6, 2025, pursuant to which the new tenants would pay $16,430 per month commencing April 1, 2025. (Karamanoukian Supp. Decl. ¶¶ 5-6.)  Consequently, plaintiffs reduce their request for attachment by $61,941.09 to $1,635,652.28. (Karamanoukian Supp. Decl. ¶¶ 7-8.)  While evidence of subletting a portion of the premises commencing eight months after Mullen vacated the property may demonstrate some effort at mitigation, without more, the Court cannot conclude that plaintiffs have sufficiently demonstrated reasonable efforts at mitigation to warrant a claim for attachment of the damages they seek.

 

Moreover, even if plaintiffs had provided meaningful evidence of reasonable steps to relet the Premises, the Court notes that Mullen requested permission from plaintiff to sublet the Premises in the summer of 2024. (Brown Decl. ¶ 7.) Paragraph 12, concerning assignment and subletting, was stricken from the Lease. (Karamanoukian Decl. ¶ 7 & Ex. 1 at ¶ 12.) “Unless a lease includes a restriction on transfer, a tenant's rights under the lease include unrestricted transfer of the tenant's interest in the lease.” (Civ. Code § 1995.210(b).) Because the Lease was silent as to whether Mullen could sublet the Premises, it appears Mullen has such a right under statute. Nevertheless, plaintiff refused to allow Mullen to sublet the Premises. (Brown Decl. ¶ 9 & Ex. A.) Because Mullen may have been able to sublet the Premises but for plaintiff’s refusal to grant permission, which would have reduced the outstanding rent owed under the Lease, the Court also finds that amount of rent owed by defendants from at least the time of abandonment of the Premises onward is not readily ascertainable, as required under CCP § 483.010(a).

 

For the foregoing reasons, the amount to be attached shall be reduced by the amount of rent, late charges, and interest claimed from August 2024 (the month when defendants abandoned the Premises) to July 2025. From August to November 2024, plaintiff claims $400,106.00 in base rent, $40,010.60 in late charges, and $2,654.33 in interest, for a total of $442,770.93. (Karamanoukian Decl. ¶ 24.) Plaintiff also claims $754,199.84 in rent due from December 2024 to July 2025. (Karamanoukian Decl. ¶ 32.) Further, because plaintiff does not describe his efforts to relet the Premises, the amount to be attached shall also be reduced by $2,272.50, the amount claimed for reletting expenses. (Karamanoukian Decl. ¶ 34.) The total reduction from the requested amount of attachment is $1,199,243.27.

 

Defendants assert that plaintiff is not entitled to an award of rent for the entire Lease term because Mullen returned the keys to plaintiff and plaintiff refused Mullen’s request for permission to sublet the Premises. (Opp. at 6:16-21; Brown Decl. ¶ 9 & Ex. A.) However, defendants do not dispute that they abandoned the Premises on August 5, 2024. (Brown Decl. ¶ 8.) Payments were due on the fifteenth of every month. (Karamanoukian Decl. ¶ 7 & Ex. 1 at ¶ 1.5.) Accordingly, defendants were obligated to pay rent from August 2022, when the Lease began, to July 2024, the last monthly payment due before defendants abandoned the Premises, because they were in possession of the Premises during this period. The rent from August 2022 to July 2024 remains unpaid (Karamanoukian Decl. ¶ 22), and plaintiff is entitled to attach that amount as damages flowing from the breach of the Lease and guaranty.

 

Defendants do not state exactly when in the summer of 2024 they asked plaintiff to allow them to sublet the Premises. (Brown Decl. ¶ 7.) Accordingly, the Court will allow the amount of unpaid rent for the period prior to defendants’ abandonment of the Premises to be attached. The amount to be attached shall include rent, late charges, and interest owed for March 2024, when Mullen stopped paying rent, to July 2024, plus attorney fees incurred to collect on the Lease. (See Karamanoukian Decl. ¶¶ 24, 36, 37, 39.)

 

The applications are GRANTED IN PART in the amount of $498,350.10 ($1,697,593.37 - $1,199,243.27 [August 2024 to end of Lease]).

 

With respect to the amount of undertaking, CCP § 489.220 provides for an undertaking in the amount of $10,000. Defendants seek an undertaking equal to at least 10% of the amount of the attachment sought on the ground that $10,000 is “grossly inadequate to compensate Defendant in the event the attachment is determined to be wrongful.” (Opp. at 8:1-3.) “If, upon objection to the undertaking, the court determines that the probable recovery for wrongful attachment exceeds the amount of the undertaking, it shall order the amount of the undertaking increased to the amount it determines to be the probable recovery for wrongful attachment if it is ultimately determined that the attachment was wrongful.” (CCP § 489.220(b).) Defendants do not adequately explain why 10% is necessary to compensate them for any wrongful attachment.

The Court will order an undertaking in the amount of $10,000 for each defendant.

 

The Court signs the proposed orders lodged on November 26, 2024 with modifications based on the ruling above. Further, with respect to the proposed order as to defendant Michery, the Court strikes “Furthermore, the real property located at 1323 El Paseo, La Habra Heights, CA 90631 (APN: 8238-027-028), pursuant to C.C.P. § 487.010(c)” from Attachment 3(C)(2). Plaintiff provides no evidence that the referenced real property belongs to defendant Michery.