Judge: David A. Rosen, Case: 20GDCV00419, Date: 2023-08-18 Tentative Ruling



Case Number: 20GDCV00419    Hearing Date: September 8, 2023    Dept: E

Case No: 20GDCV00419
Hearing Date: 09/08/2023 – 8:30am

Trial Date: 03/04/2025

Case Name: ALFRED JACKSON, et al. v. DELOITTE & TOUCHE LLP, et al.

 

I.                   RELIEF REQUESTED

The Notice page of this motion states that “Cross-Defendant EisnerAmper LLP (Eisner) will and hereby does make this Motion for an order to dismiss or stay this action based on improper venue.”

 

For the reasons set out below, the Court will grant Eisner’s Motion and dismiss the cross-complaint against Cross-Defendant Eisner.

 

 

II.                BACKGROUND

Plaintiffs filed a Complaint on 04/28/2020. Plaintiffs filed a FAC on 08/18/2020. Plaintiffs filed a SAC on 10/27/2020.

Defendant Opus filed a Cross-Complaint on 04/20/2021. A First Amended Cross-Complaint (FACC) was filed on 02/06/2023. A notice of errata to the FACC was filed on 2/22/2023.

Plaintiffs in the SAC are investors in Direct Lending Income Fund, L.P. (DLIF), a private investment fund managed by Direct Lending Investments, LLC (DLI).

The general background behind Plaintiffs’ allegations is that Plaintiffs collectively invested over $43,750,00.00 in Direct Lending Income Fund, L.P. (DLIF), which was formed and controlled by Brendan Ross’s Direct Lending Investment, Inc. (DLI), to invest primarily in online lending marketplaces (the Fund). The SAC further alleges that Ross and others (including Cross-Defendant Quarterspot) engineered false payments on bad loans in order to prop up returns and overcharge investors on fees, manipulated loan-level information that it reported to investors, and falsified borrower payment information to make it appear as though payments had been made by borrowers, causing DLIF to value many of the nonperforming Quarterspot loans at par when the value should have been reduced to zero.

The SAC does not bring claims against Ross, the Fund, or alleged bad actors like Quarterspot, but instead Plaintiffs sued the Fund’s auditor, Deloitte & Touche LLP and Deloitte Tax, LLP (collectively Deloitte).

Plaintiffs also sued Opus, the Fund’s administrator, who allegedly represented to Plaintiffs’ registered investment advisors that Opus would independently value the Fund’s assets.

Opus’s FACC appears to name four Cross-Defendants: (1) Deloitte & Touche and Deloitte Tax, LLP (collectively Deloitte), (2) Quarterspot, Inc., (3) Kroll, and (4) EisnerAmper LLP.

Cross-Defendant, EisnerAmper LLP (Eisner), now moves to dismiss or stay Opus’s FACC based on a forum-selection clause between Eisner and DLIF, an entity that is not a party to the FACC or the SAC.

III.             ANALYSIS

As a preliminary matter, Eisner’s motion is somewhat confusingly structured. It isn’t until page 16 of Eisner’s motion that Eisner finally mentions two statutes – CCP §§410.30 and 418.10 – that Eisner appears to be basing its motion on.

“The procedure for enforcing a forum selection clause is a motion to stay or dismiss for forum non conveniens.” (Olinick v. BMG Entertainment (2006) 138 Cal.App.4th 1286, 1294 citing Berg v. MTC Electronic Technologies (1998) 61 Cal.App.4th 349, 358.)

Eisner argues that a forum-selection clause between Eisner and DLIF (an entity that is not a party to the FACC or the SAC) provides a basis for Opus’s FACC to be dismissed with prejudice as to Eisner, or, alternatively, stayed pending the outcome of an action Opus might file in the proper New York State venue.

Eisner also argues: (1) The forum-selection clause is presumptively valid; (2) public policy favors enforcing the forum-selection clause, and (3) Opus was closely related to the contractual relationship between DLIF and Eisner.

“For [defendant] to demonstrate that it was ‘so closely related to the contractual relationship’ that it is entitled to enforce the forum selection clause, it must show by specific conduct or express agreement that (1) it agreed to be bound by the terms of the purchase agreement, (2) the contracting parties intended [defendant] to benefit from the purchase agreement, or (3) there was sufficient evidence of a defined and intertwining business relationship with a contracting party.” (Bugna v. Fike (2000) 80 Cal.App.4th 229, 233 citing Bancomer, S.A. v. Superior Court (1996) 44 Cal.App.4th 1450, 1461.)

Here, having reviewed the briefs and the supporting declarations, the Court concludes that Eisner has demonstrated that Opus was “so closely related to the contractual relationship” that “it is entitled to enforce the forum selection clause . . . .”  (Id.) 

As Eisner notes, the basis for Opus’s claims against Eisner are in fact founded on the engagement agreements between Eisner and DLIF.  Without those engagement agreements, Opus would appear to have no basis for any claim against Eisner.  (See FACC ¶¶ 14-25.)   This seems to be the primary obstacle that all of Opus’s arguments come up against:  Why is Opus suing Eisner?  It seems the answer is because it relied on Eisner as a result of the intertwined relationships that DLIF, Eisner, and Opus had.  (See Bugna, 80 Cal.App.4th at 233-35; Bancomer S.A., 44 Cal.App.4th at 1461; Lu v. Dryclean-U.S.A. of Calif., Inc. (1992) 11 Cal.App.4th 1490, 1493-94.)  The intertwined relationships of DLIF, Eisner, and Opus are at issue in the Plaintiffs’ FAC and Opus’s FACC: “The Plaintiffs in this action have alleged that the services provided by Opus as administrator to DLIF contained false information. Opus relied on Eisner Amper’s and Deloitte’s Audit reports and other services they provided to the Funds that are at issue in the SAC, and Opus relied upon the valuation policies and procedures created by Eisner Amper and Deloitte to provide administration services to DLIF that are at issue in the SAC.” (FACC ¶25.)

The Court is, for similar reasons, also persuaded by Eisner’s argument that Opus was acting as DLIF’s agent in carrying out many of DLIF’s obligations under the Eisner engagement agreements.

The Court concludes that Eisner has established, for the purposes of this motion, that the allegations and evidence presented on this motion support the conclusion that there was sufficient evidence of a defined and intertwined business relationship with a party bound by the forum-selection clause. (See Bugna, 80 Cal.App.4th at 233-34.)

“For [a party] to demonstrate that [a non-contracting party] was ‘so closely related to the contractual relationship’ that it is entitled to enforce the forum selection clause [against the non-contracting party], it must show by specific conduct or express agreement that (1) it agreed to be bound by the terms of the purchase agreement, (2) the contracting parties intended [the non-contracting party] to benefit from the purchase agreement, or (3) there was sufficient evidence of a defined and intertwining business relationship [between the non-contracting party and] a contracting party.” (Bugna v. Fike (2000) 80 Cal.App.4th 229, 233 citing Bancomer, S.A. v. Superior Court (1996) 44 Cal.App.4th 1450, 1461.)

Here, having reviewed the briefs and the supporting declarations, the Court concludes that Eisner has demonstrated that Opus was “so closely related to the contractual relationship” that “it is entitled to enforce the forum selection clause . . . .”  (Id.) 

Eisner’s argument that public policy favors enforcing the forum-selection clause is further justifies the conclusion that the forum-selection clause should be enforced.

IV.             Request for Judicial Notice

Eisner requests that the Court take judicial notice of various legal filings in federal court.

The Court takes judicial notice of the requested materials.  (Evid Code. §§ 452-53.)  The requested materials do not alter the Court’s ruling.

V.                Tentative Ruling  

For the reasons set out above, Eisner’s motion is GRANTED and the Cross-Complaint against Cross-Defendant Eisner is DISMISSED pursuant to CCP § 410.30.