Judge: David S. Cunningham, Case: JCCP5101, Date: 2022-09-29 Tentative Ruling



Case Number: JCCP5101    Hearing Date: September 29, 2022    Dept: 11

JCCP 5101 (Clergy Cases)

 

Tentative Ruling Re: Motion to Vacate and Strike Re: 20STCV49905 (John Doe D.G.)

 

Date:                           9/29/22

Time:                          9:00 am

Moving Party:           Defendant Doe 1 and Defendant Doe 2 (jointly “Defendants”)

Opposing Party:        John Doe G.D. (“G.D.”) and John Doe J.H.C. (“J.H.C.”) (jointly “Plaintiffs”)

Department:              11       

Judge:                        David S. Cunningham III

________________________________________________________________________

 

TENTATIVE RULING

Defendants’ motion to vacate and strike is denied.

 

BACKGROUND

 

This coordinated proceeding involves approximately 475 Plaintiffs.  The complaints allege that clergy members sexually assaulted Plaintiffs when they were minors.  The Institutional Defendants allegedly failed to protect Plaintiffs from the alleged assaults.

 

Here, Defendants move to strike G.D. and J.H.C.’s complaint, arguing that Judge Timothy Dillon’s orders approving the certificates of merit and service of process are invalid.

 

LAW

 

Motion to Strike

 

“Motions to strike can be used to reach defects in or objections to pleadings that are not challengeable by demurrer.  Complaints, cross-complaints, answers and demurrers are all subject to a motion to strike [citation].”  (Weil & Brown, Cal. Prac. Guide: Civ. Proc. Before Trial (The Rutter Group 2022) ¶ 7:156.)  “Moreover, a motion to strike can be used to attack the entire pleading, or any part thereof—i.e., even single words or phrases (unlike demurrers).”  (Ibid.)

 

Unless the action is a limited civil case, the motion lies either:

 

* To strike any ‘irrelevant, false or improper matter inserted in any pleading’; or

 

* To strike any pleading or part thereof ‘not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.’  [Citation.]

 

(Id. at ¶ 7:167, emphasis in original.)

 

As with demurrers [citation], the grounds for a motion to strike must appear on the face of the pleading under attack, or from matter which the court may judicially notice (e.g., the court's own files or records).”  (Id. at ¶ 7:168.)

 

“Thus, for example, defendant cannot base a motion to strike the complaint on affidavits or declarations containing extrinsic evidence showing that the allegations are ‘false’ or ‘sham.’  Such challenges lie only if these defects appear on the face of the complaint, or from matters judicially noticeable.”  (Id. at ¶ 7:169, emphasis in original.)

 

Certificates of Merit and Corroborative Fact

 

“Special procedures are required in actions by a plaintiff who is 40 or older for childhood sexual assault.”  (Id. at ¶ 1:913.1.)  Before serving any defendant, plaintiffs must file a certificate of merit with the court as to each defendant allegedly responsible for the abuse.  The certificate must show that, in the opinion of both plaintiff's attorney and a qualified mental health practitioner, there is reason to believe plaintiff was subject to the childhood sexual abuse alleged in the complaint.”  (Id. at ¶ 1:913.3.)  “If more than one defendant is sued, the attorney must file separate certificates of merit for each defendant.”  (Ibid.)  “The court must review the certificates in camera to determine if there is a ‘reasonable and meritorious cause for the filing of the action’ against each particular defendant.  If such finding is made, the duty to serve that defendant arises.”  (Ibid.; see also id. at ¶ 1:469.5 [“In cases brought by victims of childhood sexual assault who are over 40 at the time of the case filing, plaintiff's counsel must certify counsel has consulted with a mental health practitioner and concluded there is merit to the case.  The practitioner must execute a certificate that “there is a reasonable basis to believe that the plaintiff had been subject to childhood sexual abuse.”].)

 

“The person charged with the abuse shall not be named and shall be referred to only as ‘Doe’ in the original complaint filed with the court.”  (Id. at ¶ 1:0913.2.)  Plaintiff must apply to the court for leave to amend the complaint to name the defendant.  Such application must be accompanied by a ‘certificate of corroborative fact’ executed by plaintiff's attorney.”  (Id. at ¶ 1:913.4.)

 

“Failure to comply with the above requirements [citation] is ground for demurrer or motion to strike the complaint and for disciplinary action against plaintiff's attorney.  (Id. at ¶ 1:913.5, emphasis in original.)

 

DISCUSSION

 

On 12/31/20, Plaintiffs filed the complaint.

 

On 2/23/22, Judge Jill Feeney transferred the case to Judge Dillon.

 

On 3/18/22, Judge Dillon granted Plaintiffs’ ex parte application to approve the certificates of merit, name Defendants by their real names, file amendments to the complaint, and serve Defendants with process.

 

On 3/25/22, Plaintiffs filed the amendments, adding Defendants’ real names.

 

On 3/30/22, Defendants acknowledged receipt of the amendments.

 

The first issue is whether Defendants’ motion is timely.  Code of Civil Procedure section 340.1(k) states that “[t]he failure to file certificates in accordance with this section shall be grounds for a demurrer pursuant to Section 430.10 or a motion to strike pursuant to Section 435.”  (Code Civ. Proc. § 340.1, subd. (k), emphasis added.)  Section 435 requires a motion to strike to be filed “‘within the time allowed to respond to a pleading’ – e.g., 30 days after service of the complaint or cross-complaint unless extended by court order or stipulation.”  (Weil & Brown, supra, at ¶ 7:159.)  Defendants moved to strike on 7/11/22, more than 30 days after Judge Dillon granted leave to serve process, Plaintiffs filed the amendments, and Defendants acknowledged receiving the amendments.  The record lacks evidence of an order or stipulation extending the time to respond, so the motion appears to be late.  This is reason enough to deny the motion and to decline to consider Defendants’ arguments.

 

The motion also appears late in terms of reconsideration.  Effectively, the motion is a request for the Court to reconsider Judge Dillon’s orders approving the certificates of merit and granting permission to serve process.  Defendants filed the motion well beyond Code of Civil Procedure section 1008’s 10-day time limit.

 

Defendants contend Judge Dillon’s orders are invalid – and the motion should be granted – because:

 

* the mental health certificates for G.D. and J.H.C. are exactly the same and fail to state sufficient facts (see Motion, pp. 2-3);

 

* the attorney certificates for G.D. and J.H.C. are exactly the same and fail to state sufficient facts (see id. at pp. 3-4);

 

* Judge Dillon’s 3/18/22 minute order fails to identify the documents he reviewed (see id. at p. 5);

 

* the 3/18/22 hearing constituted an improper ex parte hearing (see id. at pp. 5-8 [asserting that Judge Dillon “had a private ex parte hearing with Plaintiff[s’] counsel”]).

 

Plaintiffs disagree.  They contest each of these arguments.  (See Opposition, pp. 4-7.)

 

The Court is willing to discuss the factual disputes with the parties at the 9/29/22 hearing; however, the motion should still be denied because:

 

* it is late under sections 340.1(k), 435, and 1008;

 

* the facts asserted by Defendants are not new or different (see, e.g., Weil & Brown, supra, at ¶¶ 9:324, 9:328-9:329);

 

* Judge Dillon reviewed the certificates of merit in camera and approved them, presumably finding them compliant with section 340.1 since he allowed Defendants to be named by their real names and authorized service of process (see 3/18/22 Minute Order, p. 1 [stating that Judge Dillon reviewed the certificates in camera]; see also 3/18/22 Order Re: In Camera Reviews, p. 1 [stating that the certificates demonstrate a “reasonable and meritorious cause for the filing of the action against Defendant DOES 1-4”]);

 

* it is improper to reconsider another judge’s ruling (see, e.g., Weil & Brown, supra, at ¶¶ 9:324.3-9:324.4);

 

* the Court declines to second guess Judge Dillon.

 

 

 

 

 

 JCCP 5101 (Clergy Cases)

 

Tentative Ruling Re: Motion to Vacate and Strike Re: 20STCV13901 (John Doe #1)

 

Date:                           9/29/22

Time:                          9:00 am

Moving Party:           Defendant Roe (“Roe”)

Opposing Party:        John Doe #1, John Doe #2 (jointly “Plaintiffs”)

Department:              11       

Judge:                        David S. Cunningham III

________________________________________________________________________

 

TENTATIVE RULING

Roe’s motion to vacate and strike is denied.

 

BACKGROUND

 

This coordinated proceeding involves approximately 475 Plaintiffs.  The complaints allege that clergy members sexually assaulted Plaintiffs when they were minors.  The Institutional Defendants allegedly failed to protect Plaintiffs from the alleged assaults.

 

Here, Roe moves to strike John Doe #1 and #2’s complaint and first amended complaint (“FAC”), arguing that Judge Daniel Crowley’s orders approving the certificates of merit and service of process are invalid.

 

LAW

 

Motion to Strike

 

“Motions to strike can be used to reach defects in or objections to pleadings that are not challengeable by demurrer.  Complaints, cross-complaints, answers and demurrers are all subject to a motion to strike [citation].”  (Weil & Brown, Cal. Prac. Guide: Civ. Proc. Before Trial (The Rutter Group 2022) ¶ 7:156.)  “Moreover, a motion to strike can be used to attack the entire pleading, or any part thereof—i.e., even single words or phrases (unlike demurrers).”  (Ibid.)

 

Unless the action is a limited civil case, the motion lies either:

 

* To strike any ‘irrelevant, false or improper matter inserted in any pleading’; or

 

* To strike any pleading or part thereof ‘not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.’  [Citation.]

 

(Id. at ¶ 7:167, emphasis in original.)

 

As with demurrers [citation], the grounds for a motion to strike must appear on the face of the pleading under attack, or from matter which the court may judicially notice (e.g., the court's own files or records).”  (Id. at ¶ 7:168.)

 

“Thus, for example, defendant cannot base a motion to strike the complaint on affidavits or declarations containing extrinsic evidence showing that the allegations are ‘false’ or ‘sham.’  Such challenges lie only if these defects appear on the face of the complaint, or from matters judicially noticeable.”  (Id. at ¶ 7:169, emphasis in original.)

 

Certificates of Merit and Corroborative Fact

 

“Special procedures are required in actions by a plaintiff who is 40 or older for childhood sexual assault.”  (Id. at ¶ 1:913.1.)  “Before serving any defendant, plaintiffs must file a certificate of merit with the court as to each defendant allegedly responsible for the abuse.  The certificate must show that, in the opinion of both plaintiff's attorney and a qualified mental health practitioner, there is reason to believe plaintiff was subject to the childhood sexual abuse alleged in the complaint.”  (Id. at ¶ 1:913.3.)  “If more than one defendant is sued, the attorney must file separate certificates of merit for each defendant.”  (Ibid.)  “The court must review the certificates in camera to determine if there is a ‘reasonable and meritorious cause for the filing of the action’ against each particular defendant.  If such finding is made, the duty to serve that defendant arises.”  (Ibid.; see also id. at ¶ 1:469.5 [“In cases brought by victims of childhood sexual assault who are over 40 at the time of the case filing, plaintiff's counsel must certify counsel has consulted with a mental health practitioner and concluded there is merit to the case.  The practitioner must execute a certificate that “there is a reasonable basis to believe that the plaintiff had been subject to childhood sexual abuse.”].)

 

“The person charged with the abuse shall not be named and shall be referred to only as ‘Doe’ in the original complaint filed with the court.”  (Id. at ¶ 1:0913.2.)  “Plaintiff must apply to the court for leave to amend the complaint to name the defendant.  Such application must be accompanied by a ‘certificate of corroborative fact’ executed by plaintiff's attorney.”  (Id. at ¶ 1:913.4.)

 

“Failure to comply with the above requirements [citation] is ground for demurrer or motion to strike the complaint and for disciplinary action against plaintiff's attorney.”  (Id. at ¶ 1:913.5, emphasis in original.)

 

DISCUSSION

 

On 4/9/20, Plaintiffs filed the complaint.

 

On 12/7/21, Judge Crowley granted Plaintiffs’ ex parte application to approve the certificates of merit, name Roe by its real name, file the FAC, and serve Roe with process.

 

On 12/16/21, Judge Crowley signed an order memorializing the findings at the 12/7/21 ex parte hearing.

 

On 1/24/22, Plaintiffs filed the FAC.

 

On 2/23/22, Plaintiffs filed a proof of personal service.  It indicates that Plaintiffs used a third-party service provider to serve the FAC on Roe by personal service on 2/11/22.

 

The first issue is whether Roe’s motion is timely.  Code of Civil Procedure section 340.1(k) states that “[t]he failure to file certificates in accordance with this section shall be grounds for a demurrer pursuant to Section 430.10 or a motion to strike pursuant to Section 435.”  (Code Civ. Proc. § 340.1, subd. (k), emphasis added.)  Section 435 requires a motion to strike to be filed “‘within the time allowed to respond to a pleading’ – e.g., 30 days after service of the complaint or cross-complaint unless extended by court order or stipulation.”  (Weil & Brown, supra, at ¶ 7:159.)  Roe moved to strike on 7/11/22, more than 30 days after Judge Crowley granted leave to serve process, Plaintiffs filed the FAC, and Roe received service of the FAC.  The record lacks evidence of an order or stipulation extending the time to respond, so the motion appears to be late.  This is reason enough to deny the motion and to decline to consider Roe’ arguments.

 

The motion also appears late in terms of reconsideration.  Effectively, the motion is a request for the Court to reconsider Judge Crowley’s 12/7/21 and 12/16/21 orders approving the certificates of merit and granting permission to serve process.  Roe filed the motion well beyond Code of Civil Procedure section 1008’s 10-day time limit.  

 

Roe contends Judge Crowley’s orders are invalid – and the motion should be granted – because the certificates of merit were executed by an attorney who was not the attorney of record at that time.  Roe claims John A. Girardi of the Law Offices of John A. Girardi executed the certificates despite the fact that the Girardi and Keese firm represented Plaintiffs.  (See Motion, p. 3.)

 

Plaintiffs assert that John A. Girardi represented them at all relevant times.  (See Opposition, pp. 7-8 [stating that he represented them at the beginning of the lawsuit as a member of the Girardi and Keese firm and continued to represent them once he opened his own firm].)

 

The Court is willing to discuss this factual dispute with the parties at the 9/29/22 hearing; however, the motion still should be denied because:

 

* it is late under sections 340.1(k), 435, and 1008;

 

* the fact is not new or different (see, e.g., Weil & Brown, supra, at ¶¶ 9:324, 9:328-9:329);

 

* Judge Crowley reviewed the certificates of merit and approved them, presumably finding them compliant with section 340.1 since he allowed Roe to be named by its real name in the FAC and authorized service of process (see, e.g., 12/16/21 Order Granting Ex Parte Application, p. 2);

 

* it is improper to reconsider another judge’s ruling (see, e.g., Weil & Brown, supra, at ¶¶ 9:324.3-9:324.4);

 

* the Court declines to second guess Judge Crowley.[1]



[1] Roe’s other arguments fail to change the analysis for the same reasons.