Judge: Douglas W. Stern, Case: 22STCV23696, Date: 2023-09-21 Tentative Ruling

Case Number: 22STCV23696    Hearing Date: January 12, 2024    Dept: 68

Law Offices of L.A. Law Inc., vs. Shahrzad Shahili, 22STCV23696

MOVING PARTIES: Plaintiff/Cross-Defendants L.A. Law Inc. and F. Bari Nejadpour (Cross-Defendants)

RESPONDING PARTY: Defendant/Cross-Complainant Shahrzad Shahili

Demurrer to Third Amended Cross-Complaint

I. BACKGROUND

Cross-Defendant L.A. Law filed its complaint on July 21, 2022, alleging five causes of action against Shahili for (1) breach of contract, (2) quantum meruit for services rendered, (3) account stated, (4) book account, and (5) fraud. These causes of action arise out of Shahili’s alleged breach of a retainer agreement with Cross-Defendant’s law offices for failure and refusal to pay outstanding legal services fees and costs.

            The current iteration of Shahili’s is Cross-Complaint is her Third Amended Cross-Complaint (TACC), filed on November 20, 2023. In the TACC, Shahili alleges four causes of action against Cross-Defendants L.A. Law and F. Bari Nejadpour for (1) professional negligence legal malpractice; (2) breach of fiduciary duty; (3) fraud and deceit, practice & without license; and (4) breach of contract. These causes of action all arise out of the attorney-client relationship that Shahili had with Cross-Defendants. (TACC, ¶ 8.) Shahili alleges in her TACC that Nejadpour made a number of misrepresentations to her at the beginning of their attorney-client relationship, including what the cost of the litigation would be, what Nejadpour could get for her in the case, and who would be representing her during the pendency of the case. She also pleads that she was unhappy with the settlement that Cross-Defendants obtained for her and had to retain other counsel.

            Cross-Defendants filed this demurrer on December 13, 2023. Shahili opposes.

II. ANALYSIS

A. The Demurrer

As a general matter, in a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) “A demurrer tests the pleading alone, and not the evidence or facts alleged.” (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1315.) As such, the court assumes the truth of the complaint’s properly pleaded or implied factual allegations. (Id.) The only issue a demurrer is concerned with is whether the complaint, as it stands, states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.)

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, 348.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Id.; Lewis v. YouTube, LLC (2015) 244 Cal.App.4th 118, 226.) However, “[i]f 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).

1. Entire Complaint

            Cross-Defendants demurrer to the entire complaint on the basis that the one-year statute of limitations has passed for an action against an attorney for a wrongful act or omission.

            The one year statute of limitations for a legal malpractice action commences once “reasonable diligence should have discovered, the facts constituting a wrongful act or omission.” (Village Nurseries v. Greenbaum (2002) 101 Cal.App.4th 26, 40.)

            CCP § 340.6(a) states that

“An action against an attorney for a wrongful act or omission, other than for actual fraud, 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.

… the time for commencement of legal action shall not exceed four years except that the period shall be tolled during the time that any of the following exist:

(1) The plaintiff has not sustained actual injury.

(2) The attorney continues to represent the plaintiff regarding the specific subject matter in which the alleged wrongful act or omission occurred.

(3) The attorney willfully conceals the facts constituting the wrongful act or omission when those facts are known to the attorney, except that this subdivision shall toll only the four-year limitation.”

            Pursuant to Lee v. Hanley (2015) 61 Cal.4th 1225, 1229, the limitations period of “section 340.6(a) applies to a claim when the merits of the claim will necessarily depend on proof that an attorney violated a professional obligation – that is, an obligation the attorney has by virtue of being an attorney – in the course of providing professional services.” (Lee, 61 Cal.4th at 1229.)

The Lee Court went on to hold:

“[S]ection 340.6(a)’s time bar applies to claims whose merits necessarily depend on proof that an attorney violated a professional obligation in the course of providing professional services. In this context, a ‘professional obligation’ is an obligation that an attorney has by virtue of being an attorney, such as fiduciary obligations, the obligation to perform competently, the obligation to perform the services contemplated in a legal services contract into which an attorney has entered, and the obligations embodied in the Rules of Professional Conduct.

(Id. at 1236-37.)

Essentially, this means that any claims stemming from the same events as a legal malpractice claim, except for fraud, which is excluded by CCP § 340.6(a), would also be time barred by the one-year statute of limitations, unless the tolling provision applies.

Cross-Defendants argue that Shahili should have known of their alleged wrongdoing, at the latest, when she hired a new attorney, Alex Khaefi, who filed a substitution of attorney in the underlying case on August 6, 2020. (RJN, ¶ 5; Silverstein Decl., Ex. B.) Shahili hired Khaefi to “dispute Nejadpour’s false claim,” and he “disputed distribution of the funds to Nejadpour.” (TACC, ¶ 26.) If Shahili hired Khaefi in 2020 to dispute distribution of billing funds to Nejadpour, then she was on notice of at least some form of wrongdoing as early as 2020, or, through the use of reasonable diligence, should have discovered the wrongful act or omission in 2020. Plaintiff’s Complaint was not filed until 2022. This was well outside of the one-year statute of limitations. Shahili’s complaint alleges that she did not discover any of the wrongdoing constituting her causes of action until after Cross-Defendants filed their complaint. (TACC, ¶ 26.) However, this conflicts with her allegations about hiring Khaefi to dispute the distribution of funds to Nejadpour.

Also, Shahili claims that she was told that she would get at least $1 million, but claims that Cross Defendants forced her (while they were representing her) to agree to substantially less as a settlement.  No amount of artful pleading explains away the fact that Shahili knew at that point in time that she was not getting $1 million.

The amendments that Shahili made to her cross-complaint did not address these discrepancies in her allegations. Based on the Lee Court decision and the text of CCP § 340.6(a), the one-year statute of limitations would apply to all of Cross-Complainant’s causes of action, except for the third cause of action for fraud, because the other causes of action are derivative of her cause of action for professional negligence legal malpractice.

The demurrer is sustained without leave to amend for Plaintiff’s First, Second, and Fourth Causes of Action because they are time-barred.

2. Third Cause of Action for Fraud and Deceit, Practice & Without License

            Cross-Defendants’ demur to this cause of action on the basis that it does not plead facts sufficient to constitute a cause of action for fraud and deceit.

            The Court previously overruled Cross-Defendants’ demurrer to this cause of action. The Court reaffirms that ruling.

III. ORDER

1.    Cross-Defendants’ Demurrer to Shahili’s First, Second, and Fourth Causes of action on the statute of limitations grounds is sustained without leave to amend.

2.    Cross-Defendants’ Demurrer to Shahili’s Third Cause of Action for Fraud and Deceit is overruled.