Judge: Elaine W. Mandel, Case: SC126806, Date: 2024-02-21 Tentative Ruling

Case Number: SC126806    Hearing Date: March 15, 2024    Dept: P

Tentative Ruling

Jane Doe v. Curtis Olson et al., Case No. SC126806 (related case SC128027)

Hearing Date March 15, 2024

Plaintiff’s Motion to Consolidate SC126806 with SC 128027 and 24SMCV0012

Demurrer and Motion to Strike Second Amended Complaint in SC126806

Demurrer to First Amended Complaint in SC128027

May Doe’s Motion for Protective Order

 

Plaintiff Doe alleges she entered into a real estate development agreement with defendant Olson, under which units in Doe’s building would be converted from rentals to condominiums. Olson would purchase units, and Doe would choose one unit as her residence. Doe regularly used her condo for short term rentals through Airbnb, which she claims was permitted under her agreement with Olson.

 

Doe alleges Olson and his friends harassed her, spreading defamatory rumors, spying on her, recording her without consent, tampering with her unit, intimidating her friends, short-term tenants and business associates and insulting her. Doe alleges Olson sexually assaulted her. Doe also alleges that in retaliation for refusing his sexual advances, Olson used his position as president of the property’s HOA board to pass policies targeting her.

 

Plaintiff Doe moves to consolidate the three actions she filed arising out of these various allegations. Defendants demur to the second amended complaint in Case No. SC126806 and the First Amended Complaint in SC128027. This has been withdrawn, but the court, sua sponte, finds it appropriate to address.

 

Jane Doe moves for an award of attorney’s fees arising out of her successful anti-SLAPP motion in SC126806.

Plaintiff May Doe moves for a protective order preventing disclosure of her name or address. 

Motion to Consolidate

Plaintiff Jane Doe filed Doe v. Olson, Case no. SC126806 (“Doe I”), on December 9, 2016. On August 31, 2017, she filed Doe v. Olson, Case No. SC128027 (“Doe II”), and on January 2, 2024, she filed Doe v. Olson, Case No. 24SMCV0012 (“Doe III”). Jane Doe is plaintiff in all three matters; Curtis Olson, Douglas Econn, Scott Burham, Kelly Day, David Feder, Chateau Colline HOA, LB Property Management, Inc. (LBPM), Elsa Monroy, Robert Kilian, David Silver and Kelley Hemmeter-O’Neil are defendants in all three actions.

 

May Doe is a plaintiff in Doe II and Doe III. Doe III includes new defendants and causes of action. All three claims arise out of Olson’s alleged harassment of Jane Doe, with the alleged purpose of driving Doe out of the condominium complex.

 

Under Cal. Code of Civ. Proc. §1048, when actions involving a common question of law or fact are pending before the court, it may order all the actions consolidated.

 

When multiple actions are consolidated “for all purposes,” they are “merged into a single proceeding under one case number and result in only one verdict or set of findings[.]” Hamilton v. Asbestos Corp., Ltd. (2000) 22 Cal.4th 1127, 1148.

 

Consolidation is appropriate. Doe I and Doe II have been deemed related. The demurrers in each case address nearly identical issues. Separate trials for Doe I and Doe II would result in unnecessary expenditure of judicial resources. Both cases overlap much more than they diverge, sharing almost identical plaintiffs, defendants, causes of action and allegations. Separate trials might involve calling witnesses twice, empaneling two juries and the risk of inconsistent rulings. Doe I and Doe II are consolidated for all purposes under case number SC126806. As explained below, where the court rules on the pending demurrers, the operative complaint in the consolidated matter will be the third amended complaint in case no. SC126806.

 

Because Doe III has not been served on all defendants, defendants in that action have not yet had an opportunity to determine the basis of the third action, so cannot meaningfully consent to or oppose the request for consolidation. In the interest of due process, the court will not yet consolidate Doe III with Does I and II.  GRANTED as to Doe I (SC126806) and Doe II (SC128027), which are ordered consolidated under Case No. SC126806. DENIED as to Doe III without prejudice.

 

Demurrers

 

Doe I Demurrer

Defendants Curtis Olson, Douglas Econn, Scott Burnham, David Feder, Kelly Day, Chateau Colline HOA, and LBPM demur to the second amended complaint in case no SC126806 (Doe I).  

 

Scott Burnham

Since Burnham is not named in this complaint, the demurrer is SUSTAINED as to all claims against him. For reasons stated in the court’s analysis of the Demurrer to “Doe II” (Case No. SC128027), Burnham may be restored as a defendant in the third amended complaint. SUSTAINED with ten days leave to amend.

 

Tortious Interference

The elements of intentional interference with prospective economic advantage are (1) an economic relationship between plaintiff and a third party, with the probability of future economic benefit to the plaintiff, (2) defendant’s knowledge of the relationship, (3) intentional wrongful acts by defendant designed to disrupt the relationship, (4) actual disruption of the relationship, and (5) damages. Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134.

 

Doe alleges defendants “engaged in stalking, peeping, removing rental rights, harassment, defamation, and stealing Plaintiff’s keys” to prevent her from using her unit for short-term Airbnb rentals. SAC ¶¶128, 130. Defendants argue allegations elsewhere in the complaint contradict this claim, such as allegations in the SAC that Doe did not acquire an ownership interest in her unit until 2012. The SAC alleges Doe and Olson agreed there would be no time restriction on renting her unit, allowing for short-term rentals. SAC ¶51. For purposes of pleading, this must be treated as true.

 

Defendants argue after the CC&Rs were amended to prohibit short-term rentals, Doe was not “grandfathered in” to old rules allowing short-term rentals. Doe alleges she is grandfathered in, per her agreement with Olson. SAC ¶53. On demurrer, Doe’s allegations must be treated as true.

 

Finally, defendants argue judicially noticeable evidence shows short term rentals at Doe’s units are prohibited under the Los Angeles Municipal Code, giving defendants a complete affirmative defense of illegality. Under City Ordinance No. 185931, short-term rentals are not permitted at a property subject to the Los Angeles Rent Stabilization Ordinance (LARSO). LARSO applies to buildings built before 1978, and the SAC admits the property was built in 1936. SAC ¶16.

 

Under the Municipal Code, short-term rentals of the unit are currently illegal. Defendants have not shown how the rental’s present illegality defeats Doe’s tortious interference claim. The court takes judicial notice that ordinance No. 185931 took effect on July 1, 2019. Doe alleges acts of wrongful interference, including Olson stripping her of her right to have short-term rentals at her unit, throughout 2015 and earlier. E.g., SAC ¶¶50, 59. Doe alleged defendants interfered with short term rentals at her property while that use was still legal. OVERRULED.

 

Implied Covenant of Quiet Enjoyment

The implied covenant of quiet enjoyment provides a civil claim against any landlord who interferes with “a tenant’s right to use and enjoy the premises for the purposes contemplated by the tenancy.” Green v. Superior Court (1974) 10 Cal.3d 616, 625 fn. 10.

 

This cause of action is based on Doe’s alleged 99-year lease for a basement storage unit at the property. SAC ¶136. Defendants argue under the statute of frauds a lease for a term of over one year must be in writing, and Doe does not allege existence of a written lease. Doe need not specifically allege the lease was written to survive demurrer.

 

Defendants argue this claim fails because Doe has not specifically alleged any conduct that “interrupted the use of her storage closet.” The SAC specifically alleges Olson used his HOA president position to “evict plaintiff from her basement storage closet,” and hired Feder to break into her storage and steal Doe’s personal belongings. SAC ¶¶83, 84. These allegations are sufficient to plead interference with Doe’s right to quiet enjoyment of her storage closet.

 

Defendants argue the SAC improperly “bunches all defendants together” without clarifying which did what, and “the HOA and LBPM are corporate entities that could not have undertaken any of the alleged act.” SAC ¶13. A corporation acts through its officers and employees when their acts are within the scope of their authority. E.g., Persson v. Smart Inventions (2005) 125 Cal.App. 4th 1141, 1167; 5 Witkin, Summary of California Law (11th ed. 2017), Torts §36.

 

The implied covenant cause of action is alleged against Olson, Chateau Colline HOA, and LB PM. The SAC alleges Olson was acting in his capacity as an HOA officer when he sought to deprive Doe of her right to use the storage closet, and Feder was working for Olson. SAC ¶83. This is sufficient to establish the HOA’s potential liability at the pleading stage. The SAC does not specify that Olson was acting on behalf of LBPM when he committed alleged acts of interference. There is no basis for the implied covenant cause of action to proceed against LBPM. OVERRULED as to the HOA and Olson; SUSTAINED without leave to amend as to LBPM.  

 

IIED (By Defendant Day)

A cause of action for intentional infliction of emotional distress must allege “extreme” or “outrageous” conduct committed by defendant. The allegation must be made with great specificity to avoid demurrer. Yau v. Santa Margarita Ford, Inc. (2014) 229 Cal.App.4th 144, 160-161.

 

Defendant Day, an HOA board member and condo owner, argues Doe did not allege she engaged in outrageous conduct. The SAC alleges Day “betrayed” Doe by joining Olson’s campaign of harassment. SAC ¶69. The only specific allegations of wrongdoing against Day are that she voted with the majority of the HOA board to remove and replace windows at Doe’s unit, forwarded a private email from Doe to Olson, rolled her eyes at Doe, used her own storage closet and had advance knowledge of defendant Feder’s unfitness to serve as a property manager. SAC ¶¶68, 70, 71, 108. These allegations, as a matter of law, do not constitute outrageous conduct. Since outrageous conduct is an essential element of an IIED claim, this cause of action cannot proceed against Day. SUSTAINED without leave to amend as to defendant Day only.

 

Fiduciary Duty (By LBPM)

A defendant cannot be liable for breach of a fiduciary duty unless they “Knowingly undertake to act on behalf and for the benefit of another[.]” Committee on Children’s Television, Inc. v. General Foods Corp. (1983) 35 Cal.3d 197, 221. Directors of an HOA owe their duty to the actual association, rather than individual homeowners or members. Frances T. v. Village Green Owners Assoc. (1986) 42 Cal.3d 490, 513.

 

Defendant LBPM argues it owes Doe no fiduciary duty. The SAC alleges LBPM undertook to act as a fiduciary for all HOA members, and Doe is a member. SAC ¶163. For purposes of pleading, this allegation must be treated as true. The SAC adequately sets forth a cause of action for breach of fiduciary duty against LBPM. To the extent this cause of action is alleged against the HOA, however, it fails under Frances T. OVERRULED as to LBPM.

 

Aiding and Abetting Breach of Fiduciary Duty

Directors of an HOA owe their duty to the actual association, rather than individual homeowners or members. Frances T, supra, at 513.

 

To the extent this cause of action is based on an alleged breach of fiduciary duty by the HOA, it fails under Frances T. To the extent it is based on the fiduciary duty allegedly owed by LBPM, it is unclear which specific acts by each named defendant constituted assistance in breaching LBPM’s fiduciary duty. SUSTAINED with ten days leave to amend to clarify how individual defendants assisted LBPM in breaching its fiduciary duty.

 

Discrimination

Plaintiffs’ ninth through eleventh and twenty third causes of action allege discrimination on the basis of ethnicity, marital status, perceived religion and gender. Though the complaint alleges wrongful conduct by all defendants, it alleges no specific facts indicating any conduct was motivated by a protected characteristic. Doe’s allegation that defendants had discriminatory motives is conclusory and lacks minimal factual support so cannot survive demurrer. SUSTAINED without leave to amend as to the ninth, tenth, eleventh, and twenty third causes of action.

 

Intrusion into Private Affair

The demurrer argues no specific acts of intrusion are alleged against defendant Olson, and the SAC does not allege HOA or LBPM authorized or ratified any intrusion into Doe’s private affairs.

 

The FAC alleges Olson hired Feder to film and photograph Doe in her bathroom and bedroom. SAC at ¶¶73-75. It alleges Olson peered at Doe and her guests through bedroom and bathroom windows. SAC ¶76, 88. These allegations are sufficient to set forth a claim for intrusion into private affairs against Olson.

 

Additionally, the SAC alleges Olson and Feder were acting on behalf of the HOA while they spied on Doe, since Olson was running the HOA as an alter ego and wished to catch plaintiff renting to third parties as a pretext for removing her from the property. SAC ¶76. This allegation sets forth a basis for liability against the HOA through Olson. The SAC does not include allegations that establish LBPM’s liability, since it does not allege any defendant was acting on LBPM’s behalf. OVERRULED as to Olson and the HOA; SUSTAINED without leave to amend as to LBPM.

 

Distribution of Obscene Materials

Cal. Civ. Code §1708.85(b) creates a private cause of action against a person who “intentionally distributes” material that “exposes an intimate body part” of another person without that person’s consent.

 

This cause of action is based on allegations that defendants, without consent, took pictures of Doe while she was partially clothed. Defendants argue the SAC does not allege “distribution” of these photos or facts showing liability for Olson, the HOA or LBPM. The SAC alleges defendant Feder took the pictures and gave images to “other defendants and the HOA attorneys.” SAC ¶301. This is sufficient to allege photos were “distributed.” Additionally, the SAC alleges Feder was acting on behalf of Olson and the HOA when he took the photos. The claim is sufficient as alleged against Olson, the HOA and Feder. There are no allegations setting forth the basis for LBPM’s liability. OVERRULED as to Olson, Feder and the HOA; SUSTAINED without leave to amend as to LBPM.

 

Stalking

Defendants demur on the grounds that it does not comply with the elements of Cal. Civ. Code §1708.7. While Doe’s complaint does not reference the statute, the tort of stalking is created by Civ. Code §1708.7. Stalking is not a common law cause of action; it is a creature of statute. The court can apply the statutory elements, even if the SAC does not cite §1708.7. A claim under §1708.7 requires that defendant either “made a credible threat” against plaintiff or violated a restraining order. Neither is alleged in the SAC. SUSTAINED without leave to amend.

 

Negligent Infliction of Emotional Distress

There is no independent cause of action for negligent infliction of emotional distress; all NIED claims are treated as negligence claims, which require a showing that defendant owed plaintiff a duty of care. GU v. BMW of North America, LLC (2005) 132 Cal.App.4th (2005) 132 Cal.App.4th 195, 205. Generally, there is no duty of care to avoid negligently causing emotional distress to another unless defendant assumed a duty to plaintiff in which plaintiff’s emotional condition is an object. Id. Absent such duty, liability for NIED is proper when defendant breaches an independent duty, if a breach of that duty threatens physical injury. Potter v.  Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, 985.

 

Doe does not allege a special relationship related to her emotional condition that would give rise to a duty of care to avoid negligently causing emotional distress. Additionally, she does not allege defendants HOA, Econn, Day, Burnahm, Feder or LBPM violated a separate duty that threatened physical injury.

 

She does, however, allege sexual battery against Olson, which constitutes breach of an independent legal duty. Sexual battery also threatens physical injury, so can serve as a basis for a NIED claim under Potter. SUSTAINED without leave to amend against all defendants except Olson; OVERRULED as to Olson.

 

Negligent Failure to Prevent Retaliation

This cause of action is derivative of Doe’s discrimination claims. The derivative claims are insufficiently alleged, since Doe does not allege facts showing any of defendants’ alleged wrongdoing was motivated by discriminatory intent. SAC ¶¶326-328. The claim for negligent failure to prevent retaliation fails for the same reason. SUSTAINED without leave to amend.

 

Breach of Contract

This cause of action arises from Olson’s alleged breach of the basement storage lease. A cause of action for breach of lease is subject to demurrer if it is unclear whether the contract was in writing or oral. Cal. Code of Civ. Proc. §430.10(g). The SAC does not allege the contract was in writing or oral. Doe requests leave to allege that the contract was in writing. SUSTAINED with ten days’ leave to amend to allege the contract was written.

 

Nineteenth Cause of Action for Running a Corporation as an Alter Ego Defendant

The alter ego doctrine is “not itself a claim for substantive relief,” but rather a means by which to hold individuals liable for the obligations of a corporation. Hennessey’s Tavern, Inc. v. American Air Filter Co. (1988) 204 Cal. App. 3d 1351, 1358-1359.

 

Doe alleges a separate cause of action for “running a corporation as an alter ego defendant.” As stated above, alter ego is not a cause of action. This claim is subject to demurrer. SUSTAINED without leave to amend.

 

Sexual Harassment

This cause of action is based on the allegation that defendants “engag[ed] in a severe and pervasive scheme to harass plaintiff on the basis “of her gender, perceived religion, race and ethnicity[.]” SAC ¶343. As stated, Doe failed to allege a discriminatory motive for any of the wrongdoing alleged. Since the SAC grounds this claim in the same allegations of discrimination, it is subject to demurrer. SUSTAINED without leave to amend.

 

Twenty-Second Cause of Action for Civil Conspiracy

Defendants argue this cause of action fails under the agent immunity rule, which states an agent or employee cannot be liable for conspiracy with their principal or employer when they act on its behalf. Doctors’ Co. v. Superior Court (1989 4 Cal.3d 39, 44. Doe admits this cause of action is deficient and requests leave to amend. She does not state how this cause of action can be cured. Therefore, the court will not grant leave to amend. SUSTAINED without leave to amend.

 

Motion to Strike

 

Doe Pseudonym

Defendants move to strike Doe’s use of a pseudonym on the grounds she has not filed a confidential information form under Cal. Code of Civ. Proc. §1708.85(f)(3). Defendants argue she waived her right to proceed under a fictional name by revealing her real name in related cases.

 

In opposition, Doe provides a proof of service indicating she filed a required confidential information form in this case. Doe decl. ¶3, Exhibit A. Defendants do not provide authority for the argument that the statutory right to proceed as a Doe under Cal. Civ. Code §1708.85 can be waived in one case if a plaintiff reveals her name in other cases, even if they are related. DENIED.

 

Punitive Damages

Defendants argue the request for punitive damages should be struck because allegations of malice, oppression or fraud in the SAC are conclusory. This is true as to some defendants only.

 

Doe alleges defendant Econn made vulgar remarks toward her and defamed her in 2005 and made false reports about her conduct to LBPM from 2005-2007. SAC ¶35. These allegations fall outside the statute of limitations, so cannot support a claim for punitive damages. Id. Doe has not alleged conduct by Econn rising to the level of fraud, malice, or oppression that falls within the statute of limitations.

 

The conduct alleged against defendant Day detailed above are insufficient to support an award of punitive damages.

 

Doe does allege that in 2015 defendants Olson and Feder – with Olson acting in his capacity as president of the HOA as part of a campaign to remove her from the property – spied on her, harassed her, and – in Olson’s case—sexually assaulted her. E.g., SAC ¶¶58, 59, 66, 73-76. These allegations are sufficiently severe to support punitive damages against Feder, Olson and the HOA.

 

Since Doe has not adequately alleged these defendants were acting on behalf of LBPM, punitive damages are not appropriate as to LBPM. GRANTED without leave to amend as to Day, Econn, and LBPM; DENIED as to Feder, Olson and the HOA.

 

Allegations Outside the Statute of Limitations

Defendants argue any allegations occurring outside the statute of limitations are irrelevant and should be struck. Doe’s opposition does not address these arguments. Since the allegations are not directly relevant to Doe’s claims, they will be stricken. GRANTED.

 

Request for Attorney’s Fees

Defendants move to strike Doe’s Request for attorneys’ fees on the grounds that Doe has not provided a basis for recovering them. Doe does not address this argument. GRANTED.

 

Doe II Demurrer (Case No.SC128027)

Doe et. al. v. Olson et al., Case No.SC128027 (“Doe II”) is based on essentially the same nucleus of facts as SC126806 (“Doe I”). Both are based Olson and his friends/employees/allies’ alleged harassment. Doe II includes plaintiff May Doe and several additional defendants.

 

Defendants demur to the first amended complaint in Doe II on the grounds that it is duplicative of Doe I and, to the extent it is not duplicative, fails to adequately state a cause of action.

 

A plaintiff may not split a cause of action by filing multiple lawsuits based on the violation of the same primary right. Crowley v. Katleman (1994) 8 Cal.4th 666, 681-682. A demurrer is proper on the grounds that “[t]here is another action pending between the same parties on the same cause of action.” If two actions involve the same injury to the plaintiff and the same wrong by the defendant, the same primary right is at stake even if the plaintiff pleads different theories of recovery in the second suit. Cal Sierra Dev., Inc. v. George Reed, Inc. (2017) 14 Cal.App.5th 663, 675-676.

 

To the extent any causes of action in Doe II are alleged by Jane Doe against Olson, Econn, Day, Feder, HOA and LBPM, they duplicate the Doe I allegations, detailed above in the analysis of the first demurrer. SUSTAINED as to the causes of action between Jane Doe and those six defendants, without leave to amend.

 

To the extent new allegations not detailed in Doe I are brought by May Doe against any defendant, or by Jane Doe against any of the defendants named only in Doe II, the claims emerge out of the same nexus of facts as Doe I. Doe I and Doe II have been consolidated. The court will not issue a separate ruling in Doe II, since it has essentially been extinguished as a separate action by the consolidation order.

 

Considering this consolidation, the remnants of defendants’ demurrer to Doe II is MOOT. Jane and May Doe have ten days leave to amend to file a third amended complaint in Doe I, incorporating the Doe II allegations and parties. Defendants sued by May Doe or Defendants not named in Doe I may revive their demurrer to Doe II in the form of a demurrer to the third amended complaint once it is filed.

 

 

 

 

Motion for Protective Order (Doe II)

Plaintiff May Doe asks the court to issue a revised version of a court approved model protective order. The proposed order uses the model’s language allowing parties to designate discovery material as confidential, preventing its disclosure outside the litigation. The new language added to the model order by plaintiff designates as “Confidential – For Counsel Only” any unredacted materials disclosing May Doe’s name, address, and other personal identifying information.

 

Under Cal. Code of Civ. Proc. §2030.090(b), a court may issue any order that justice requires to protect a party from “unwanted annoyance, embarrassment, or oppression, or undue burden and expense.”

 

May Doe claims disclosing her identity would expose her to harassment, stalking and intimidation, citing alleged attacks and/or death threats defendant Olson and his associates – including attorneys -- allegedly directed at May’s co-plaintiff Jane Doe and her witnesses. May Doe presents declarations from Jane Doe, Adamo Moreno and Loren Marken, detailing alleged threats, harassment, and violence from Olson and his associates. May Doe argues defendants and attorneys are likely to subject her to the same treatment if they discover her identity.

 

In opposition, defendants state the proposed order is overbroad, allowing plaintiffs to unilaterally designate any material as “confidential,” while prejudicially restricting access by defendants’ litigation staff to crucial information needed to defend the case. Id. pg. 15. They also argue it is unsupported, stating that there is no evidence May Doe has been or will be subject to harassment from plaintiffs or their associates, and evidence of harassment against Jane Doe is irrelevant and based on speculation or hearsay.

 

The declarations alleging harassment and threats from Olson and his associates are severe and worthy of attention. Defendants are correct that some portions of the declarations are based on hearsay and/or speculation. The Harrison declaration fails to establish declarant’s expertise regarding “firing positions,” and none of his observations suggest a connection between Olson and/or his attorneys and Deputy Koo’s allegedly intimidating behavior toward Doe.

 

Portions of the Moreno declaration are admissible and uncontroverted, for example his claim that Curtis Olson and associates repeatedly came to the café where he worked and asked after Jane Doe. Moreno decl. ¶¶4-5. This evidence is sufficient to justify an order protecting May Doe’s anonymity.

 

The issuance of a protective order under Cal. Code of Civ. Proc. §2030.090(b) is warranted considered this evidence. The court’s model protective order is narrowly tailored, but defendants note some modifications Doe proposes are vague and overreaching. For example, it would unfairly inhibit defendants’ ability to litigate this action if May Doe’s identity can only be disclosed to attorneys Reagan and Partida. The proposed order, as drafted, is unworkable, unfairly restricting defendants’ counsel’s ability to defend this case. The “attorney’s eyes only” language, therefore will be modified and expanded. May Doe’s name and address are to be treated as confidential and are not to be disclosed outside the litigation. They may be disclosed to attorneys, paralegals, and staff at Slaughter, Regan & Cole. Additionally, May Doe’s name and identifying information can be included in third-party discovery subpoenas.

 

Beyond these necessary parties, May Doe’s name and address are to be treated as confidential and omitted from any documents produced in the litigation to non-necessary parties. DENIED in part and GRANTED in part.