Judge: Frank M. Tavelman, Case: 23BBCV02659, Date: 2024-06-21 Tentative Ruling

Case Number: 23BBCV02659    Hearing Date: June 21, 2024    Dept: A

LOS ANGELES SUPERIOR COURT

NORTH CENTRAL DISTRICT - BURBANK

DEPARTMENT A

 

TENTATIVE RULING

JUNE 21, 2024

DEMURRER

Los Angeles Superior Court Case # 23BBCV02659

 

MP:     Exceed Companies LLC & William Mcgrayan (Defendants)

RP:     Ameris Bank (Plaintiff)

 

NOTICE:

 

The Court is not requesting oral argument on this matter.  The Court is guided by California Rules of Court, Rule 3.1308(a)(1) whereby notice of intent to appear is requested.  Unless the Court directs argument in the Tentative Ruling, no argument is requested and any party seeking argument should notify all other parties and the court by 4:00 p.m. on the court day before the hearing of the party’s intention to appear and argue.  The tentative ruling will become the ruling of the court if no argument is received.  

 

Notice may be given either by email at BurDeptA@LACourt.org or by telephone at (818) 260-8412.

 

ALLEGATIONS:

 

Ameris Bank (Ameris) brings this action against Canmar Promo Corp. (Canmar), Anahit Sahakyan (Sahakyan), Exceed Companies LLC dba Exceed Capital Lending (Exceed), William Mcgrayan aka Vahe Margaryan (Mcgrayan), and Mane Nersisyan (Nersisyan) (collectively Defendants). Plaintiff alleges that Defendants worked together to create a number of “straw” companies with the purpose of inducing Ameris to issue a Small Business Administration Loan in the amount of $2,250,000.  Ameris alleges it issued the loan to Canmar based on the representations of these companies and that Canmar is actually a defunct entity.

 

Ameris’ First Amended Complaint (FAC) states five causes of action for (1) Breach of Contract, (2) Intentional Fraud, (3) Negligent Misrepresentation, (4) Civil Conspiracy, and (5) Breach Of Fiduciary Duty.

 

Exceed and Mcgrayan (hereinafter Demurring Defendants) now demur to Ameris’ second, third, fourth, and fifth causes of action. Ameris opposes the demurrer.

 

ANALYSIS:

 

I.                    LEGAL STANDARDS

 

Demurrer

 

The grounds for a demurrer must appear on the face of the pleading or from judicially noticeable matters. (C.C.P. § 430.30(a); Blank v. Kirwan (1985) 39 Cal. 3d 311, 318.) A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) The only issue involved in a demurrer hearing is whether the complaint states a cause of action. (Id.)

 

A demurrer assumes the truth of all factual, material allegations properly pled in the challenged pleading. (Blank v. Kirwan, supra, 39 Cal. 3d at p. 318.) No matter how unlikely or improbable, the plaintiff’s allegations must be accepted as true for the purpose of ruling on the demurrer. (Del E. Webb Corp. v. Structural Materials Co. (1981) 123 Cal.  App. 3d 593, 604.) But this does not include contentions; deductions; conclusions of fact or law alleged in the complaint; facts impossible in law; or allegations contrary to facts of which a court may take judicial notice.  (Blank, supra, 39 Cal. 3d at 318.)

 

Pursuant to Code of Civil Procedure (“C.C.P.”) §§ 430.10(e) and (f), the party against whom a complaint has been filed may demur to the pleading on the grounds that the pleading does not state facts sufficient to constitute a cause of action, or that the pleading is uncertain, ambiguous and/or unintelligible. It is an abuse of discretion to sustain a demurrer without leave to amend if there is a reasonable probability that the defect can be cured by amendment. (Schifando v. City of Los Angeles (2003) 31 Cal. 4th 1074, 1082.)

 

II.                 MERITS

 

Meet and Confer

 

C.C.P. §§ 430.41(a) requires that the moving party meet and confer with the party who filed the pleading that is subject to the demurrer. Upon review the Court finds the meet and confer requirements were met. (Tan Decl. ¶¶ 2(a).)

 

Second COA – Intentional Fraud – Sustained with Leave to Amend

 

“The elements of fraud are (a) a misrepresentation (false representation, concealment, or nondisclosure); (b) scienter or knowledge of its falsity; (c) intent to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Hinesley v. Oakshade Town Ctr. (2005) 135 Cal.App.4th 289, 294.) The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.)

 

To properly allege fraud against a corporation, the plaintiffs must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

Here, Demurring Defendants argue the factual allegations supporting this cause of action are pled without the requisite specificity. Demurring Defendants argue that the FAC merely states the elements of fraud in a conclusory matter without specific factual allegations stated as to the misrepresentations made.

 

A review of the FAC reveals that Ameris alleges a large conspiracy involving Demurring Defendants and several other parties. Ameris contends the majority of this conspiracy was set into motion by Demurring Defendants and Nersisyan. Ameris alleges that Mcgrayan and Nersisyan, on behalf of Exceed, created a number of “straw companies” for the purpose of submitting loan applications on their behalf. (Compl. ¶ 31.) Ameris alleges that Canmar is one such company.

 

Ameris alleges that on March 9, 2023, Canmar executed and delivered to Ameris a Loan Agreement relating to a loan to Canmar in the stated principal amount of $2,250,000.00 (hereinafter Canmar Loan). Although it is not clearly stated, it is apparent from the overall allegations that Ameris contends Exceed served as the broker for the loan. For example, Ameris alleges that it communicated only with Mcgrayan and Exceed during the loan approval process and were kept from ever communicating with Canmar or its president Sahakyan. (FAC ¶ 37.) Plaintiff further alleges that, during the time Exceed was brokering the loan, it was doing so with a suspended license. Ameris alleges that Exceed’s finance lender/broker license was revoked by the Department of Financial Protection and Innovation of the State of California on December 27, 2022. (FAC ¶ 46, Exh. I.)

 

Ameris further alleges that “Nersisyan and Mcgrayan, in their individual capacity and on behalf of Exceed Capital, were intimately involved in the process and created/submitted documents to Ameris on behalf of Canmar.” (FAC ¶ 38.) Ameris alleges that Demurring Defendants submitted documents under penalty of perjury to demonstrate that Canmar was valued at a net worth of $900,000. (FAC ¶ 43). However, Ameris does not attach these documents to the FAC, nor do they state their specific nature. Ameris also alleges that Demurring Defendants submitted a fake Top 10 Customers List falsely demonstrating that Canmar had performed over $1,537,000 in services. (FAC ¶¶ 43, 44, Exh. H.)

 

Ameris further asserts that Nersisyan, in both an individual capacity and on behalf of Exceed Capital, procured a $1.8 million life insurance policy on behalf of Sahakyan that was utilized as collateral for the Canmar Loan. (FAC. ¶ 38.) Ameris further alleges that Exceed Capital selected this specific life insurance policy because it was not dependent on age or a medical exam of the insured and thus Nersisyan did not have to produce any individual for the medical examination. (FAC. ¶ 40.) Ameris allege that this life insurance policy has now been cancelled due to nonpayment. (FAC ¶ 41.)

 

Ameris alleges that Canmar thereafter defaulted on the loan. (FAC ¶ 21.) On July 14, 2023, approximately three days after Ameris sent its first letter noticing default, Ameris received a wire transfer from a third party, Dynamic Delivery Install, Inc. (Dynamic). (FAC ¶ 26.) Ameris applied the payment to the Canmar Loan as directed. (FAC ¶ 27.) The receipt of the wire transfer prompted Ameris to send another letter to Canmar, requesting to know who Dynamic was and why they were wiring money for the Canmar Loan. (FAC ¶ 28, Exh. G.) Ameris alleges this letter received no response. (FAC ¶ 30.) Ameris further alleges that Dynamic was another of the companies submitted to Ameris by Exceed for a loan. (FAC ¶ 32.)

 

Ameris, apparently concerned at this point, alleges that it conducted an investigation of Canmar and the Canmar Loan. (FAC ¶ 30.) Ameris alleges that its investigation revealed Canmar was never operating in the capacity that was related to Ameris on the loan documents. (FAC ¶ 30.) Ameris also alleges that Canmar was suspended by the California Secretary of State in 2017 and was only revived in 2020 with the purpose of defrauding Ameris. (FAC ¶ 35.)  Ameris alleges that Canmar’s office space was merely a shell and abandoned shortly after the loan was secured. (FAC ¶ 45.)

 

As an initial matter, Demurring Defendants argue that these facts are not alleged specifically because Ameris does not allege how the falsity of the loan documents was discovered. Demurring Defendants cite to no authority stating that a fraud cause of action must allege how a plaintiff determined the representations made were false. The Court finds this argument unpersuasive. The Court does not view the specificity requirements as necessitating Ameris plead how it discovered the loan documents were fraudulent. Demurrers are meant to test the sufficiency of pleadings, not the veracity of the allegations made. How Ameris came to learn the documents were false is matter for discovery, not demurrer. As it stands, Ameris’ allegation that it conducted an internal investigation of the loan and determined the documents to be false is sufficient. (See FAC ¶¶ 29, 30.)

 

Although Ameris has alleged a variety of fraudulent behavior, the Court finds that the current allegations are insufficiently detailed. Ameris’ allegation that Mcgrayan presented false loan documents is not specific enough to establish what misleading statements were made. The FAC is unclear as to whether the entirety of these statements were false, certain values were forged, or some other aspect of them was fraudulent. Ameris’ statement that Demurring Defendants submitted documents under penalty of perjury to demonstrate that Canmar was valued at a net worth of $900,000” is too vague for purposes of a fraud action. (See FAC ¶ 43.) Presumably this combination of any number of allegedly fraudulent documents was done to simplify Ameris’ pleadings, but it has left Demurring Defendants without notice of what these documents are.

 

Likewise, the Court finds the allegations concerning Canmar’s status as a “shell company” to be insufficiently detailed. While Ameris is not required to plead the exacting details of their investigation, they must at the very least allege the facts their investigation turned up. Canmar’s office space being empty, while peculiar, is not sufficient on its own to support Ameris’ allegation that Canmar was created for the sole purpose of defrauding them.  The facts which cause Ameris to conclude Canmar was a shell company should be set forth.   One of the facts is the vacant property, but that alone may not be sufficient.  Did Canmar have any assets?   Did it have any customers?  Were there other factors that can be asserted to support the conclusion that Canmar was a shell company set up primarily for fraud?

 

The specificity requirement means a plaintiff must allege facts showing how, when, where, to whom, and by what means the representations were made. (Lazar supra, 12 Cal.4th at 645.) Here, Ameris has alleged no facts concerning the means by which the misrepresentations were made. Ameris alleges that Demurring Defendants communicated exclusively with them during the loan process, but the FAC contains no allegations as to the nature of this communication. Presumably in this exclusive communication some statements regarding Canmar were made to include Ameris’ reliance. Without factual allegations as to these statements, Ameris’ FAC lacks for specificity.

 

The above being said, the Court finds that these are defects which can likely be cured upon amendment. Accordingly, the demurrer to this cause of action is SUSTAINED with 30 days’ leave to amend.

 

Third COA – Negligent Misrepresentation – Overruled

 

The elements of a cause of action for negligent misrepresentation include “[m]isrepresentation of a past or existing material fact, without reasonable ground for believing it to be true, and with intent to induce another’s reliance on the fact misrepresented; ignorance of the truth and justifiable reliance on the misrepresentation by the party to whom it was directed; and resulting damage.” (Hydro-Mill Co., Inc. v. Hayward, Tilton & Rolapp Ins. Associates, Inc. (2004) 115 Cal.App.4th 1145, 1154 [quotation marks omitted].)

 

Demurring Defendants argue that Ameris’ cause of action for Negligent Misrepresentation also fails for lack of specificity. Demurring Defendants present no novel arguments as to this cause of action, instead directing attention to the arguments made regarding the cause of action for Intentional Fraud.

 

From the Court’s review of the FAC it appears that Ameris has pled negligent misrepresentation sufficiently. Specifically, Ameris alleges that Exceed’s finance lender/broker license was revoked by the Department of Financial Protection and Innovation of the State of California on December 27, 2022. (FAC ¶ 46, Exh. I.) As a result, Ameris alleges that Exceed was not permitted to operate as a broker during the time of the loan transaction. (FAC ¶ 47.) Ameris alleges this revocation was never disclosed to Ameris despite Exceed and Mcgrayan communicating exclusively on behalf of Canmar. (FAC ¶ 37.) The Court finds these allegations are sufficient to sustain Ameris’ cause of action for Negligence Misrepresentation.

 

Accordingly, the demurrer to this cause of action is OVERRULED.

 

Fourth COA – Civil Conspiracy - Overruled

 

“Civil conspiracy is not an independent tort. Instead, it is a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immediate tortfeasors a common plan or design in its perpetration.” (City of Industry v. City of Fillmore (2011) 198 Cal.App.4th 191, 211-212 [quotation marks omitted].) “The elements of a civil conspiracy are (1) the formation of a group of two or more persons who agreed to a common plan or design to commit a tortious act; (2) a wrongful act committed pursuant to the agreement; and (3) resulting damages.” (Id. at p. 212.)

 

Demurring Defendants demur to this cause of action arguing that Civil Conspiracy cannot be a separate cause of action. Demurring Defendants further argue that this cause of action is duplicative in that it adds no theory of liability not already pled in the second cause of action for Intentional Fraud.

 

The Court begins by addressing the argument that Civil Conspiracy cannot serve as a cause of action. In Applied Equipment Corp. v. Litton Saudi Arabia Ltd. (1994) 7 Cal.4th 503, the California Supreme Court addressed the validity of a cause of action for Civil Conspiracy. The Applied court held:

 

A civil conspiracy, however atrocious, does not per se give rise to a cause of action unless a civil wrong has been committed resulting in damage. A bare agreement among two or more persons to harm a third person cannot injure the latter unless and until acts are actually performed pursuant to the agreement. Therefore, it is the acts done and not the conspiracy to do them which should be regarded as the essence of the civil action.

 

(Applied supra, 7 Cal.4th at 511 [internal quotation marks and citations omitted].)

 

The above demonstrates that while Civil Conspiracy cannot be an “independent” cause of action, it can be a “separate” cause of action. This is because a cause of action for Civil Conspiracy requires the commission of an independent tort, rather than the formation of a conspiracy alone. This is in contrast to a criminal cause of action for conspiracy, which contains no requirement that the purpose of the conspiracy is actually effectuated. (See Cal. Penal Code § 182(b).)

 

Here, the Court finds Ameris has pled all of the elements of Civil Conspiracy. Ameris alleges the Demurring Defendants, “…were aware of, cooperated and worked together to defraud the Bank into issuing a loan to Canmar,” and “…agreed with the plan for Canmar to submit fraudulent documents to the Bank and Defendants…to induce the Bank into making the Loan to Canmar.” (FAC ¶¶ 83-85.) Further, Ameris alleges that the mechanisms of this conspiracy, the false loan documents, were actually submitted in fulfillment of the conspiracy. (FAC ¶ 84.) The Court finds these allegations are sufficient to sustain Ameris’ cause of action for Civil Conspiracy.

 

Accordingly, the demurrer to this cause of action is OVERRULED.

 

Fifth COA - Breach of Fiduciary Duty – Sustained with Leave to Amend

 

“The elements of a cause of action for breach of fiduciary duty are the existence of a fiduciary relationship, breach of fiduciary duty, and damages.” (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 820.)

 

Demurring Defendants demur to this cause of action on grounds that (1) it pleads insufficient facts as to the existence of a fiduciary duty and (2) it is uncertain because of conflicting allegations in the FAC.

 

It is well-settled that a fiduciary duty under common law may arise “when one person enters into a confidential relationship with another.” (Hasso v. Hapke (2014) 227 CA4th 107, 140.) Hence, a fiduciary relationship is ordinarily synonymous with a confidential relationship, founded on the confidence and trust placed by one person in the integrity and expertise of another. (Cleveland v. Johnson (2012) 209 CA4th 1315, 1338.) “Before a person can be charged with a fiduciary obligation, he must either knowingly undertake to act on behalf and for the benefit of another, or must enter into a relationship which imposes that undertaking as a matter of law.” (Comm. on Children's Television Inc. v. Gen. Foods Corp., 35 Cal. 3d 197, 221 (1983), superseded on other by statute on other grounds as stated in Branick v. Downey Sav. and Loan Ass'n, 39 Cal. 4th 235 (2006)

 

Here, it is alleged that Exceed owed a fiduciary duty to Ameris by virtue of soliciting the loan to Canmar. The Court does not find the allegations that Exceed solicited the loan sufficiently alleges the existence of a fiduciary duty. The Court does not find mere solicitation equates to the creation of a confidential relationship whereby Exceed knowingly undertook to act on behalf or for the benefit of Ameris. While it could be said that the FAC properly alleges a fiduciary duty, that duty would be owed to Canmar and not Ameris.

 

Further, Ameris’ argument that California law establishes the fiduciary duties of brokers is unpersuasive. The case to which Ameris cites, Easton v. Strassburger (1984) 152 Cal.App.3d 90, concerns brokerage which is factually distinguishable from this case. Easton concerned a real estate broker and not a general loan broker. This is important because the basis for fiduciary duty of a real estate broker in California is derived from statute, specifically Cal. Civ. Code § 2079.2.  (See also Field v. Century 21 Klowden-Forness Realty (1998) 63 Cal.App.4th 18, 25.) While the role of a loan broker and a real estate broker can be similar, the Court is aware of no statutory authority establishing fiduciary duty for the latter to lenders.

 

Accordingly, the demurrer to this cause of action for failure to allege sufficient facts is SUSTAINED with 30 days’ leave to amend. As the Court sustains the demurrer on these grounds, the demurrer on the grounds of uncertainty is MOOT. 

 

---

 

RULING:

 

In the event the parties submit on this tentative ruling, or a party requests a signed order or the Court in its discretion elects to sign a formal order, the following form will be either electronically signed or signed in hard copy and entered into the Court’s records.

 

ORDER

 

Exceed Companies LLC & William Mcgrayan’s Demurrer came on regularly for hearing on June 21, 2024, with appearances/submissions as noted in the minute order for said hearing, and the Court, being fully advised in the premises, did then and there rule as follows:

 

THE DEMURRER TO THE THIRD, AND FOURTH CAUSES OF ACTION IS OVERRULED.  

 

THE DEMURRER TO THE SECOND AND FIFTH CAUSE OF ACTION IS SUSTAINED WITH 20 DAYS’ LEAVE TO AMEND.

 

UNLESS ALL PARTIES WAIVE NOTICE, DEFENDANT EXCEED TO GIVE NOTICE.

 

IT IS SO ORDERED.

 

DATE:  June 21, 2024                                    _______________________________

                                                                        F.M. Tavelman, Judge

                                                                        Superior Court of California

County of Los Angeles