Judge: Gail Killefer, Case: 20STCV27444, Date: 2025-06-16 Tentative Ruling



Case Number: 20STCV27444    Hearing Date: June 16, 2025    Dept: 37

HEARING DATE:                 Monday, June 16, 2025

CASE NUMBER:                   20STCV27444

CASE NAME:                        Sebastian Zurita, et al. v. Martel Investment, LLC, et al.

TRIAL DATE:                        Post Judgment

PROOF OF SERVICE:           OK

                                                                                                                                                           

MOVING PARTY:                 Plaintiffs Sebastian and Emiliano Zurita

OPPOSING PARTY:             Defendant Drail Investments, LLC

PROCEEDING:                      Motion for Judgment Not Withstanding the Verdict (MJOV)

OPPOSITION:                        19 May 2025

REPLY:                                  27 May 2025

 

TENTATIVE:                         Plaintiffs’ JNOV is granted.

                                                                                                                                                           

 

MOVING PARTY:                 Defendants Martel Investment, LLC and Ron Fattal

OPPOSING PARTY:             Plaintiffs Sebastian and Emiliano Zurita

PROCEEDING:                      Motion for Judgment Not Withstanding the Verdict (MJOV)/Motion for a New Trial in the Alternative

OPPOSITION:                        19 May 2025

REPLY:                                  27 May 2025

 

TENTATIVE:                         Plaintiffs’ JNOV is granted. The Fattals Defendants’ JNOV is denied as is their alternative motion for a new trial.

                                                                       

 

Background

 

On July 15, 2020, Plaintiffs Sebastian and Emiliano Zurita (collectively “Plaintiffs”) filed this action against Defendants Martel Investments, LLC (“Martel”) and Ron Fattal (“Fattal”) due to construction defects found in the property located at 415 North Martel Avenue, Los Angeles, California 90036 (the “Martel Property”).

On July 20, 2023, Plaintiffs filed the operative Third Amended Complaint  (“TAC”) alleging three cause of action: (1) Violation of California Right to Repair Act (California Civil Code § 896, et seq.) against Defendants Fattal, Martel, Drail Investments, LLC (“Drail”); (2) Negligence against Fattal, Martel, Drail, Jose De Jesus Rodriguez, The Right Team Construction, Inc., Tiran Benmoshe, Pacific Ocean Wall, Inc., HC Builders, Inc., Roberto’s Wrought Iron, Inc., and John Biczo, and (3) Fraudulent Concealment against Fattal, Martel, and Drail.

 

On September 6, 2023, the Court entered Dismissal, without prejudice, as to Defendant John Biczo.

 

On September 21, 2023, Plaintiffs filed their Amendment to Third Amended Complaint, adding Roberto Vazquez Gomez as a Defendant to the Second Cause of Action for Negligence.

 

On October 15, 2023, the Court entered Dismissal, without prejudice, as to Defendant Roberto’s Wrought Iron, Inc.

 

On October 23, 2023, the Court entered Default as to Defendant Pacific Ocean Wall, Inc.

 

On October 25, 2023, the Court entered Default as to Defendant Jose de Jesus Rodriguez.

 

On November 21, 2023, the Court entered Default as to Defendant Roberto Vazquez Gomez.

 

On December 6, 2023, Plaintiffs filed their Amendment to Third Amended Complaint adding HomeMade Custom Builders, Inc. as a Defendant to the Second Cause of Action for Negligence.

 

On July 10, 2024, the Court entered Dismissal, with prejudice, as to Defendant The Right Team Construction, Inc.

 

On July 25, 2024, Plaintiffs dismissed their Second Cause of Action for Negligence,

without prejudice, as to Fattal, Martel, and Drail.

 

On August 2, 2024, the Court entered Dismissal, with prejudice, as to Tiran Benmoshe.

On August 6, 2024, the Court entered Dismissal, with prejudice, as to Defendants HC Builders, Inc. and HomeMade Custom Builders, Inc.

 

This action came on regularly for a jury trial on Plaintiffs’ First Cause of Action for Violation of California Right to Repair Act (California Civ. Code § 896, et seq.) and Third Cause of Action for Fraudulent Concealment against Fattal, Martel, and Drail. The trial commenced on Tuesday, February 18, 2025, and continued through Friday, February 28, 2025, and resumed for one day on Friday, March 7, 2025, in Department 37 of the Stanley Mosk Courthouse of the Los Angeles Superior Court, the Honorable Gail Killefer, Judge presiding. A jury of twelve persons was regularly impaneled and sworn to try the action. Witnesses on the part of both Plaintiffs and Martel, Fattal, and Drail were sworn and examined.

 

During the course of the trial, prior to the jury rendering its Verdict, Plaintiffs withdrew their Third Cause of Action for Fraudulent Concealment as to Drail Investments, LLC.

On February 28, 2025, the jury rendered its verdict, finding that Plaintiffs are the prevailing parties in this action with respect to their two claims against Ron Fattal and Martel Investment, LLC and that Drail Investments, LLC is the prevailing party in this action with respect to Plaintiffs’ First Cause of Action for Violation of California Right to Repair Act (Civ. Code, § 896, et seq.)

 

On April 2, 2025, Judgment was entered as follows:

 

1)     On Plaintiffs’ First Cause of Action for Violation of California Right to Repair Act (California Civil Code § 896, et seq.), Plaintiffs are entitled to recover from Ron Fattal and Martel Investment, LLC, jointly and severally, compensatory damages in the principal sum of $963,146.32.

 

2)     On Plaintiffs’ First Cause of Action for Violation of California Right to Repair

 Act (California Civil Code § 896, et seq.), Plaintiffs are entitled to recover nothing from Drail Investments, LLC.

 

3)     On Plaintiffs’ Second Cause of Action for Negligence, in light of Defaults being previously entered, Plaintiffs are entitled to recover from Pacific Ocean Wall, Inc., Jose de Jesus Rodriguez, and Roberto Vazquez Gomez, jointly and severally with Ron Fattal and Martel Investment, LLC, compensatory damages of $963,146.32, which is inclusive of the compensatory damages awarded under the First Cause of Action.

 

4)     On Plaintiffs’ Third Cause of Action for Fraudulent Concealment, Plaintiffs are entitled to recover from Ron Fattal and Martel Investment, LLC, jointly and severally, compensatory damages in the amount of $1,975,223.32, which is inclusive of the compensatory damages awarded under the First and Second Causes of Action. Plaintiffs are entitled to recover from Ron Fattal the additional amount of $2,000,000, reflecting punitive damages. Plaintiffs are entitled to recover from Martel Investment, LLC the additional amount of $1,000,000, reflecting punitive damages. Thus, the total principal sum Plaintiffs are entitled to recover on the Third Cause of Action for Fraudulent Concealment is $4,975,223.32.

 

Plaintiffs now move for judgment notwithstanding the verdict as to the First Cause of Action for violation of the Right to Repair Act (the “Act”).

 

Defendants Martel and Fattal also move for judgment notwithstanding the verdict as to the Third Cause of Action for Fraudulent Concealment or, alternatively, a new trial.  The matter is now before the court.

 

Legal Standard

 

            A.        Judgment Not Withstanding the Verdict

 

CCP § 629(a) provides that, “[t]he court… on motion of a party against whom a verdict has been rendered, shall render judgment in favor of the aggrieved party notwithstanding the verdict whenever a motion for a directed verdict for the aggrieved party should have been granted had a previous motion been made.” A motion for judgment notwithstanding the verdict has been described as in the nature of a demurrer to the evidence.” (Martin v. Ideal Packing Co. (1957) 156 Cal.App.2d 232, 235.) 

 

“The trial judge’s power to grant a judgment notwithstanding the verdict is identical to [her] power to grant a directed verdict. The trial judge cannot weigh the evidence, or judge the credibility of witnesses. If the evidence is conflicting or if several reasonable inferences may be drawn, the motion for judgment notwithstanding the verdict should be denied. ‘A motion for judgment notwithstanding the verdict of a jury may properly be granted only if it appears from the evidence, viewed in the light most favorable to the party securing the verdict, that there is no substantial evidence to support the verdict. If there is any substantial evidence, or reasonable inferences to be drawn therefrom, in support of the verdict, the motion should be denied.’ ” (Hauter v. Zogarts (1975) 14 Cal.3d 104, 110.)  

 

            B.        New Trial

 

Pursuant to CCP § 657, a motion for a new trial may be granted if there is any:  

 

1.¿Irregularity in the proceedings of the court, jury or adverse party, or any order of the court or abuse of discretion by which either party was prevented from having a fair trial. 

2.¿Misconduct of the jury; and whenever any one or more of the jurors have been induced to assent to any general or special verdict, or to a finding on any question submitted to them by the court, by a resort to the determination of chance, such misconduct may be proved by the affidavit of any one of the jurors. 

3.¿Accident or surprise, which ordinary prudence could not have guarded against. 

4.¿Newly discovered evidence, material for the party making the application, which he could not, with reasonable diligence, have discovered and produced at the trial. 

5.¿Excessive or inadequate damages. 

6.¿Insufficiency of the evidence to justify the verdict or other decision, or the verdict or other decision is against law. 

7.¿Error in law, occurring at the trial and excepted to by the party making the application. 

 

When ruling on an application for a new trial, the court sits as an independent trier of fact.¿(Lane v. Hughes Aircraft Co. (2000) 22 Cal.4th¿405, 412.)¿The court, therefore, has broad discretion to order new trials, limited only by the obligation to state its reasons for granting a new trial and the existence of substantial evidence in the record to support those reasons.¿(Id.)¿¿In assessing¿the need for a new trial,¿the court must rely on its¿view of the overall record,¿taking into account such factors, among others, as the nature and seriousness of the¿alleged¿misconduct, the general¿atmosphere, including the judge’s control, of the trial, the likelihood of prejudicing the jury, and the efficacy of objection or admonition under all the circumstances.¿(Dominguez v. Pantalone¿(1989) 212 Cal.App.3d¿201, 211.)¿ 

 

“The right to a new trial is purely statutory, and a motion for a new trial can be granted only on one of the grounds enumerated in the statute.” (Fomco, Inc. v. Joe Maggio, Inc. (1961) 55 Cal.2d 162, 166.) Since new trial motions are “creatures of statute,” the procedural steps for making and determining such a motion are mandatory and must be strictly followed, or else the court acts in excess of jurisdiction. (Maroney v. Iacobsohn (2015) 237 Cal.App.4th 473, 485; Wall Street Network, Ltd. v. New York Times Co. (2008) 164 Cal.App.4th 1171, 1193; Mercer v. Perez (1968) 68 Cal.2d 104, 118.)  

 

PLAINTIFFS’ motion for judgment notwithstanding the verdict 

 

I.         Request for Judicial Notice

 

The court may take judicial notice of records of any court of record of the United States. (Evid. Code, § 452(d)(2).) However, the court may only judicially notice the existence of the record, not that its contents are the truth. (Sosinsky v. Grant (1992) 6 Cal.App.4th 1548, 1565.) 

 

Plaintiffs request judicial notice of the following:

 

Exhibit A: A true and correct copy of The Third Amended Complaint filed by Plaintiffs on July 20, 2023 with the Los Angeles Superior Court, assigned Case Number 20STCV27444.

 

Exhibit B: A true and correct copy of the Joint Submission of Jury Instructions submitted by the parties in the above-referenced action on February 26, 2025

 

Exhibit C: A true and correct copy of the Verdict entered by the jury in the above-referenced action on February 28, 2025, a true and correct copy of which is attached hereto as Exhibit “C”.

 

Exhibit D: A true and correct copy of the Judgment entered in the above-referenced action on April 2, 2025.

 

Plaintiffs’ request for judicial notice is granted.

 

II.        Discussion

 

Plaintiffs’ move for a judgment notwithstanding the verdict (“JNOV”) against Defendant Drail Investment, LLC (“Drail”) as to the first cause of action for violation of the Right to Repair Act (the “Act”) on the basis that the jury’s verdict is contrary to facts and law.  “A trial court may grant a motion JNOV only if it appears from the evidence, viewed in the light most favorable to the party who won the verdict, that there is no substantial evidence to support the verdict.” (Gillotti v. Stewart (2017) 11 Cal.App.5th 875, 898.)

 

                    A.             The Parties’ Stipulation

 

Plaintiffs show that on July 25, 2024, at the Final Status Conference, Defendant Drail stipulated to being a “Builder” under the Right to Repair Act in exchange for the negligence claim being dismissed. (Torkamani Decl., Ex. A [07/25/24 Trans. at p. 23:21-23].) Plaintiffs explain that the first cause of action for violation of the Act was pled in the alternative to the second cause of action for negligence in the event that Defendants were not the Builder of the Martel Property. (Id. at pp. 19:22-20:27.) Plaintiffs’ counsel explained that the first cause action is “framed as a cause of action for strict liability under the Right to Repair Act.” (Id. at p. 20:4-5.)

 

MR. TORKAMANI: [¶] If they’re builders, they're liable under the cause of action for strict liability under the Right to Repair Act. If they're not builders, they're subject to negligent violation of the standards set forth in the Right to Repair Act. So both are available as alternatives; not both available as to any specific party, they're alternative causes of action.

 

(Id. at p. 20:20-27.)

 

Defendant Drail agreed to stipulate that it qualified as a “Builder” for purposes of the Right to Repair Act in exchange for Plaintiffs dismissing the negligence claim:

 

MR. PARADES:         [¶] One, I do have authority to stipulate that Mr. Fattal is a builder under the Right to Repair Act so that the negligence claim does go away.

 

(Torkamani Decl., Ex. A  at p. 23:21-23.)

 

Defendant Drail’s counsel clarified that Martel and Drail, not just Fattal, were stipulating that they were Builders under the first cause of action:

 

THE COURT:             Let's clarify: Mr. Parades, how about the two other defendants? Are they also stipulating that those entities are builders?

 

MR. PARADES:         Yes, your Honor.

 

(Id., at pp. 24:27-25:2.)

 

The court summarized the Parties’ stipulation on the record as follows:

 

MR. TORKAMANI:   If we can get that stipulation in writing, we will dismiss the negligence cause of action as to the builders.

 

THE COURT:             It's a matter of record.

 

MR. SAUER:              It's on the record.

 

MR. TORKAMANI: Then we'll go ahead and dismiss the negligence.

 

THE COURT:             So, Mr. Paredes, if that is your firm position, that’s your representation to the Court, I’ll ask Mr. Torkamani if he wants to move to dismiss the negligence cause of action.

       

So I'm assuming that you truly are seeking, or stipulating that all three of your clients are builders in this case; is that correct?

 

MR. PARADES:         Yes, your Honor, that is correct.

 

MR. TORKAMANI:   We’ll dismiss the negligence cause of action, your Honor.

 

THE COURT:             All right.

 

(Id. at p. 25:3-21.)

 

Defendant Drail denies that it was the builder of the Martel Property.

 

Drail invests in renovation projects, as opposed to new builds such as the Martel Property. That being the case, Drail never would have, nor did it stipulate to being a builder of the Martel Property. What Drail did was stipulate that it was a builder, in return for Plaintiffs’ dismissal of their Negligence claim. In so doing, Drail eliminated Plaintiffs’ burden to prove that Drail was a builder of real estate, versus being merely an investor.

 

(Opposition, at p. 2:11-15.)

 

 “Courts may interpret stipulations to determine their effect.” (City of Martinez v. Workers' Comp. Appeals Bd. (2000) 85 Cal.App.4th 601, 621.) Defendant Drail is correct that in stipulating to being a “Builder” under the Right to Repair Act, Plaintiffs' burden of proof was eliminated. “Stipulations obviate the need for proof and are independently sufficient to resolve the matter at issue in the stipulation.” (People v. Palmer (2013) 58 Cal.4th 110, 118.) “Even at trial, counsel may stipulate to the existence or nonexistence of essential facts.” (Ibid.) However, Drail’s stipulation that it was a Builder under the Right to Repair Act also resolved the issue of whether Drail was the builder of the Martel Property in Plaintiffs’ favor.

 

The Act defines “Builder” as the entity that sold the property at issue:

 

(a) For purposes of this title, except as provided in subdivision (b), “builder” means any entity or individual, including, but not limited to a builder, developer, general contractor, contractor, or original seller, who, at the time of sale, was also in the business of selling residential units to the public for the property that is the subject of the homeowner's claim or was in the business of building, developing, or constructing residential units for public purchase for the property that is the subject of the homeowner's claim.

 

(b) For the purposes of this title, “builder” does not include any entity or individual whose involvement with a residential unit that is the subject of the homeowner's claim is limited to his or her capacity as general contractor or contractor and who is not a partner, member of, subsidiary of, or otherwise similarly affiliated with the builder. For purposes of this title, these nonaffiliated general contractors and nonaffiliated contractors shall be treated the same as subcontractors, material suppliers, individual product manufacturers, and design professionals.

 

(Civ. Code, § 911(a).)

 

Defendant Drail fails to explain how it could be a “Builder” under the Act but not be the “Builder” of the Martel Property when the Act defines “Builder” as the entity that sold “the property that is the subject of the homeowner's claim.” (Civ. Code, § 911(a).) In other words, Drail fails to show that it could stipulate to being the “Builder” under the Act while also maintaining that it was not the “Builder” of the Martel Property when such a position would be contrary to both the Act and the Parties’ stipulation.

 

            B.        The Jury Instructions, Verdict, and Relevant Case Law

 

The effect of Defendant Drail’s stipulation is reflected in the Joint Submission of Jury Instructions given to the Jury:

 

INSTRUCTION NO. 28

 

            In order for a defendant to be strictly liable under the Right to Repair Act, the defendant must be a builder. In this case, you are to accept as true that Fattal, Martel Investment, LLC, and Drail Investments, LLC qualify as builders for purposes of the Right to Repair Act.

 

INSTRUCTION NO. 29

 

            If you find that Fattal, Martel Investment, LLC, and/or Drail Investments, LLC are liable as builders under the Right to Repair Act, you should not attempt to apportion or allocate liability between them or any other party. Fattal, Martel Investment, LLC, and/or Drail Investments, LLC are liable for all damages that may be awarded under the Right to Repair Act.

 

(Plaintiffs’ RJN Ex. B.) Defendant Drail’s stipulation means it acquiesced to the fact it was a builder of the Martel Property. (Torkamani Decl., Ex. A at pp. 24:27-25:2.) The effect of the stipulation was explained to Drail by Plaintiffs’ counsel prior to Drail’s stipulation. (Id. at pp. 20:3-27.)

 

Civ. Code § 942 states:

 

In order to make a claim for violation of the standards set forth in Chapter 2 (commencing with Section 896), a homeowner need only demonstrate, in accordance with the applicable evidentiary standard, that the home does not meet the applicable standard, subject to the affirmative defenses set forth in Section 945.5. No further showing of causation or damages is required to meet the burden of proof regarding a violation of a standard set forth in Chapter 2 (commencing with Section 896), provided that the violation arises out of, pertains to, or is related to, the original construction.

As the Act has no causation component and because Defendant Drail was a “Builder” of the Martel Property, Plaintiffs only needed to show that it suffered a violation under the Act for Drail to be liable under the first cause of action.

 

Question No. 1 of the Verdict Form states as follows:

 

Which, if any, of the following Defendants do you find are liable to Plaintiffs Sebastian Zurita and Emiliano Zurita for violation of California's Right to Repair Act?

 

(Plaintiffs’ RJN Ex. C.) The Jury responded by finding that Defendants Ron Fattal and Martel Investment, LLC were liable but that Drail Investments, LLC was not. (Ibid.)

 

As the Jury found that Defendants Ron Fattal and Martel Investment, LLC were liable to Plaintiffs under the Act, it means that Plaintiffs prevailed in showing they suffered a violation under the Act. Therefore, Defendant Drail could only escape liability under the Act if it prevailed on one of the affirmative defenses set forth in Civ. Code section 945.5:

 

A builder . . .  under the principles of comparative fault pertaining to affirmative defenses, may be excused, in whole or in part, from any obligation, damage, loss, or liability if the builder, general contractor, subcontractor, material supplier, individual product manufacturer, or design professional, can demonstrate any of the following affirmative defenses in response to a claimed violation:

 

(a) To the extent it is caused by an unforeseen act of nature which caused the structure not to meet the standard. For purposes of this section an “unforeseen act of nature” means a weather condition, earthquake, or manmade event such as war, terrorism, or vandalism, in excess of the design criteria expressed by the applicable building codes, regulations, and ordinances in effect at the time of original construction.

 

(b) To the extent it is caused by a homeowner's unreasonable failure to minimize or prevent those damages in a timely manner, including the failure of the homeowner to allow reasonable and timely access for inspections and repairs under this title. This includes the failure to give timely notice to the builder after discovery of a violation, but does not include damages due to the untimely or inadequate response of a builder to the homeowner's claim.

 

(c) To the extent it is caused by the homeowner or his or her agent, employee, general contractor, subcontractor, independent contractor, or consultant by virtue of their failure to follow the builder's or manufacturer's recommendations, or commonly accepted homeowner maintenance obligations. . . 

 

(d) To the extent it is caused by the homeowner or his or her agent's or an independent third party's alterations, ordinary wear and tear, misuse, abuse, or neglect, or by the structure's use for something other than its intended purpose.

 

(e) To the extent that the time period for filing actions bars the claimed violation.

 

(f) As to a particular violation for which the builder has obtained a valid release.

 

(g) To the extent that the builder's repair was successful in correcting the particular violation of the applicable standard.

 

(h) As to any causes of action to which this statute does not apply, all applicable affirmative defenses are preserved.

 

Defendant Drail does not claim that it escaped liability under the Act because it prevailed on one of the affirmative defenses set forth in section 945.5.  Instead, Drail asserts the jury verdict is not erroneous because Plaintiff failed to meet its burden of showing that Drail is a “Builder’ as defined by Civ. Code § 911. As explained above, the effect of the July 25, 2024, stipulation is that Drail stipulated to being a builder under the Act, precluding Drail from challenging this fact and eliminating the need for Plaintiffs to prove Drail was a “Builder” under the Act.

 

First, Plaintiffs did put forth evidence that Drail entered into a contract to create the architectural plans for the Martel Property, while Defendant Fattal, as the sole owner and member of Drail, maintained he signed the contract on Drail’s behalf by mistake. (Torkamani Decl. Ex. C [02/24/2025 Trial Trans. at pp. 12:4-14:11, 25:12-26:24, 94:13-95:22; Exs. 7, 8, 13.) Defendant Drail fails to cite a single legal authority that would have allowed the Jury to deviate from the Jury Instructions, which instructed the Jury to consider Drail as qualifying as a “Builder” under the Act and not to apportion liability between Defendants. (Plaintiffs’ RJN Ex. B.) Plaintiffs were also entitled to rely on Drail’s stipulation that it was a Builder under the Act to prove Drail’s liability under the Act.

 

Second, because of the stipulation, the Jury was instructed to accept as true that Defendant Drail was a “Builder” under the Act, meaning that once Plaintiff established a violation of the Act, Drail could only escape liability if Drail prevailed on an affirmative defense set forth in Civ. Code section 911. (See Plaintiffs’ RJN Ex. B, Jury Instructions Nos. 28, 29.) Drail does not assert, nor does the record show, that Drail prevailed on an affirmative defense under section 911 such that it could escape liability under the Act. Drail also fails to cite any legal authority that would have permitted the Jury to deviate from the Jury Instructions.

Third, if Defendant Drail wished to renege on the stipulation that it was a “Builder” under the Act during trial, Plaintiffs should have been allowed to revive the negligence claim against Drail. During its closing argument, Drail’s counsel argued that Drail was not the builder of the Martel Property:

 

INSTRUCTION NUMBER 28, IN ORDER FOR A DEFENDANT TO BE STRICTLY LIABLE UNDER THE RIGHT TO REPAIR ACT, THE DEFENDANT MUST BE A BUILDER. IN THIS CASE, YOU ARE TO ACCEPT AT TRUE THAT FATTAL, MARTEL INVESTMENT AND DRAIL INVESTMENTS LLC QUALIFY  AS BUILDERS FOR THE PURPOSE OF THE RIGHT TO REPAIR ACT. WHY AM I SHARING THIS WITH YOU?  IT’S BECAUSE ALTHOUGH MR. FATTAL AND MARTEL INVESTMENTS, LLC WERE THE BUILDERS OF THE MARTEL PROPERTY, DRAIL INVESTMENTS WAS NOT. DRAIL INVESTMENTS WAS NOT THE BUILDER OF THE MARTEL PROPERTY AND THEREFORE HAS NO GREATER LIABLITY TO THE PLAINTIFFS THAN ANY OTHER BUILDER THAT EXISTS.

 

(Grossman Decl., Ex. A [Drail Closing Argument at pp. 57:22-58:28 [All caps original].)

 

The Jury was instructed that statements made during closing arguments are not evidence. Jury Instruction No. 5 states in the relevant part:

 

What the attorneys say during the trial is not evidence. In their opening statements and closing arguments, the attorneys will talk to you about the law and the evidence. What the lawyers say may help you understand the law and the evidence, but their statements and arguments are not evidence.

 

(Plaintiffs’ RJN Ex. B.)

 

While Defense counsel has the right to refer to the law in its closing argument, counsel cannot correct or vary from the instructions given to the jury. (See Gotcher v. Metcalf (1970) 6 Cal.App.3d 96, 100 [“However, it is the right of counsel, and therefore not misconduct, to discuss the law of the case in his oral argument, provided, of course, that his statement of the law is correct and is not at variance with instructions on the law which the court has advised counsel it will give.”].) “Nor does it violate the rule that the jury must follow the law as given in the jury instructions and must disregard the attorneys' remarks to the extent that they conflict with the jury instructions.” (People v. Brown (2017) 11 Cal.App.5th 332, 341.)

 

The court agrees that because Defendant Drail stipulated it was the “Builder” under the Act, the Act’s definition of builder designated Drail as the “Builder” of the Martel Property. (Civ. Code, § 911(a).) Therefore, Defendant Drail was strictly liable to Plaintiffs for violations of the Act along with the other Defendants. And as fault could not be apportioned, the Jury could not find that some “Builders” were responsible for the violations while other “Builders” were not. (Civ. Code, § 942.)

 

Defendant Drail asserts that Plaintiffs cannot show that Drail’s stipulation was a “clear and unmistakable” acknowledgment that Drail was the builder of the Martel Property. The court disagrees. “Case law is clear that ‘ “[w]aiver is the intentional relinquishment of a known right after knowledge of the facts.” [Citations.] The burden ... is on the party claiming a waiver of a right to prove it by clear and convincing evidence that does not leave the matter to speculation, and 'doubtful cases will be decided against a waiver' [citation].’ ” (Waller v. Truck Ins. Exchange, Inc. (1995) 11 Cal.4th 1, 30.) “The waiver may be either express, based on the words of the waiving party, or implied, based on conduct indicating an intent to relinquish the right.” (Ibid.)

 

The record before the court reflects that Defendant Drail expressly agreed to stipulate that it was a “Builder” as defined by the Act and that as the “Builder’ it was subject to strict liability for any violations under the Act. (Torkamani Decl., (Ex. A [07/25/24 Trans. at pp. 19:27-20:27,23:21-23, 24:27-25:21.) Defendant Drail fails to show that by stipulating to being a “Builder” under the Act, it could also take the position that it was not the “Builder” of the Martel Property when the Act defines the “Builder” as the entity that sold “the property that is the subject of the homeowner's claim.” (Civ. Code, § 911(a).) In other words, the legal effect of Drail accepting it was a “Builder” under the Act was that Drail accepted it was the “Builder” of the Martel Property and was subject to strict liability. Therefore, once the other “Builders” were found liable under the Act, “Drail” was also liable as liability could not be apportioned. (Civ. Code, § 942.)

 

Moreover, Defendant Drail accepted the benefits of having the negligence claim dismissed, to Plaintiffs’ detriment, while taking the position that Drail was mistakenly included as the entity that contracted the creation of the architectural plans for the Martel Property. (Torkamani Decl., Ex. C [02/24/2025 Trial Trans. at pp. 12:4-14:11, 25:12-26:24, 94:13-95:22; Exs. 7, 8, 13.) Drail waited until closing arguments to assert that it was not the “Builder” the Martel Property, despite the Act defining Drail as the “Builder” of the Martel Property. (Grossman Decl., Ex. A [Drail Closing Argument at pp. 57:22-58:28 [All caps original].)

 

Consequently, the court finds that the record shows by clear and convincing evidence that Defendant Drail stipulated that it was the “Builder” under the Act, precluding Drail from challenging said definition by asserting it was not the “Builder” of the Martel Property.

 

For the reasons set forth above, Plaintiffs’ Motion is granted.

 

Fattal Defendants’ motion for judgment notwithstanding the verdict 

 

I.         Request for Judicial Notice

 

The court may take judicial notice of records of any court of record of the United States. (Evid. Code, § 452(d)(2).) However, the court may only judicially notice the existence of the record, not that its contents are the truth. (Sosinsky v. Grant (1992) 6 Cal.App.4th 1548, 1565.) 

 

Fattal Defendants request judicial notice of the following:

Exhibit 1: Plaintiffs’ Third Amended Complaint filed on or about July 20, 2023.

 

Exhibit 2: Plaintiffs’ Brief re Motion in Limine No. 5 filed on or about February 16, 2025.

 

Exhibit 3: Minute Order entered February 19, 2025.

 

Exhibit 4: Excerpts of Jury Instructions filed on February 28, 2025.

 

Exhibit 5: Notice of Entry of Judgment filed on or about April 16, 2025.

 

Exhibit 6: Excerpts of Trial Testimony by Mark Vanderslice on February 21, 2025.

 

Exhibit 8: Excerpts of Trial Testimony of Sebastian Zurita on February 19, 2025.

 

Fattal Defendants’ request for judicial notice is granted.

 

Plaintiffs’ request judicial notice of the following:

 

Exhibit A: A true and correct copy of the Third Amended Complaint filed by Plaintiffs on July 20, 2023 with the Los Angeles Superior Court, assigned Case Number 20STCV27444.

 

Exhibit B: A true and correct copy of the Order on the Parties’ Stipulation Re Striking Allegations From Third Amended Complaint entered by the Court on January 13, 2025

 

Exhibit C: The Order on the Parties’ Stipulation Re Amendment Of Third Amended Complaint To Conform To Proof entered by the Court on February 25, 2025.

 

Exhibit D: A true and correct copy of the Joint Submission of Jury Instructions submitted by the parties in the above referenced action on February 26, 2025.

 

Exhibit E: A true and correct copy of the Verdict entered by the jury in the above-referenced action on February 28, 2025.

 

Exhibit F: The Judgment entered in the above-referenced action on April 2, 2025.

 

Plaintiffs’ request for judicial notice is granted.

 

            II.        Discussion

 

Defendants Martel Investment, LLC and Ron Fattal (collectively “Fattal Defendants”) seek a judgment notwithstanding the verdict and/or a new trial on Plaintiffs’ Third Cause of Action for Fraudulent Concealment. “A motion for judgment notwithstanding the verdict may be granted only if it appears from the evidence, viewed in the light most favorable to the party securing the verdict, that there is no substantial evidence in support.” (Sweatman v. Department of Veterans Affairs (2001) 25 Cal.4th 62, 68.)

 

The Fattal Defendants assert that Plaintiffs offered no evidence that the Martel Property’s construction defects and resulting damages were caused by any of the alleged non-disclosures rather than faulty workmanship. “As such, there is no causal connection between the non-disclosures and any of the damages awarded to the Plaintiffs. Without causation, there can be no fraudulent concealment, and on that basis Fattal is entitled to a judgment notwithstanding the verdict.” (Motion, at p. 2:11-14.)

 

The Jury Instructions on the Defendants’ Nondisclosure of Material Facts state as follows:

 

INSTRUCTION NO. 32

 

Sebastian and Emiliano Zurita also claim that Ron Fattal, Martel Investment, LLC failed to disclose certain information, and that because of this failure to disclose, Sebastian and Emiliano Zurita were harmed. In order to establish this claim, Sebastian and Emiliano Zurita must prove all of the following:

 

  1. That Sebastian and Emiliano Zurita purchased 415 North Martel Avenue from Ron Fattal and/or Martel Investment, LLC;
  2. That Ron Fattal and/or Martel Investment, LLC knew one or more of the following:

a.      Fattal acted as an owner/builder in connection with overseeing construction at the Property, despite the fact that he did not hold a valid contractor’s license and was not qualified to oversee the work of the subcontractors, and did not carry appropriate insurance coverage, in order to save money on the cost of construction of the property; or

 

b.     Fattal failed to hire a licensed general contractor to oversee the construction at the Property, failed to hire subcontractors who possessed the requisite licenses to perform the construction, failed to hire subcontractors who carried appropriate insurance coverage, and failed to hire tradespersons sufficiently skilled to construct the Property in order to save money on the cost of construction.

 

  1. That Ron Fattal and/or, Martel Investment, LLC did not disclose this information to Sebastian and Emiliano Zurita;
  2. That Sebastian and Emiliano Zurita did not know, and could not reasonably have discovered, this information;
  3. That Ron Fattal and/or Martel Investment, LLC knew that Sebastian and Emiliano Zurita did not know, and could not reasonably have discovered, this information;
  4. That this information significantly affected the value or desirability of the property;
  5. That Sebastian and Emiliano Zurita were harmed; and
  6. That Ron Fattal and/or Martel Investment, LLC’s failure to disclose the information was a substantial factor in causing Sebastian and Emiliano Zurita’s harm.

 

The Fattal Defendants do not dispute the fact that the Martel Property suffered from construction defects, and that Defendant Fattal failed to disclose that he held no valid contractor’s license or that there was no licensed general contractor or subcontractors who had the requisite skill to construct the Martel Property. Instead, the Fattal Defendants assert that there is no causal link between the Defendants’ fraudulent concealment and the damage award as they relate to the cost of correcting the construction defects and loss of rental income.

 

Jury Instruction No. 37 sets out the specific items of damages Plaintiffs sought:

 

Sebastian and Emiliano Zurita must prove the amount of their damages. However, Sebastian and Emiliano Zurita do not have to prove the exact amount of damages that will provide reasonable compensation for the harm. You must not speculate or guess in awarding damages.

 

The following are the specific items of damages claimed by Sebastian and Emiliano Zurita:

 

1.     Amounts that Sebastian and Emiliano Zurita reasonably spent in reliance on Ron Fattal and Martel Investment, LLC’s failure to disclose if those amounts would not otherwise have been spent in the purchase or acquisition of the property; and

 

2.     Amounts that Sebastian and Emiliano Zurita have spent or will spend to repair the property to the extent that Ron Fattal and Martel Investment, LLC’s failure to disclose was a substantial factor in causing those expenses; and

 

3.     Lost profits or lost rental income to the extent that Ron Fattal and Martel Investment, LLC’s failure to disclose was a substantial factor in causing those lost profits or lost rental income.

 

(Plaintiffs’ RJN Ex. D [Jury Instruction No. 37].)

 

The Jury awarded damages for the fraudulent concealment as follows:

 

Question No. 4: What is the total amount of damages, if any, that you award to Plaintiffs Sebastian Zurita and Emiliano Zurita with respect to their claim for Fraudulent Concealment?

 

ANSWER: Repair costs, investigative costs, and costs incidental to the repair:

$963,146.32

Rent and incidental rental costs: $1,012,077.00

 

(Plaintiffs’ RJN Ex. E [Jury Verdict].)

 

Plaintiffs point to the testimony of their real estate agent, Gloria Carmona (“Carmona”), who testified that Defendants were required to disclose information affecting the condition of the Martel Property “and everything that can impact the value or desirabilities [sic] of the home” via two documents, the Seller Property Questionnaire and the Transfer Disclosure Statement. (Torkamani Decl., Ex. B [02/20/2025 Trial Trans. at pp. 84:16-87:7].) On the Seller Property Questionnaire, Defendant Fattal did not disclose water intrusion issues and answered no to questions related to disclosures that pertain to the condition or repair or improvement of the property or “any past or present known material facts or other significant items affecting the value or desirability of the property not otherwise disclosed by buyer.” (Id. at pp. 96:2 – 98:4.)

 

Carmona further testified that Defendants were required to disclose the fact that work done on the Martel Property was not done by a licensed general contractor or an insured subcontractor:

 

            Q         BY MR. SAUER: MS. CARMONA, WITH RESPECT TO THE WORKER, IF THE CONTRACTOR IS EITHER SUB OR GENERAL OR UNLICENSED, IS THAT SOMETHING THAT SHOULD BE DISCLOSED?

            A         ABSOLUTELY.        

            Q         IF THERE'S NO INSURANCE THAT THE GENERAL CONTRACTOR, SUBS DON'T CARRY INSURANCE, IS THAT SOMETHING THAT SHOULD BE DISCLOSED?

            A         100 PERCENT.

            Q         AND AGAIN, IT GOES TO VALUE AND DESIRABILITY; CORRECT?

            A         CORRECT.

 

(Torkamani Decl., Ex. B at p. 99:7-18.)

 

Defendant Fattal confirmed that he was not a licensed contractor and that he acted as the owner-builder for the Martel Property and was responsible for overseeing its construction, hiring licensed subcontractors, and ensuring that they were insured. (Torkamani Decl., Ex. D [02/24/2025 Trial Trans. at pp. 18:6-23:15.) Plaintiffs presented evidence that Fattal did not take any action to confirm licenses or insurance of the subcontractors. (Id. at pp. 30:5-38:27.) Fattal also admitted that he did not disclose to Plaintiffs he acted as an owner-builder, did not carry a license as a general contractor, and did not believe these facts were not relevant to the value or desirability of the Martel Property. (Id. at pp. 39:3-42:25.)

 

Based on the evidence above, the Jury had substantial evidence to conclude that the costs of purchasing and subsequently having to repair the Martel Property could be attributed to both the faulty workmanship and the Defendants’ failure to disclose that there was no general licensed contractor or licensed and insured subcontractor who worked the Martel Property. In other words, Defendants’ nondisclosures were a substantial factor in bringing Plaintiffs’ harm because they induced Plaintiffs to purchase the Martel Property by depriving Plaintiff of the opportunity to know the true value of the Property and its desirability, causing Plaintiffs to incur repair costs and loss of rental income due to the purchase. “Causation for fraud is properly determined using the substantial factor test.” (Knutson v. Foster (2018) 25 Cal.App.5th 1075, 1091 [Confirming that causation for fraud is determined by the substantial factor test, not the “but for” test].)

 

Plaintiffs also point to the testimony of the expert, Jeffrey Hughes (“Hughes”), who prepared a report that included a list of the defects at the Martel Property and estimated the total repair costs of those defects to be around $743,100. (Torkamani Decl., Ex. C [02/21/2025 Trial Trans. at pp. 111:18-21; Trial Exs. 42, 46, 471, 535, 543].) Hughes also testified that additional costs had not yet been incurred and that the costs of repair were reasonable. (Id. at pp. 132:18-136:5.) Plaintiffs’ roofing and waterproofing expert, Mark Vanderslice (“Vanderslice”), prepared a report that gave a detailed explanation as to a variety of defects at the roof and waterproofing of the Martel Property. (Torkamani Decl., Ex. 47.)

 

Defendants’ expert, Don Boatwright (“Boatwright”), agreed that there were defects at the Martel Property, agreed with the Vanderslice’s report, and agreed that Plaintiffs had incurred repair costs.  He opined, however, that the list of defects was shorter than what Hughes had prepared, and that it would cost less to repair the Martel Property than the estimate given by Hughes. (Torkamani Decl., Ex. E [02/25/25 at pp. 13:13-40:20, 44:12-51:19; Trial Exs. 46, 57, 530.)  Boatwright did not provide an estimate of what the costs should have been. (Id. at p. 45:3-6.)

 

In addition, Plaintiffs also provided evidence in the form of testimony that they suffered loss of rental income due to Defendants’ nondisclosure. (Torkamani Decl., Ex. A [02/19/2025 Trial Trans. at pp. 86:27-89:16.) Plaintiffs leased the Martel Property for $17,000 per month. (Ibid.) The tenants began to complain about various property defects, including leakage in the master bedroom, patio, and living room. (Id. at p. 89:22-90:13.) The water damage caused the roof of one of the rooms to collapse, resulting in the lease termination. (Id. at p. 91:6-95:7; Exs. 62, 531.)

 

The court finds that substantial evidence supports the fact that Defendant Fattal’s concealment of the facts that he was not a licensed contractor and did not employ or oversee that licensed or insured subcontractors worked the Martel Property were substantial factors that led Plaintiffs to purchase the Martel Property and deprived Plaintiffs of the opportunity to cancel the purchase or negotiate a price reduction. (Torkamani Decl., Ex. B [02/20/2025 Trial Trans. at pp. 84:16-87:7.)

 

Accordingly, Plaintiffs incurred repair costs and other damages caused by Defendants’ nondisclosure of the facts that construction of the Martel Property was not adequately supervised and was built by unlicensed and/or uninsured contractors and/or by unskilled tradespeople. (Torkamani Decl., Ex. D [02/24/2025 Trial Trans. at pp. 18:6-23:15, 30:5-38:27, 39:3-42:25.) Substantial evidence also exists to support the Jury’s award of damages for the loss of rental income on the Martel Property because the loss was substantially caused by the Defendants’ concealment of who and how the Martel Property was built. (Torkamani Decl., Ex. A [02/19/2025 Trial Trans. at pp. 86:27-89:16; 91:6-95:7]; Exs. 62, 531.)

 

Because substantial evidence supports the Jury’s verdict, the Fattal Defendants’ JNOV is denied.

 

Fattal Defendants’ Motion For A New Trial

 

            I.         Discussion

 

In the alternative, the Fattal Defendants move for a new trial on the basis that there is insufficient evidence to justify the verdict. (CCP, 657(6).) “In weighing and evaluating the evidence, the court is a trier-of-fact and is not bound by factual resolutions made by the jury. The court may grant a new trial even though there be sufficient evidence to sustain the jury's verdict on appeal, so long as the court determines the weight of the evidence is against the verdict.” (Candido v. Huitt (1984) 151 Cal.App.3d 918, 923.) 

 

The evidence presented at trial shows that Defendants’ concealed of how and who built the Martel Property, despite such a disclosure being required because it related to the value and desirability of the Property. (Torkamani Decl., Ex. B [02/20/2025 Trial Trans. at p. 99:7-18]; Ex. D [02/24/2025 Trial Trans. at pp. 18:6-23:15, 30:5-38:27, 39:3-42:25.) Defendants’ concealment induced Plaintiffs to purchase the Martel Property by depriving Plaintiffs of the necessary facts needed to make an informed decision during the escrow “due process” period, which would have allowed Plaintiffs to negotiate a price reduction and/or decide whether to cancel the purchase of the Martel Property. Consequently, Plaintiffs purchased the property and incurred repair costs and loss of rental income. (Id. Ex. B at pp. 81:5-83:17, 84:16-87:7; Ex. D [02/24/2025 Trial Trans. at pp. 18:6-23:15, 30:5-38:27, 39:3-42:25]; Ex. A [02/19/2025 Trial Trans. at pp. 86:27-89:16; 91:6-95:7]; Exs. 62, 531.)

 

This evidence was sufficient for the jury to conclude that Defendants’ fraudulent concealment was a substantial factor in Plaintiffs’ decision to purchase the Martel Property, and that the consequential damages that flowed from that purchase were substantially caused by the concealment. (See Strebel v. Brenlar Investments, Inc. (2006) 135 Cal.App.4th 740, 752 [“The jury was instructed on the proper standard of causation (“substantial factor”) and the record supports its finding that defendants' fraud was a substantial factor in bringing about Strebel's damages.”].)

 

In other words, the jury could conclude that both the subpar workmanship and the Defendants’ concealment of the fact that no licensed or insured contractors worked or oversaw construction on the Martel Property, were substantial factors in Plaintiffs’ decision to purchase the Martel Property.  Plaintiffs incurred repair costs and loss of rental income resulting from the purchase. For this reason, damages on the third cause of action for fraudulent concealment were “inclusive of the compensatory damages awarded under the First and Second Causes of Action.” (Plaintiffs’ RJN, Ex. F.)

 

Therefore, the Fattal Defendants’ motion for a new trial is denied.

 

Conclusion

 

Plaintiffs’ JNOV is granted. The Fattals Defendants’ JNOV is denied as is their motion for a new trial.

 





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