Judge: Gail Killefer, Case: 21STCV22638, Date: 2023-01-09 Tentative Ruling



Case Number: 21STCV22638    Hearing Date: January 9, 2023    Dept: 37

HEARING DATE:                 January 9, 2023

CASE NUMBER:                  21STCV22638

CASE NAME:                        Salvatore J. Balsamo, Trustee, Balsamo Family Trust dated May 16, 1991, as Amended and Restated April 20, 2004, Sub-Trust B. v. Victor Amaya, an individual d.b.a. M. P. Tire shop, et al.

MOVING PARTY:                Plaintiff, Salvatore J. Balsamo, Trustee, Balsamo Family Trust dated May 16, 1991 as Amended and Restated April 20, 2004, Sub-Trust B 

OPPOSING PARTIES:          Defendants, Marjorie Amaya and Amaya Tire Service, Inc. 

TRIAL DATE:                        March 7, 2023

PROOF OF SERVICE:          OK

                                                                                                                                                           

PROCEEDING:                     Plaintiff’s Motion for Summary Judgment

OPPOSITION:                       November 4, 2022

REPLY:                                  November 9, 2022

                                                                                                                                                           

TENTATIVE:                         Plaintiff’s motion is denied as to the first cause of action. It is otherwise granted. Plaintiff is to give notice.

                                                                                                                                                           

Background

This action arises in connection with a commercial building owned by Salvatore J. Balsamo, Trustee, Balsamo Family Trust dated May 16, 1991 as Amended and Restated April 20, 2004, Sub-Trust B (“Plaintiff”) located at 5502 S. Avalon Boulevard, Los Angeles, California (the “Property”). Plaintiff alleges that Defendant Victor Amaya (“Mr. Amaya”) has been a tenant at the Property for over 29 years and operates a tire shop known as Defendant, M.P. Tire Shop (“MP Tire”). Additionally, Defendant Marjorie Amaya (“Ms. Amaya”) has allegedly also worked at the business. On May 13, 2017, Plaintiff served a 3-day and 30-day notice on Mr. Amaya to quit the Property and Mr. Amaya failed to respond, resulting in Plaintiff filing an unlawful detainer action against him. Thereafter, the parties settled the unlawful detainer action, with Mr. Amaya agreeing to return possession of the Property by June 30, 2017.  

Mr. Amaya later sued Plaintiff, alleging that Plaintiff had wrongfully interfered with his business and wrongfully evicted him (“Debtor’s Action”).  According to Mr. Amaya’s lawsuit, Ms. Amaya and Plaintiff had allegedly entered into an oral agreement that Mr. Amaya could post a sign indicating that his business had moved. Plaintiff filed a Cross-Complaint in this action and had judgment (the “Judgment”) entered in his favor on the Cross-Complaint, which has not been satisfied to date. According to Plaintiff, Ms. Amaya incorporated Defendant, Amaya Tire Service, Inc. (“Amaya Tire Service”) and purchased all of the assets of Defendant MP Tire Service in an effort to hinder Plaintiff from collecting the Judgment.  

Plaintiff’s Complaint alleges the following causes of action: (1) declaratory relief, (2) to set aside void transfer of personal property, (3) to set aside voidable transfer, (4) judgment debtor’s interest in property to satisfy money judgment against Amaya and Amaya Tire Service. 

Plaintiff now moves for summary judgment as to the Complaint’s causes of action, as follows:

 

1.      Issue 1: Plaintiff will move this Court for an order granting summary adjudication as to the Fourth Cause of Action for a Creditor’s Suit on the grounds that there is no triable issue of material fact as to any elements of the Creditor’s claim.

2.      Issue 2: Plaintiff will move this Court for an order granting summary adjudication as to the Second Cause of Action to Set Aside Void Transfer of Personal Property on the grounds there is no triable issue of material fact as to any elements of Plaintiff’s claim for fraudulent or voidable transfer.

3.      Issue 3: Plaintiff will move this Court for an order granting summary adjudication on the Complaint’s Third Cause of action to Set Aside Voidable Transfer on the grounds there is no triable issue of material as to any elements of Plaintiff’s claim.

4.      Issue 4: Plaintiff  will move this Court for an order granting summary adjudication as to the First Cause of Action for Declaratory Relief on the grounds there is no triable issue of material fact as to any element of Plaintiff Creditor’s claim.

 

Defendants oppose the motion. The court will address the issues in the order numbered by Plaintiff’s motion.

Request for Judicial Notice

Plaintiff requests that the court take judicial notice of the following in support of their motion:

1.      Verified Amended Answer to Complaint filed in this action by Defendant Marjorie Amaya on September 3, 2021 (Exhibit R);

2.      Verified Amended Answer to Complaint filed in this action by Defendant Amaya Tire Service, Inc. on September 3, 2021 (Exhibit S);

3.      Articles of Incorporation of M.P. Tire Service, Inc. filed with the Office of the California Secretary of State on November 28, 2006 (Exhibit T);

4.      Statement of Information of M.P. Tire Service, Inc. filed with the Office of the California Secretary of State on January 29, 2007 (Exhibit U);

5.      Certificate of Information re M.P. Tire Service, Inc (Exhibit V);

6.      Petition for Dissolution of Marriage filed on March 1, 2016 in the matter of Ana Marjorie Pleitez-Amaya and Victor Amaya, Los Angeles County Superior Court Case No. BD637104 (Exhibit W);

7.      Judgment for Dissolution of Marriage entered on July 8, 2016 in the matter of BD637104 (Exhibit X);

8.      Statement of Information for Amaya Tire Service, Inc. filed with the Office of the California Secretary of State on April 6, 2021 (Exhibit Y);

9.      Printout from California Secretary of State website reflecting suspension and revivor of Amaya Tire Service, Inc. (Exhibit Z);

10.  Complaint for Unlawful Detainer filed on June 8, 2017 in the matter of Salvatore J. Balsamo, Trustee, Balsamo Family Trust dated May 16, 1991, as Amended and Restated April 20, 2004, Sub-Trust B v. Victor Amaya, Los Angeles County Superior Court Case No. 17U05883 (Exhibit AA);

11.  Complaint for Damages filed on February 14, 2018, in the matter of Victor Amaya v. Salvatore Balsamo, Trustee, etc., et al., Los Angeles County Superior Court Case No. BC694745 (Exhibit BB);

12.  First Amended Complaint for Damages filed on May 24, 2018 in the matter of Victor Amaya v. Salvatore Balsamo, Trustee, etc., et al., Los Angeles County Superior Court Case No. BC693745 (Exhibit CC);

13.  Cross-Complaint for (1) Breach of Lease; (2) Breach of Settlement Agreement; (3) Waste, filed on May 14, 2018 in the matter of Victor Amaya v. Salvatore Balsamo, Trustee, etc., et al., Los Angeles County Superior Court Case No. BC693745 (Exhibit DD);

14.  Judgment entered on September 10, 2019, in the matter of Victor Amaya v. Salvatore Balsamo, Trustee, etc., et al., Los Angeles County Superior Court case No. BC693745 (Exhibit EE).

Plaintiff’s request is granted. The existence and legal significance of these documents are proper matters for judicial notice. (Evidence Code § 452(d), (h).)

Discussion

I.                   Legal Authority

“The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.” (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843(“Aguilar”).)  CCP § 437c(a) provides:

A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding.  The motion may be made at any time after 60 days have elapsed since the general appearance in the action or proceeding of each party against whom the motion is directed or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct….  The motion shall be heard no later than 30 days before the date of trial, unless the court for good cause orders otherwise.  The filing of the motion shall not extend the time within which a party must otherwise file a responsive pleading.

A motion for summary judgment may be granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”  (CCP § 437c(c).) 

“The motion shall be supported by affidavits, declarations, admissions, answers to interrogatories, depositions, and matters of which judicial notice shall or may be taken.  The supporting papers shall include a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed.  Each of the material facts stated shall be followed by a reference to the supporting evidence.  The failure to comply with this requirement of a separate statement may in the court’s discretion constitute a sufficient ground for denial of the motion.”  (CCP § 437c(b)(1); see also Cal. Rules of Court, rule 3.1350(c)(2) & (d).) 

In analyzing motions for summary judgment, courts must apply a three-step analysis: “(1) identify the issues framed by the pleadings; (2) determine whether the moving party has negated the opponent's claims; and (3) determine whether the opposition has demonstrated the existence of a triable, material factual issue.”  (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294 (Hinsley).)  CCP § 437c(p)(2) provides:

A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action.  Once the defendant or cross-defendant has met that burden, the burden shifts to the plaintiff or cross-complainant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.  The plaintiff or cross-complainant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto.

(CCP § 437c(p)(2).)  The court must “view the evidence in the light most favorable to the opposing party and accept all inferences reasonably drawn therefrom.”  (Hinesley, 135 Cal.App.4th at p. 294; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389 [Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”].)  A motion for summary judgment must be denied where the moving party’s evidence does not prove all material facts, even in the absence of any opposition (Leyva v. Sup. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387). 

CCP § 437c(b) requires the opposition papers to include “a separate statement that responds to each of the material facts contended by the moving party to be undisputed, indicating if the opposing party agrees or disagrees that those facts are undisputed.”  (C.C.P., § 437c(b)(3).) However, the absence of a separate statement does not preclude the Court from considering the merits of the opposition where the case involves a single, simple issue with minimal evidentiary support.  (Gilbertson v. Osman (1986) 185 Cal.App.3d 308, 315-16 (disapproved on other grounds in Woods v. Young (1991) 53 Cal.3d 315); see also North Coast Business Park v. Nielsen Construction Co. (1993) 17 Cal.App.4th 22, 31 fn. 6; Security Pacific Nat. Bank v. Bradley (1992) 4 Cal.App.4th 89, 94.)

II.                Factual Summary

In 1998, Mr. Amaya took possession of the Property and operated a tire shop and automotive repair business called Amaya Tires. (Separate Statement in Support of Motion (“PSS”), ¶ 1; Exhibits in Support of Motion, Ex. A.) Prior to 2007, Amaya Tires was only a fictitious business name of Mr. Amaya. (PPS ­­¶2.) On November 28, 2006, Mr. Amaya’s wife, Ana Pleitez (“Ms. Pleitez”), formed M.P. Tire Service, Inc., listed herself as sole owner, listed the Property as the business address and business location. (PSS ¶¶3-5.) M.P. Tire Service, Inc. was suspended on November 1, 2010 and has not been revived. (PSS ¶7.)

In 2013, Mr. Amaya entered into a lease for the Property with Plaintiff and signed as “Victor Amaya, individually and dba MP Tire Shop.” (PSS ¶ 8; Exh. P.) Plaintiff, as Creditor to Mr. Amaya, became owner and successor landlord of the Property in July 2015. (PSS ­¶11.)

On March 1, 2016, Ms. Pleitez filed a Petition for dissolving her marriage to Mr. Amaya, claiming 100% of the business at the Property was owned by Mr. Amaya, along with all debts and obligations associated with that business. (PSS ¶12.) On July 8, 2016, the court awarded Mr. Amaya 100% of the business operating at the Property as his separate property. (PSS ¶13.)

On September 6, 2016, Marjorie Amaya, Mr. Amaya’s daughter (“Ms. Amaya”), formed Amaya Tire Service, Inc. as a California Corporation to “take over the family business,” but did not purchase any of M.P. Tire Services, Inc.’s business assets or assets belonging to Mr. Amaya. (PSS ¶¶14-18.) Amaya Tire Service, Inc. listed the Property as its business location. (PSS ¶¶19-20.) Amaya Tire Service, Inc. was suspended on April 23, 2019, and subsequently revived on April 6, 2021. (PSS ¶¶27-28.) Amaya Tire Service operated at the Property from approximately September 2016 to July 21, 2017 but did not file tax returns from 2018 through 2020. (PSS ­­¶¶29-31.) Further, after it was established, Amaya Tire Service has used Mr. Amaya’s equipment, inventory, telephone number, office, vendors, insurance, employees, accountant, and premises from the time it began operating at the Property. (PSS ¶32.)

Plaintiff filed an Unlawful Detainer Action against Mr. Amaya on June 8, 2017, Superior Court of California, County of Los Angeles Case No. 17U05883. (PSS ¶34.) Plaintiff and Mr. Amaya entered into a written settlement agreement regarding the Unlawful Detainer action on June 27, 2017. (PSS ¶36.) In the settlement agreement, Mr. Amaya represented he had “full, exclusive and absolute legal and physical possession of the [Property] and there is no other person or entity that is in possession or claims a right to possess all or any portion of the [Property] . . .,” and full ownership of the title to all personal property located at the Property. (PSS ¶¶37-38.)

Mr. Amaya turned over possession of the business at the Property to Plaintiff on July 21, 2017. (PSS ¶39.) On February 14, 2018, Mr. Amaya filed suit against Plaintiff for wrongful interference and wrongful eviction from the Property with the Los Angeles Superior Court, Case No. BC693745. (PSS ¶41.) Plaintiff filed a Cross-Complaint against Mr. Amaya for damages incurred; on September 10, 2019, judgment was entered in favor of Plaintiff on Plaintiff’s Cross-Complaint in the suit in the principal amount of $133,813.46. (PSS ¶¶43-44.)

Even though Ms. Amaya corresponded with Plaintiff on several occasions between September 2016 and July 21, 2017, Plaintiff contends, and Defendants do not dispute, that Ms. Amaya “never told [Plaintiff] that she or Defendant Amaya Tire Service had taken over [Mr. Amaya’s] business and/or its assets.” (PSS ¶46.) Plaintiff was never informed Ms. Amaya and Amaya Tire Service were operating at the Property during 2016 and 2017; they did not enter into any agreement with Plaintiff to operate from the Property. (PSS ­¶¶47-49.)

After eviction, Mr. Amaya moved his business to 6208 Main Street, Los Angeles, California (the Main Street Location”). (PSS ­¶40.) On November 7, 2017, Ms. Amaya entered into a lease for the Main Street location, and Mr. Amaya signed a personal guarantee for the Main Street lease with a guarantee he “hereby covenants, warrants and represents that the making of this Guaranty and making of the Lease is in furtherance of its business purpose and is to the benefit of Guarantor.” (PSS ¶¶51-52.)

Plaintiff contends, and Defendants do not dispute, that to the extent any assets of M.P. Tire Service or Mr. Amaya’s business were transferred to Amaya Tire Service or Ms. Amaya, there was no delivery, no change in possession, and no consideration given in exchange. (PSS ­­¶¶55-59.) “No consideration was given by Defendant Amaya Tire Service to [Mr. Amaya] for the transfer of any of his business assets to Defendant Amaya Tire Service.” (PSS ¶60.)

Plaintiff also contends, and Defendants do not dispute, Mr. Amaya continued working full-time at the business operating at the Property, both before and after any transfer of Mr. Amaya’s business to Amaya Tire Service or to Ms. Amaya. (PSS ¶62.) Further, there are no documents reflecting any such transfer of business assets. (PSS ¶63.) Plaintiff further contends, and Defendants again do not dispute, that to the extent Mr. Amaya’s assets were transferred to Amaya Tire Service and/or Ms. Amaya, Mr. Amaya was left insolvent as a result and now claims to have no assets following the transfer. (PSS ¶¶64-65.)

Lastly, Plaintiff contends, and Defendants do not dispute, Ms. Amaya maintains business records for Amaya Tire Service at her home, has purchased vehicles for Amaya Tire Service with personal funds and registered them in her name, and has paid personal expenses for her and her family with Amaya Tire Service’s bank account. (PSS ¶¶66-68.)

III.             Analysis

 

A.     First Issue: Fourth Cause of Action

CCP § 708.210 authorizes a judgment creditor to bring an action against a third party who has possession or control of property in which the judgment debtor has an interest so that the judgment creditor may have the debt applied to satisfy the money judgment. “Section 708.210 provides, ‘If a third person has possession or control of property in which the judgment debtor has an interest or is indebted to the judgment debtor, the judgment creditor may bring an action against the third person to have the interest or debt applied to the satisfaction of the money judgment.’ ” Cabral v. Soares (2007) 157 Cal.App.4th 1234, 1242.  See also generally  Cal. Practice Guide: Enf. of J. & Debt (The Rutter Group 2017) §6:1392, et seq. A creditor may be brought without attempting to exhaust other remedies. (Cabral, supra, 157 Cal.App.4th at 1243.) If the creditor can establish that the third person possesses or control any property which is not exempt where the judgment debtor has an interest or can be determined to be indebted to the judgment debtor, the “the court shall render” an order that such property or debt be applied to satisfy the creditor’s judgment against the judgment debtor. (CCP § 708.280.)

 

Plaintiff correctly explains, “[t]here are several remedies allowed in a creditor’s suit. These include (1) a judgment against the third party holding a judgment debtor’s property; (2) an order that the property be applied to satisfaction of the judgment; (3) an order that the third party may not transfer the property until it can be levied upon; and (4) money damages against the third party if property subject to a lien has been sold.” (Motion, 11.)

 

Plaintiff contends the evidence indisputably shows Ms. Amaya and Amaya Tire Service

 

“have possession and/or control of Debtor’s Business and all of the assets thereof, including the business assets, cash, deposit accounts, accounts receivable, trade fixtures, and other tangible and intangible assets of Debtor’s Business, all of which are currently located at the Main Street Location and/or at Defendant Daughter’s residence. Neither Defendant Daughter nor Defendant Amaya Tire Service ever paid any consideration to Defendant Debtor (or anyone else) for these assets, but merely changed the name of Debtor’s Business, stepped into Debtor’s shoes, and began running the business as if it belonged to them.”

 

(Id.)

 

Plaintiff contends that as all assets of Mr. Amaya’s business are now in the hands of Amaya Tire Service and/or Ms. Amaya, that such property in a third person’s hands should be “subject to levy to satisfy Plaintiff Creditor’s judgment, and Plaintiff Creditor is entitled to entry of Judgment against [Ms. Amaya] and Defendant Amaya Tire Service that all business assets held by them are subject to levy” to satisfy the earlier judgment against them; further, such assets “cannot be transferred until” Plaintiff’s judgment is “satisfied in full.” (Motion, 11-12.)

 

In opposition, Defendants confusingly contend summary adjudication should not be granted here because Mr. Amaya “does not have, nor has he ever had an interest in Defendant Amaya Tire Service,” and “is simply an employee of the corporation.” (Opposition, 8.) However, Mr. Amaya’s interests in Amaya Tire Service is the wrong inquiry, as a creditor’s suit claim is merely concerned with assets belonging to Mr. Amaya which were transferred to a third party, here Ms. Amaya and/or Amaya Tire Service. Further, these contentions are contradicted by the undisputed by the personal guarantee made by Mr. Amaya for Amaya Tire Service’s Main Street location lease, where Mr. Amaya represented Amaya Tire Service’s lease was also for his business purpose and his benefit. (PSS ¶¶51-52.)

 

Defendants also contend,

 

“Defendant Marjorie Amaya procured the equipment and created her own corporation and tire shop which ran out of the same facility as MP Tires Inc. as she negotiated terms of lease at a new location. The Plaintiff is simply attempting to enforce a judgment against Defendant Marjorie Amaya and Amaya Tire Service for an action that they were never included in.”

 

(Opp., 8.)

 

However, Defendants fail to explain what happened to those business assets after MP Tire Service Inc, which Defendants incorrectly name as “MP Tires Inc.,” was suspended in 2010 and after Mr. Amaya was awarded said business assets after the dissolution of his marriage, as described above. The fact Ms. Amaya and Amaya Tire Service were not involved in the earlier judgment is exactly why they are seen as third parties here, and why a creditor’s suit claim is brought against them.

 

In reply, Plaintiff correctly points out Defendants failed to file a separate statement in opposition, and have failed to dispute any of the contended material facts brought forth by Plaintiff. (Reply, 2.) Plaintiff therefore correctly contends that such failure can constitute an admission of all facts contained in the moving separate statement. (Id.; citing Thompson v. Iaone (2017) 11 Cal.App.5th 1180, 1186, fn. 4.) Thus, citing Aguilar, Plaintiff correctly explains that as Defendants have failed to dispute the material facts in their opposition, “the Court need only find that Plaintiff has made a prima facie showing that there are no triable issues of material fact.” (Reply, 3.) Further, Plaintiff correctly points out Defendants’ statements in opposition contradict statements made by Mr. Amaya and Ms. Amaya regarding ownership of assets and the chain of transfers of said assets. (Reply, 7.)

 

Viewing the evidence submitted in the light most favorable to Defendants, the court finds that Plaintiff has met their burden of making a prima facie showing that third parties, here Ms. Amaya and/or Amaya Tire Service, are in possession or control of personal properties in which Plaintiff Creditor has an interest after the entrance of judgement in their favor on their Cross-Complaint against Mr. Amaya. Therefore, Plaintiff has shown entitlement to summary adjudication as to the fourth cause of action in subjecting the aforementioned business assets to levy to satisy Plaintiff Creditor’s judgment and to prohibit transfer of any such business assets until Plaintiff’s judgment is satisfied in full.

 

For these reasons, Plaintiff’s motion is granted as to the fourth cause of action.   

 

B.     Second and Third Issues: Second & Third Causes of Action

“A fraudulent conveyance claim is set forth in the Uniform Fraudulent Transfer Act (UFTA), which is codified in Civil Code section 3439 et seq.  A fraudulent conveyance is a transfer by the debtor of property to a third person undertaken with the intent to prevent a creditor from reaching that interest to satisfy its claim.”  (Kirkeby v. Superior Court (2004) 33 Cal.4th 642, 648 (Kirkeby), internal quotation marks omitted.)

A claim for fraudulent transfer requires a showing that: (1) transfer was made, or obligation incurred by a debtor; (2) with actual intent to hinder, delay, or defraud any creditor of debtor; (3) without receiving a reasonably equivalent value in exchange for the transfer or obligation; and (4) resulting injury to creditor. Civil Code §§ 3439, et seq.; 3439.04(a), 3439.05; 8 Witkin Cal. Pro. (5th ed. 2008) Enforcement of Judgment §§495-98.  See also Filip v. Bucurenciu (2005) 129 Cal. App. 4th 825, 834 ("There is no minimum number of factors that must be present before the scales tip in favor of finding of actual intent to defraud.");  Kirkeby v. Sup. Ct. (2004) 33 Cal. 4th 642, 651 (fraudulent transfer was sufficiently alleged based on defendant’s transfer of property with the intent to defraud, hinder or delay creditors in collection);  Annod Corp. v. Hamilton & Samuels (2002) 100 Cal. App. 4th 1286, 1298 (proof of fraudulent intent in conveyances often is inferences from the surrounding circumstances);  Civ. Code §§ 3439.07(a)(1), 3439.08(a) (fraudulent transfers may be avoided as against transferees who did not take property in good faith for adequate consideration);  Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 (UFTA is merely cumulative of other remedies and not exclusive);  Mehrtash v. Mehrtash  (2001) 93 Cal.App.4th 75, 80  (“‘It cannot be said that a creditor has been injured unless the transfer puts beyond [her] reach property [she] otherwise would be able to subject to the payment of [her] debt.’”);  Mejia v. Reed (2003) 31 Cal.4th 657, 664 (“Under the UFTA, a transfer is fraudulent, both as to present and future creditors, if it is made ‘[w]ith actual intent to hinder, delay, or defraud any creditor of the debtor.’ ”);  Renda v. Nevarez (2014) 223 Cal.App.4th 1231, 1238  (“The UFTA does not impose on the debtor any liability additional to or distinct from the existing claim of the creditor; it simply allows the creditor to obtain ‘[a]voidance of the transfer ... to the extent necessary to satisfy the creditor's claim.’ ”);  ibid at 1237  (“to the extent a transfer is voidable, ‘the creditor may recover judgment’ for the lesser of the value of the asset or the amount needed to satisfy the creditor's claim, and the ‘judgment may be entered’ against the person for whose benefit the transfer was made.”);  Monastra v. Konica Business Machines, U.S.A., Inc. (1996) 43 Cal.App.4th 1628, 1645  (“A constructive trust plainly is a proper remedy” for a fraudulent transfer claim.);  Fidelity Nat. Title Ins. Co. v. Schroeder (2009) 179 Cal.App.4th 834, 850 (resulting trust is a cognizable remedy as an alternative to fraudulent transfer).   

“...[E]very transfer of personal property made by a person having at the time the possession of the property, and not accompanied by an immediate delivery followed by an actual and continued change of possession of the property, is void as against the transferor's creditors (secured or unsecured) at the time of the transfer and those who become creditors while the transferor remains in possession and the successors in interest of those creditors, and as against buyers from the transferor for value in good faith subsequent to the transfer.”

(Civ. Code § 3440, et seq.)

Here, Plaintiff contends the evidence shows “no actual transfer of [Mr. Amaya’s] Business to either [Ms. Amaya] or Defendant Amaya Tire Service ever occurred. Instead...” the name of Mr. Amaya’s business was changed and Ms. Amaya continued operating it in the same manner. (Motion, 12.) In the alternative, Plaintiff contends that if the court even finds a transfer took place, “any transfer was not accompanied by any delivery or change of possession.” (Id.) Plaintiff again points to Mr. Amaya’s personal guarantee made as part of the Main Street location for Amaya Tire Service and emphasizes Ms. Amaya’s admission that no consideration was given for any transfer of business assets. (Motion, 12-13.)

Plaintiff also points to the multifactor analysis of Civil Code § 3439.04 to make a prima facie showing of intent to defraud Plaintiff Creditor. (Motion, 13.) Those factors include: an alleged transfer to an insider, here Mr. Amaya’s daughter; no changing of hands for any business assets and the continued working of Mr. Amaya; lack of disclosure of any transfer to Plaintiff Creditor; the transfer being for the entirety of Mr. Amaya’s assets; the admission that no consideration was given in exchange; and the resulting insolvency of Mr. Amaya after the alleged transfer. (Motion, 13-14.) Plaintiff also explains that the transfer was made without Mr. Amaya receiving any reasonably equivalent value in return, and the alleged insolvency of Mr. Amaya is another factor which leans towards a prima facie showing of a claim under Civil Code S§ 3439.04 and 3439.07. (Id.)

As discussed above, while Defendants attempt to make contradictory statements in their opposition, their failure to dispute any material facts in an opposing separate statement constitutes admission of those facts. (Reply, 4-5.) Further, while Defendants contend that no concealment of any transfer took place and dispute any inference of an intent to defraud Plaintiff Creditor, Plaintiff correctly explains “[Ms. Amaya] paid no consideration for [Mr. Amaya’s] business, has no documents reflecting the transfer of a single asset, and instead simply began using [Mr. Amaya’s] business assets as if they were her own.” (Reply, 5-6.)

Viewing the evidence submitted in the light most favorable to Defendants, the court finds Plaintiff has again met their burden to make a prima facie showing of their entitlement to summary adjudication as to the second and third causes of action. As discussed above, Defendants’ opposition fails to dispute any material fact, and fails to counter Plaintiff’s prima facie showing of their claims. Plaintiff successfully points to a multitude of factors showing not only an inference of intent to defraud Plaintiff or hinder Plaintiff Creditor’s satisfaction of judgment, but also a fraudulent or voidable transfer entirely as defined by Civil Code §§ 3439, et seq. and 3440.

For these reasons, Plaintiff’s motion is granted as to the second and third causes of action.

C.     First Cause of Action: Declaratory Relief

Pursuant to CCP § 1060, any person interested under a contract may, ““in cases of actual controversy relating to the legal rights and duties of the respective parties,” bring an action for a declaration of his or her rights.¿“‘It is clear that declaratory relief may be asked for alone or with other relief…that the mere fact that the¿contract has already been breached and a cause of action therefor (one of the traditional remedies) has accrued, does not necessarily deprive the court of the power to grant declaratory relief under the law.’” (Bertero¿v. Nat’l General Corp.¿(1967) 254 Cal.App.2d 126, 136 [quoting¿Ermolieff¿v. R.K.O. Radio Pictures¿(1942) 19 Cal.2d 543, 547].)¿“The actual controversy language in section 1060¿encompasses a probable future controversy relating to the legal rights and duties of the parties that is ‘ripe’ when it has reached, but has not passed, the point that the facts have sufficiently congealed to permit an intelligent and useful decision to be made.” (TransparentGov¿Novato v. City of Novato¿(2019) 34 Cal.App.5th 140, 148 [internal citations omitted, emphasis in original].)¿ 

CCP § 187 provides that “[w]hen jurisdiction is, by the Constitution or this Code, or by any other statute, conferred on a Court or judicial officer, all the means necessary to carry it into effect are also given; and in the exercise of this jurisdiction, if the course of proceeding be not specifically pointed out by this Code or the statute, any suitable process or mode of proceeding may be adopted which may appear most conformable to the spirit of this Code.”  “Pursuant to its authority under section 187, the trial court may amend a judgment to add a judgment debtor.”  (Favila v. Pasquarella (2021) 65 Cal.App.5th 934, 942.) 

 

“‘As a general rule, a court may amend its judgment at any time so that the judgment will properly designate the real defendants . . ..  Judgments may be amended to add additional judgment debtors on the ground that a person or entity is the alter ego of the original judgment debtor . . . .  Amendment of a judgment to add an alter ego is an equitable procedure based on the theory that the court is not amending the judgment to add a new defendant but is merely inserting the correct name of the real defendant.  [Citation.]  In addition, even if all the formal elements necessary to establish alter ego liability are not present, an unnamed party may be included as a judgment debtor if the equities overwhelmingly favor the amendment and it is necessary to prevent an injustice.’”  (Favila, supra, 65 Cal.App.5th at 942 (quoting Carolina Casualty Ins. Co. v. L.M. Ross Law Group, LLP (2012) 212 Cal.App.4th 1181, 1188-89).) 

 

Here, Plaintiff seeks a declaratory judgment “that Defendants are a single enterprise and/or alter egos for the purposes of enforcing the Judgment, and seeks a judgment amending Plaintiff Creditor’s Judgment to add [Ms. Amaya} and Defendant Amaya Tire Service as additional judgment debtors.” (Motion, 14-15.) Plaintiff cites to CCP § 187 and Favila v. Pasquarella in support of this claim. (Id.) However, section 187 and Favila empower a court to amend “its” own previously entered judgment, and do not entrust a separate Department of this court to amend the previously entered judgment and/or order of another. Further, as this court already granted summary adjudication as to the second, third, and fourth causes of action, the court has already voided any alleged transfer of business assets and has already granted summary adjudication in subjecting said assets to a levy, as well as prohibiting the transfer of said assets until satisfaction of Plaintiff’s judgment. Therefore, the court finds no declaration of rights are needed as no further controversy exists at this time. Lastly, the court finds Plaintiff has failed to explain how a finding of alter ego liability can be established under this claim.

If Plaintiff seeks to amend the prior judgment on its Cross-Complaint, the court reminds Plaintiff it can make a motion to amend such judgment with the assigned Department.

Thus, the court finds the first cause of action is moot.

For these reasons, Plaintiff’s motion is denied as to the first cause of action.  

Conclusion

Plaintiff’s motion is denied as to the first cause of action. It is otherwise granted. Plaintiff is to give notice.