Judge: Gail Killefer, Case: 23STCV22654, Date: 2024-08-06 Tentative Ruling

Case Number: 23STCV22654    Hearing Date: August 6, 2024    Dept: 37

HEARING DATE:                 Tuesday, August 6, 2024

CASE NUMBER:                   23STCV22654

CASE NAME:                        Antonio Lujak v. Travis Bott, et al.

MOVING PARTY:                 Defendant Travis Bott

OPPOSING PARTY:             Plaintiff Antonio Lujak

TRIAL DATE:                        Not Set

PROOF OF SERVICE:           OK

                                                                                                                                                           

PROCEEDING:                      Motion to Quash Service of Summons

OPPOSITION:                        16 July 2024

REPLY:                                  29 July 2024

 

TENTATIVE:                         Defendant Bott’s motion to quash is granted. Plaintiff’s request for sanctions is denied. Defendant to give notice.

                                                                                                                                                           

 

Background

 

On September 19, 2023, Antonio Lujack (“Plaintiff”) filed a Complaint against Travis Bott (“Bott”); Traders Domain Fx Ltd. (“Traders”); Digi Ware Technology Ptd LTD (“Digi Ware”); and Does 1 to 100.

 

The Complaint alleges twelve causes of action for:

1)     Breach of Fiduciary Duties;

2)     Negligence;

3)     Rescission of Securities Transactions (Material Misrepresentations);

4)     Joint and Several Liability Management;

5)     Recession and Restitution (Violation of Qualification Requirements);

6)     Joint and Several Liability of Offering Principals;

7)     Fraud;

8)     Conversion;

9)     Declaration of Constructive Trust;

10) Negligent Misrepresentation;

11) Conspiracy; and

12) Accounting.

 

On July 10, 2024, Defendant Travis Bott (“Bott”) filed a Motion to Quash the Plaintiff’s Summons and Complaint for lack of personal jurisdiction. Plaintiff opposes the Motion. The matter is now before the court.

 

motion to quash service of summons

 

I.         Legal Standard

 

 CCP § 418.10(a) states: “A defendant, on or before the last day of his or her time to plead or within any further time that the court may for good cause allow, may serve or file a motion…[t]o quash service of summon on the ground of lack of jurisdiction of the court over him or her.”¿¿¿¿¿ 

¿ 

When a defendant moves to quash service of process on jurisdictional grounds, the plaintiff has the initial burden of demonstrating facts justifying the exercise of jurisdiction.¿(State of Oregon v. Superior Court (1994) 24 Cal.App.4th 1550, 1557.)¿If the plaintiff meets his or her burden, the burden shifts to the defendant to demonstrate that the exercise of jurisdiction would be unreasonable. (Buchanan v. Soto (2015) 241 Cal.App.4th 1353, 1362. [“When a motion to quash is properly brought, the burden of proof is placed upon the plaintiff to establish the facts of jurisdiction by a preponderance of the evidence.”].) This burden must be met by competent evidence in affidavits and authenticated documentary evidence. (Jewish Defense Org. v. Superior Court¿(1999) 72 Cal.App.4th 1045, 1055.)

 

II.        Evidentiary Objections

 

Defendant Bott submitted evidentiary objections to the Declaration of Richard R. Farcus:

 

Objections Nos. 1 and 4 are overruled as the Plaintiff may rely on well-pleaded allegations made in the Compliant.

 

Objections Nos. 2, 3, 5, 10, 11, 12, 13, 14, and 15 are sustained as they are hearsay and lack foundation.

 

Objections Nos. 6, 7, 8, 9, and 16 are overruled.

 

III.      Discussion

 

Defendant Bott moves to quash the service of summons due to lack of personal jurisdiction. Defendant Bott submitted a declaration attesting that he has been a resident of the state of Utah for the last 12 years and does not direct, market, advertise, or employ any officer, distributor, servant, agent, employee, salesperson, or other representative within the State of California. (Botts Decl., ¶¶ 4, 7-11.) Bott asserts he does not maintain any bank accounts in California, pay taxes in California, or own any real property in California. (Bott, Decl., ¶ 12.) Bott asserts that he works for a Management Service Business in Utah, and has never been an employer, owner, or worked for Defendant Traders. (Bott Decl., ¶¶ 5, 6, 14.)

 

Lastly, Defendant Bott asserts that he was served at the wrong address because he has not lived in Alpine, Utah for two and half years as that is the address of his legally separated wife and she is not authorized to accept service on his behalf. (Bott Decl., ¶ 15.) Therefore, Defendant Bott asserts that the May 20, 2024, Proof of Service by substitute service at the address 1651 East Box Elder Circle, Alpine UT 84004 is improper.

 

In opposition to a motion to quash based upon lack of personal jurisdiction, complainants have the initial burden of filing evidence to show minimum contacts. (See Muckle v. Superior Court (2002) 102 Cal.App.4th 218, 228.) “It is plaintiff's burden to prove facts of jurisdiction by a preponderance of evidence.” (Cornelison v. Chaney (1976) 16 Cal.3d 143, 155.) “This burden must be met by competent evidence in affidavits and authenticated documentary evidence. An unverified complaint may not be considered as an affidavit supplying necessary facts.” (Ziller Electronics Lab GmbH v. Superior Court¿(1988) 206 Cal.App.3d 1222, 1233.)¿ 

 

Plaintiff offers only the declaration of his attorney, Richard D. Farkas. Farkas presents evidence that Defendant Botts is involved in another case entitled EM1 Capital LLC vs. Bott, et. al., United States District Court case number 2:24-cv-01044-SB-SSC, in which Bott attests under penalty of perjury under the laws of the United States that he has been a citizen of Utah since 2016 and that his permanent address is 1651 Box Elder Circle, Alpine Utah 84004. (Farkas Decl. Ex. A, ¶ 4.) The declaration was executed on February 13, 2024. (Farkas Decl. Ex. A.) Under the doctrine of judicial estoppel, the court accepts that service was proper at 1651 Box Elder Circle. (See The Swahn Group, Inc. v. Segal (2010) 183 Cal.App.4th 831, 842.) However, the fact that service is proper is insufficient to show that the court has personal jurisdiction over Defendant Bott in this action.

 

For specific jurisdiction, “courts consider the relationship among the defendant, the forum and the litigation.” (Snowey v. Harrah’s Entertainment, Inc. (2005) 35 Cal.4th 1054, 1062.) A court may exercise specific jurisdiction over a nonresident defendant only if: “(1) the defendant has purposefully availed himself or herself of forum benefits; (2) the controversy is related to or arises out of the defendant’s contacts with the forum, and (3) the assertion of personal jurisdiction would comport with fair play and substantial justice.” (Ibid.)¿¿¿¿ 

 

Plaintiff’s reliance on a copy of the First Amended Complaint in EM1 Capital LLC vs. Bott, et. al., United States District Court case number 2:24-cv-01044-SB-SSC, and a Third-Party Complaint in the same action does not establish that the court has personal jurisdiction over Bott in this action. Plaintiff cites no case law in which the court may rely on allegations made in the complaint of another action to assert personal jurisdiction over the defendant in a similar action. “Instead, each party's ‘contacts with the forum [s]tate must be assessed individually.’ ” (In re Boon Global Limited (9th Cir. 2019) 923 F.3d 643, 651 citing Calder v. Jones (1984) 465 U.S. 783, 790.)

Plaintiff submits no evidence Bott has purposefully availed himself of the benefits of conducting business in California and has minimum contacts with the State of California such that “the assertion of jurisdiction does not violate traditional notions of fair play and substantial justice.” (Brue v. Shabaab (2020) 54 Cal.App.5th 578, 589.) Other than then the conclusory allegations in the Complaint, Plaintiff offers no evidence that Bott reached out to Plaintiff about a business venture and that the venture was entered into and/or aimed at Plaintiff as a resident of California.

The Complaint alleges that it was Plaintiff who “contacted Defendant Pak” about the investing with Defendant Traders. (Compl., ¶ 12.) When jurisdiction is at issue, the court accepts well-pleaded allegations as fact. (Brue, supra, 54 Cal.App.5th at p. 590.) However, if the allegation is based on information and belief, the plaintiff must allege what information leads the Plaintiff to believe that the allegations are true. (Doe v. City of Los Angeles (2007) 42 Cal.4th 531, 551, fn. 5; Brown v. USA Taekwondo (2019) 40 Cal.App.5th 1077, 1106.)

 

The Complaint fails to allege what information led Plaintiff to believe that Bott is an authorized agent or representative or owner or operator of Defendant Traders. The Complaint fails to allege specific facts to show that Defendant Bott reached out to Plaintiff in California to entice him to invest with Defendant Traders, such that there was purposeful availment. Plaintiff’s Exhibit D, purporting to show screenshots in Plaintiff’s cell phone showing a message from Pak/David forwarded from Travis Bott is not authenticated by Plaintiff’s testimony and fails to explain who the intended recipient, “Goldie longstocking,” is and their connection to Plaintiff. (Farkas Decl., Ex. D.) Exhibit D fails to show Bott intended that his message be forwarded to Plaintiff and that he knew Plaintiff was a resident of California. The other screenshot appears to show the name “Adam Powell” and fails to explain how the screenshots relate to Plaintiff or Defendant Bott. Consequently, there is no evidence showing Defendant Bott is connected with Defendant Traders and that Defendant Bott has sufficient minimum contacts with California such that the court may exercise personal jurisdiction.

 

Therefore, the Motion to quash is granted.

 

Plaintiff’s request for sanctions is denied.

 

Conclusion

 

Defendant Bott’s motion to quash is granted. Plaintiff’s request for sanctions is denied. Defendant to give notice.