Judge: H. Jay Ford, III, Case: 21SMCV01885, Date: 2023-02-28 Tentative Ruling
Case Number: 21SMCV01885 Hearing Date: February 28, 2023 Dept: O
Case Name:
5916 S. Village Dr. LLC v Flying Tigers, Inc., et al.
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Case No.: 21SMCV01885
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Complaint Filed: 12-1-21 |
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Hearing Date: 2-28-23 |
Discovery C/O: N/A |
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Calendar No.: 4 |
Discover Motion C/O: N/A |
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POS: OK |
Trial Date: 8-8-22 |
SUBJECT: MOTION FOR
ATTORNEY’S FEES
MOVING
PARTY: Defendant Flying Tigers, Inc.
RESP.
PARTY: Plaintiff 5916 S.
Village Dr. LLC
TENTATIVE
RULING
Defendant Flying Tigers, Inc.’s
Motion for Attorney’s Fees is DENIED. Defendant
has already exceeded the cap on recoverable fees and costs under ¶36 of the
Lease Agreement. Plaintiff establishes that it denied the subject RFAs based on
a reasonable good faith belief grounded in evidence.
Plaintiff filed this UD action on
12-1-21 based nonpayment of rent under the lease agreement. Defendant obtained a judgment in its favor on
8-16-22 after jury trial. Judgment was
entered on 9-19-22.
I. Defendant is limited to recovery of $1000 in
fees and costs under ¶36 of the Lease Agreement and it has already recovered $5,012.91
in uncontested costs
Under ¶36 of the Lease Agreement, Defendant
is entitled to a maximum of $1000 in reasonable attorney’s fees and costs capped
at $1000 “In any action or proceeding arising out of this Agreement, the
prevailing party between Landlord and Tenant shall be entitled to reasonable
attorney’s fees and costs, collectively not to exceed $1,000 (or
$___________), except as provided in paragraph 35A.” See Motion, Ex. 4. Defendant has already been awarded $5,012.91
in uncontested costs pursuant to its memo of costs filed on 9-21-23. Defendant is therefore not entitled to
recover any fees under ¶36 of the Lease Agreement.
II. Defendant not entitled to cost of proof
sanctions under CCP §2033.420, because Plaintiff establishes that it had a
reasonable basis to deny the subject RFAs
A. Applicable Law
Showing required to recover sanctions by moving
party. “If a party fails to admit
the genuineness of any document or the truth of any matter when requested to do
so under this chapter, and if the party requesting that admission thereafter
proves the genuineness of that document or the truth of that matter, the party
requesting the admission may move the court for an order requiring the party to
whom the request was directed to pay the reasonable expenses incurred in making
that proof, including reasonable attorney's fees.” CCP §2033.420(a).
The party seeking cost of proof sanctions under CCP
§2033.420(a) must show they spent the amounts claimed to prove the issues that
should have been admitted. See Grace
v. Mansourian (2015) 240 Cal.App.4th 523, 530. The requested amounts must be segregated from
costs and fees expended to prove other issues.
Id.
Costs of proof sanctions “are recoverable only where the
moving party actually proves the matters that are the subject of the
requests. Further, those amounts cannot
be awarded if the parties stipulated to facts, even if the responding party had
previously denied them. The purpose of
requests for admission is to expedite trial and a stipulation achieves that
goal.” Id.
Exceptions to sanctions award. “The court shall make this order unless
it finds any of the following: (1) an
objection the request was sustained or a response to it was waived under
Section 2033.290. (2) The admission sought was of no substantial importance.
(3) The party failing to make the admission had reasonable ground to believe
that the party would prevail on the matter. (4) There was other good reason for
the failure to admit.” CCP §2033.420(b).
“The party seeking to benefit from an exception listed in
section 2033.420, subdivision (b) bears the burden to establish the
exception. In evaluating whether a ‘good
reason’ exists for denying a request to admit, a court may properly consider
whether at the time the denial was made the party making the denial held a
reasonably entertained good faith belief that the party would prevail on the
issue at trial. A party's reasonable
belief must be grounded in the evidence; it cannot be based merely on hope or a
roll of the dice. It is also not enough
for a party making the denial to hotly contest the issue; instead, there must
be some reasonable basis for contesting the issue in question before sanctions
can be avoided. A party's reliance on
‘self-serving testimony’ may be insufficient to establish a reasonable refusal
to admit a request for admission.” Spahn
v. Richards (2021) 72 Cal.App.5th 208, 216–217 (plaintiff had no reasonable
basis to believe that he would prevail on issue of existence of oral agreement
with defendant where plaintiff’s undisputed statements during the time the oral
agreement was allegedly formed, admitted that there was no such agreement); Doe
v. Los Angeles County Dept of Children & Family Services (2019) 37
Cal.App.5th 675, 691 (plaintiff did not reasonably deny the RFAs
where she did not conduct reasonable investigation to answer them); Gracie
v. Mansourian (2015) 240 Cal.App.4th 523, 532 (defendant did not
have reasonable belief that he would prevail on issue of his liability for car
accident at trial where plaintiff and witnesses testifies that defendant ran
through a red light, police report indicated defendant ran through red light,
plaintiff’s accident reconstruction expert indicated he ran through a red light
and defendant did not have any expert testimony on the issue, nor did defendant
ever testify that he saw the color of the light when he actually went through
the intersection).
B.
Application to facts
Defendant propounded RFAs pertaining
to nonpayment of rent, the basis of the UD action. In RFA Nos. 5, 9, 15, 24, 26
and 27, Defendant asked Plaintiff to admit that Defendant did not owe Plaintiff
any rent and Plaintiff was not entitled to any rent sought in the UD action. See Motion, Dec. of R. Jacobs, Ex. 1,
RFAs (set one) and Plaintiff’s responses.
Plaintiff denied these RFAs and the jury ultimately found that Defendant
did not fail to make any rental payments during the relevant period identified
in the 15-day notice. Id. at Ex. 2. Defendants therefore establish that they
proved the matters denied in the RFAs.