Judge: Joseph Lipner, Case: 24STCV04204, Date: 2024-12-12 Tentative Ruling



Case Number: 24STCV04204    Hearing Date: December 12, 2024    Dept: 72

 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

KATHERINE KELLER,

 

                                  Plaintiff,

 

         v.

 

 

ROBERT H. BISNO, et al.,

 

                                  Defendants.

 

 Case No:  24STCV04204

 

 

 

 

 

 Hearing Date:  December 12, 2024

 Calendar Number:  8

 

 

 

Defendants Robert H. Bisno (“Robert Bisno”); Jeanette Ann Bisno (“Jeanette Bisno”); Law Office of Robert H. Bisno (“Law Office”); Bisno Management Company, LLC (“Bisno Management”); Bisno Development Enterprise, LLC (“Bisno Development”); The Bisno Family Limited Partnership (“Bisno Family”); and Bisno Real Estate Group, LLC (“Bisno Real Estate”) (collectively, “the Bisno Parties”) bring a special motion under Code of Civil Procedure, section 425.16 to strike the Complaint filed by Plaintiff Katherine Keller (“Keller”).

 

Defendants additionally demur to the Complaint.

 

The Court DENIES the anti-SLAPP motion.

 

The Court OVERRULES the demurrer.

 

The Court determines that Keller may recover attorney’s fees against Defendants Robert Bisno and Jeanette Bisno associated with her opposition to the anti-SLAPP motion as it relates to the claim for malicious prosecution only. Since this is a portion of the attorney’s fees claimed, the Court will require additional information from the parties as to the proper amount of attorney’s fees.

 

Background

 

Factual Background

 

This is a malicious prosecution action. The following facts are taken from the parties’ separate statements. For the purposes of the anti-SLAPP motion, the Court resolves disputes of fact in Keller’s favor. For the purposes of the demurrer, the Court accepts the allegations of the Complaint as true.

 

In reviewing the parties’ separate statements, the Court notes that the Bisno Parties improperly filed their reply separate statement dated October 11, 2014 using Keller’s caption page – including the name of Keller’s attorney and law firm, and the title of Keller’s separate statement. The Court admonishes Defendant Robert Bisno, who represents himself as well as the other Bisno Parties, that it is inappropriate to make a filing under a caption page for an opposing party.

 

This case arises out of two underlying actions – one civil, and one criminal.

 

On December 12, 2018, Defendant Jeanette Bisno battered Keller at a parking garage in Beverly Hills, California (the “Parking Lot Incident”). (Keller’s Undisputed Fact (“UF”) 1.) The Parking Lot Incident was recorded on video, which shows Jeanette Bisno barricading Keller’s vehicle in with her own vehicle and repeatedly shoving Keller. (UF 47, 50.)

 

No Defendants other than Jeanette Bisno were involved in the Parking Lot Incident. (Defendants’ Response to Undisputed Fact (“RUF”) 1.)

 

On December 20, 2018, Defendant Robert Bisno, acting as Jeanette Bisno’s attorney, filed a civil complaint in Los Angeles Superior Court Case No. 18STCV09206 (the “Underlying Civil Case”) against 100 Doe defendants only. (UF 2.) The complaint arose out of the Parking Lot Incident and raised claims for (1) assault; (2) battery; (3) intentional infliction of emotional distress (“IIED”); (4) false imprisonment; and (5) false arrest.

 

On March 13, 2019, Jeanette Bisno was arraigned on one count of criminal battery (Pen. Code, § 242) in Los Angeles Superior Court Case No. 9AR31364 (the “Underlying Criminal Case”). (UF 3.) Robert Bisno, who is Jeanette Bisno’s husband, appeared as her attorney at the arraignment. (UF 4.)

 

            As the criminal defense attorney in the Underlying Criminal Case, Robert Bisno obtained discovery which included Keller’s name and contact information. (UF 5.) Keller contends that Robert Bisno and Jeanette Bisno then used this information to assist in the prosecution of the Underlying Civil Case. (UF 6.) On March 14, 2019, Robert Bisno, acting as Jeanette Bisno’s attorney, amended the complaint in the Underlying Civil Case to name Keller as a defendant. (UF 7.)

 

Keller contends that the Bisno Parties then engaged in a pattern of harassment of Keller which included calls to Keller’s job threatening to punish and financially harm Keller for speaking and continuing to speak to law enforcement with regard to the Underlying Criminal Case. (UF 8.) Keller contends that she feared for her safety and her ability to continue to participate in the criminal trial. (UF 9.)

 

On October 29, 2019, Jeanette Bisno pleaded no contest in the Underlying Criminal Case and was found guilty of criminal battery upon Keller. (UF 10.) Jeanette Bisno admitted under penalty of perjury that Keller never touched Jeanette Bisno. (UF 11.)

 

Defendants continued to prosecute the Underlying Civil Case. (UF 12.)

 

On December 2, 2020, the court in the Underlying Criminal Case addressed Jeanette Bisno’s actions on the record as follows: “It’s outrageous. …. Ms. Bisno is using the legal mechanism to further harass [Keller]. ….. I think the law does not account for situations like this, where you have a very sophisticated defendant who uses the legal system as a bully, as a hammer.” (UF 13; see Keller Decl. ¶ 37, Ex. I.)

 

On December 4, 2020, Jeanette Bisno voluntarily dismissed her claims against Keller in the Underlying Civil Case.

 

In the Underlying Civil Case, Keller proceeded to trial on a cross-complaint against Jeanette Bisno. (UF 16.) The cross-complaint raised claims for (1) assault; (2) battery; (3) IIED; (4) violation of the Bane Act, Civil Code, section 52.1; and (5) malicious prosecution. (Bisno Parties’ Request for Judicial Notice at p. 23, Item 3.)

 

Prior to trial, Robert Bisno, acting as Jeanette Bisno’s attorney, successfully argued in a series of motions in limine that Keller’s Bane Act and malicious prosecution claims were premature. (UF 17.) The court in the Underlying Civil Case ruled that the malicious prosecution claim was premature and that the Bane Act did not apply to the Parking Lot Incident. (UF 18-19.) Jeanette Bisno waived the statute of limitations as to the Bane Act. (UF 17, Keller Decl., Ex. L.) Neither the malicious prosecution claim, nor the Bane Act claim were litigated at trial in the Underlying Civil Case. (UF 20.)

 

On August 21, 2023, judgment was entered for Keller in the Underlying Civil Case for the sum of $193,255.00. (UF 21.)

 

Procedural History

 

Keller filed this action against the Bisno Parties on February 20, 2024, raising claims for (1) malicious prosecution, and (2) violation of the Bane Act. Keller subsequently named a number of additional corporate defendants via Doe amendments.

 

Keller alleges in her first claim that Defendants maliciously prosecuted the Underlying Civil Case against her. Keller alleges in her second claim that Robert Bisno disclosed the personal identifying information of Keller, a victim and witness in the Underlying Criminal Case, to Jeanette Bisno. Keller alleges that the Bisno Parties used that information not only to file the Underlying Civil Case, but to intimidate Keller and cause her to believe that the Bisno Parties would commit violence against her if she continued to participate in the criminal case.

 

On April 12, 2024, Keller served Robert, Jeanette, Bisno Management, Bisno Development, and Bisno Real Estate via personal service.

 

On May 6, 2024, Bisno Management, Bisno Development, and Bisno Real Estate (collectively, the “Anti-SLAPP Entities”) filed an anti-SLAPP motion (the “First Anti-SLAPP”), noticing the hearing for May 28, 2024. Keller filed an opposition on May 9, 2024 arguing, inter alia, that the motion did not provide an adequate notice period.

 

On May 17, 2024, default was entered against Law Office and Bisno Family.

 

On May 20, 2024, the Anti-SLAPP Entities withdrew the First Anti-SLAPP, stating that they would re-file it with an adequate notice period.

 

On May 21, 2024, default was entered against Robert, Bisno Management, Bisno Development, and Bisno Real Estate.

 

On May 23, 2024, Robert, Bisno Management, Bisno Development, and Bisno Real Estate filed a Notice of Intent to File Anti-SLAPP Motion.

 

On May 28, 2024, the Anti-SLAPP Entities filed the pending anti-SLAPP motion (the “Second Anti-SLAPP”).

 

On May 31, 2024, default was entered against Jeanette.

 

On June 3, 2024, Robert and Jeanette filed a notice of joinder to Second Anti-SLAPP.

 

On July 30, 2024, the Court denied the Second Anti-SLAPP on the basis that all of the moving parties had been defaulted.

 

On September 17, 2024, the Court granted the Bisno Parties’ motion for relief from default.

 

On September 18, 2024, the Bisno Parties filed this anti-SLAPP motion. On October 3, 2024, Plaintiff filed an opposition. On October 11, 2024, the Bisno Parties filed a reply.

 

On October 22, 2024, the Court ordered additional briefing on the applicability of the anti-SLAPP motion to Plaintiff’s Bane Act claim. The Bisno Parties filed a supplemental brief. Plaintiff filed a supplemental opposition. The Bisno parties filed a supplemental reply.

 

Request for Judicial Notice

 

The Court grants the parties’ requests for judicial notice and takes notice of the submitted court records.

 

Objections

 

The Court has considered Keller’s objections to the anti-SLAPP motion and joinder.

 

The Court overrules Keller’s objections that the motion is unclear, misleading, and improperly noticed because it contains the word “Proposed” on the caption page. The Bisno Parties have filed an errata document fixing this error. Furthermore, the intent of the motion is clear. Keller was able to file a well-argued opposition.

 

The Court overrules Keller’s objections that the motion was not timely filed. The motion was filed more than 60 days after service of the summons because Defendants were defaulted and subsequently relieved from default. For this same reason, the Court finds that the current motion is not an improper motion for reconsideration, because the Bisno Parties’ previous anti-SLAPP motion was denied because the parties were in default, and was not a decision on the merits. The Bisno Parties have now been relieved from default. The Court may now consider the anti-SLAPP motion.

 

Anti-SLAPP Motion

 

Legal Standard

 

Code of Civil Procedure, section 425.16 requires courts to strike causes of action arising from an act in furtherance of the defendant’s right of free speech or petition unless the plaintiff establishes that there is a probability that the plaintiff will prevail on the claim.

 

In assessing a defendant’s Code of Civil Procedure, section 425.16 special motion to strike, the court must engage in a two-step process. (Shekhter v. Financial Indem. Co. (2001) 89 Cal.App.4th 141, 150.) First, the court must decide whether the defendant has met the threshold burden of showing that the plaintiff’s cause of action arises from the defendant’s constitutional rights of free speech or petition for redress of grievances. (Ibid.) This burden may be met by showing the act which forms the basis for the plaintiff’s cause of action was an act that falls within one of the four categories of conduct set forth in Code of Civil Procedure section 425.16, subdivision (e). 

 

Once a defendant has met its initial burden and established that the anti-SLAPP statute applies, the burden shifts to the plaintiff to demonstrate a “probability” of success on the merits. (Code Civ. Proc., § 425.16, subd. (b); Equilon Enters. LLC v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 67.) “[T]he plaintiff must demonstrate that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts to sustain a favorable judgment if the evidence submitted by the plaintiff is credited.” (Matson v. Dvorak (1995) 40 Cal.App.4th 539, 548, internal quotations omitted.)

 

Malicious Prosecution

 

“A plaintiff must plead and prove three elements to establish the tort of malicious prosecution: a lawsuit (1) was commenced by or at the direction of the defendant and was pursued to a legal termination favorable to the plaintiff; (2) was brought without probable cause; and (3) was initiated with malice.” (Nunez v. Pennisi (2015) 241 Cal.App.4th 861, 872, quotation marks omitted.)

 

Protected Activity

 

To determine the gravamen of an alleged SLAPP, courts look to the factual basis for liability. (Wallace v. McCubbin (2011) 196 Cal.App.4th 1169, 1190, as modified on denial of reh'g (July 26, 2011) disapproved of on other grounds by Baral v. Schnitt (2016) 1 Cal.5th 376.)

 

            The anti-SLAPP statute applies to a “cause of action against a person arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue.”  (Civ. Proc. Code § 425.16, subd. (b)(1).) The statute defines such acts to include the following:

 

(1) any written or oral statement or writing made before a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law,

(2) any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law,

(3) any written or oral statement or writing made in a place open to the public or a public forum in connection with an issue of public interest, or

(4) any other conduct in furtherance of the exercise of the constitutional right of petition or the constitutional right of free speech in connection with a public issue or an issue of public interest. 

 

(Code Civ. Proc., §425.16, subd. (e).) 

 

The anti-SLAPP statute protects statements and writings made before a legislative, executive, or judicial proceeding. (Code Civ. Proc., § 425.16, subd. (e)(1).) “The constitutional right to petition ... includes the basic act of filing litigation....” (Birkner v. Lam (2007) 156 Cal.App.4th 275, 281.) “It is beyond question that the initiation and prosecution of [... a lawsuit is] protected under the anti-SLAPP statute.” (Paiva v. Nichols (2008) 168 Cal.App.4th 1007, 1017-1018).

 

“A cause of action arising from defendant's litigation activity may appropriately be the subject of a section 425.16 special motion to strike. Any act includes communicative conduct such as the filing, funding, and prosecution of a civil action.” (Thayer v. Kabateck Brown Kellner LLP (2012) 207 Cal.App.4th 141, 154 [internal citations and quotation marks omitted; cleaned up].) All communicative acts performed by attorneys as part of their representation of a client in a judicial proceeding or other petitioning context are per se protected as petitioning activity by the anti-SLAPP statute. (Cabral v. Martins (2009) 177 Cal.App.4th 471; Rusheen v. Cohen (2006) 37 Cal.4th 1048, 1056.) Further, “communications preparatory to or in anticipation of the bringing of an action or other official proceeding … are equally entitled to the benefits of section 425.16.” (Briggs v. Eden Council for Hope & Opportunity (1999) 19 Cal.4th 1106, 1115.) California courts have held that pre-litigation communications such as letters threatening to sue are protected activity. (Neville v. Chudacoff (2008) 160 Cal.App.4th 1255, 1266 [letter to employer's customers accusing ex-employee of misappropriation of trade secrets and threatening to file litigation was protected]; CKE Restaurants, Inc. v. Moore (2008) 159 Cal.App.4th 262, 271 [statements made in 60–day notice of intent to sue required by Prop. 65].) “Counseling others in anticipation of litigation or encouraging others to sue is considered protected prelitigation activity.” (Pech v. Doniger (2022) 75 Cal.App.5th 443, 462.)

 

“[A] statement is ‘in connection with’ litigation under section 425.16, subdivision (e)(2) if it relates to the substantive issues in the litigation and is directed to persons having some interest in the litigation.” (Neville v. Chudacoff, supra, 160 Cal.App.4th at p. 1266; see also Fremont Reorganizing Corp. v. Faigin (2011) 198 Cal.App.4th 1153, 1167 [statements made by the defendant, who was a court-appointed liquidator in an insolvency proceeding, to the Insurance Commissioner concerning the assets of the insolvent company were protected].) The audience to the statements need not be a party to the proceeding, or even a potential party, but the audience must have some level of specific interest in the litigation. (Contemporary Services Corp. v. Staff Pro Inc. (2007) 152 CA4th 1043, 1055 [email to customers accusing competitor of litigation-related misconduct was protected].)

 

“By definition, a malicious prosecution suit alleges that the defendant committed a tort by filing a lawsuit.” (Jarrow Formulas, Inc. v. LaMarche (2003) 31 Cal.4th 728, 735.) “Accordingly, every Court of Appeal that has addressed the question has concluded that malicious prosecution causes of action fall within the purview of the anti-SLAPP statute.” (Ibid.) Thus, Keller’s malicious prosecution claim arises out of protected activity.

 

Probability of Success

 

Litigation Privilege

 

California law does not permit liability for filing lawsuits, except in the case of malicious prosecution. (See Civ. Code, § 47.) However, the litigation privilege does not extend to actions for malicious prosecution. (Action Apartment Assn., Inc. v. City of Santa Monica (2007) 41 Cal.4th 1232, 1242.)

 

Collateral Estoppel

 

“As generally understood, [t]he doctrine of res judicata gives certain conclusive effect to a former judgment in subsequent litigation involving the same controversy.’ The doctrine has a double aspect. In its primary aspect, commonly known as claim preclusion, it operates as a bar to the maintenance of a second suit between the same parties on the same cause of action. In its secondary aspect, commonly known as collateral estoppel, [t]he prior judgment ... operates in a second suit ... based on a different cause of action ... as an estoppel or conclusive adjudication as to such issues in the second action as were actually litigated and determined in the first action.” (Boeken v. Philip Morris USA, Inc. (2010) 48 Cal.4th 788, 797 [internal citations and quotation marks omitted.)

 

“Claim preclusion, the primary aspect of res judicata, acts to bar claims that were, or should have been, advanced in a previous suit involving the same parties.” (DKN Holdings LLC v. Faerber (2015) 61 Cal.4th 813, 824 [internal quotations and citations omitted].) “Claim preclusion arises if a second suit involves: (1) the same cause of action (2) between the same parties (3) after a final judgment on the merits in the first suit.” (Ibid.) “To determine whether two proceedings involve identical causes of action for purposes of claim preclusion, California courts have consistently applied the ‘primary rights’ theory.” (Boeken v. Philip Morris USA, Inc. (2010) 48 Cal.4th 788, 797 [internal quotations and citations omitted].) “When two actions involving the same parties seek compensation for the same harm, they generally involve the same primary right.” (Id. at 798.) A dismissal ordered by a court constitutes a final judgment. (Code Civ. Proc., § 581d.)

 

“Issue preclusion differs from claim preclusion in two ways. First, issue preclusion does not bar entire causes of action. Instead, it prevents relitigation of previously decided issues. Second, unlike claim preclusion, issue preclusion can be raised by one who was not a party or privy in the first suit.” (DKN Holdings LLC v. Faerber, supra, 61 Cal.4th at p. 824.) “In summary, issue preclusion applies: (1) after final adjudication (2) of an identical issue (3) actually litigated and necessarily decided in the first suit and (4) asserted against one who was a party in the first suit or one in privity with that party.” (Id. at p. 825.)

 

The Bisno Parties argue that Keller is collaterally estopped from asserting her malicious prosecution claim because the court in the Underlying Civil Case denied her the ability to assert it there. The Bisno Parties’ argument is mistaken. The Underlying Civil Case did not result in a judgment on the merits. Rather, the court there found that Keller’s assertion of the malicious prosecution claim was premature because the litigation that was the subject of the claim had not yet terminated. (UF 18.) Defendants cannot both claim the benefit of the ruling that Keller’s previous assertion of the claim was premature and, now that her claim is mature, insist that the previous ruling is preclusive. Thus, collateral estoppel does not bar Keller from asserting her malicious prosecution claim.

 

The Bisno Parties contend that Keller may not “split her claims.” (Motion at p. 8:25.) Keller is not doing so. Her malicious prosecution claim is not being improperly “split” from her claims in the Underlying Civil Case because she could not have brought it there – as the judge there ruled.

 

The Bisno Parties contend that by failing to pursue her appeal of the motion in limine rulings, Plaintiff has acceded to their preclusive effect. This argument is mistaken for the reason that those rulings did not have a preclusive effect, as discussed above.

 

Statute of Limitations

 

The statute of limitations for malicious prosecution is one year for claims against attorneys and two years for claims against litigants. (Connelly v. Bornstein (2019) 33 Cal.App.5th 783, 798.)

 

A claim for malicious prosecution cannot state a cause of action until the underlying proceeding has terminated. (Babb v. Superior Court (1971) 3 Cal.3d 841, 846.) “ ‘[A] cause of action for malicious prosecution accrues upon entry of judgment in the underlying action....’ [Citation.] ” (Pasternack v. McCullough (2015) 235 Cal.App.4th 1347, 1356.)

 

Jeanette Bisno filed her request for dismissal of her claims against Plaintiff on December 4, 2020. (Bisno Parties’ Request for Judicial Notice, Item 7.) Judgment was entered for Keller in the Underlying Civil Case on August 21, 2023, stating “Katherine Keller is the prevailing party. Jeanette Ann Bisno shall take nothing from Katherine Keller.” (Bisno Parties’ Request for Judicial Notice, Item 15 at p. 4:6-11.) The August 21, 2023 judgment was the only judgment entered in the Underlying Civil Case. Thus, Plaintiff’s malicious prosecution claim accrued on August 21, 2023.

 

Keller filed this action on February 20, 2024, less than one year later. Keller’s malicious prosecution claim is therefore timely as against all of the Bisno Parties.

 

Factual Merit

 

As discussed above, “a plaintiff must plead and prove three elements to establish the tort of malicious prosecution: a lawsuit (1) was commenced by or at the direction of the defendant and was pursued to a legal termination favorable to the plaintiff; (2) was brought without probable cause; and (3) was initiated with malice.” (Nunez v. Pennisi (2015) 241 Cal.App.4th 861, 872, quotation marks omitted.)

 

Keller has provided evidence that Jeanette Bisno brought the Underlying Civil Case, and that Robert Bisno prosecuted the case as Jeanette Bisno’s attorney. The Court discusses the applicability to the entity defendants below in the Alter Ego section.

 

Jeanette Bisno dismissed all of her claims against Keller, resulting in a favorable termination for Keller. “A voluntary dismissal is presumed to be a favorable termination on the merits, unless otherwise proved to a jury.” (Sycamore Ridge Apartments, LLC v. Naumann (2007) 157 Cal.App.4th 1385, 1400.)

 

Keller has provided evidence that the Underlying Civil Action was brought without probable cause. Jeanette Bisno voluntarily dismissed her claims and furthermore testified under oath that Keller never touched her in the Parking Lot Incident. Jeanette Bisno also pled no contest to the criminal battery charges against her and was found guilty. In fact, the Parking Lot Incident was recorded on video, which was provided to Robert Bisno, Jeanette Bisno’s attorney. Thus, Keller has created a triable issue of fact that the Underlying Civil Action lacked probable cause.

 

Keller has similarly provided evidence of malice. Keller states in her declaration that Robert Bisno sent people to her house and places of work to look for her, and called her, stating that he would sue her for everything she had and ruin her life. (Keller Decl. ¶¶ 10-14.) Furthermore, Robert Bisno and Jeanette Bisno knew that Jeanette Bisno had battered Keller, and that Keller had not touched Jeanette Bisno. A reasonable jury could infer that Robert Bisno and Jeanette Bisno acted with malice in bringing the Underlying Civil Action against Keller.

 

The Bisno Parties argue in their reply that Keller cannot overcome Jeanette Bisno’s advice of counsel defense or Robert Bisno’s reliance on client information. (Reply at p. 1:21-24.) This argument was not raised in the moving papers. The Court deems it waived for the purposes of the anti-SLAPP motion.

 

The Court therefore denies the anti-SLAPP motion as to the malicious prosecution claim against Robert Bisno and Jeanette Bisno.

 

Alter Ego

 

The remaining issue is that of whether the entity defendants can be tagged with liability. Keller alleges that each of the entity defendants are alter egos of Robert Bisno and Jeanette Bisno.

 

“In California, two conditions must be met before the alter ego doctrine will be invoked. First, there must be such a unity of interest and ownership between the corporation and its equitable owner that the separate personalities of the corporation and the shareholder do not in reality exist. Second, there must be an inequitable result if the acts in question are treated as those of the corporation alone.” (Sonora Diamond Corp. v. Superior Court (2000) 83 Cal.App.4th 523, 538.) When these conditions are met, courts disregard the corporate structure and impute the actions of a corporation onto its owner or parent. (McLaughlin v. L. Bloom Sons Co. (1962) 206 Cal.App.2d 848, 851-852.)

 

In determining whether to apply the doctrine, California courts consider a number of factors which include but are not limited to (1) inadequate capitalization, (2) commingling of funds, records, and other assets, (3) disregard of corporate formalities (e.g., stock issuance, holding board meetings, keeping of minutes, election of officers and directors, segregation of corporate records), (4) the same equitable ownership in the two entities, (5) the same directors and officers, (6) confusion about corporate identity, (7) use of the same offices and employees, (8) use of subsidiary as a mere shell or conduit for the affairs of the parent, and (9) lack of segregation of corporate records. (Brooklyn Navy Yard Cogeneration Partners, L.P. v. Superior Court (Parsons Corp.) (1997) 60 Cal.App.4th 248, 258.)

 

There are two defendant entities which the Bisno Parties contend do not actually exist. In his declaration in support of the previous anti-SLAPP motion, Robert Bisno declared that the Law Office of Robert H. Bisno (“Law Office”) is not an entity and that The Bisno Family Limited Partnership (“Bisno Family”) is not an entity. (Willoughby Decl., Ex. N ¶ 5.) Robert Bisno now declares that he does business under the name of the Law Office of Robert H. Bisno (indeed, he captions his filing as such), but that the Law Office is not a separate entity. (Reply Bisno Decl. ¶ 6.) His law practice is conducted from 14820 Mulholland Dr., Los Angeles, California 90077, a property owned by James and Jan, LLC. (Reply Bisno Decl. ¶ 6.) Robert Bisno declares that it has been over 15 years since there was any activity in Bisno Family. (Reply Bisno Decl. ¶ 6.)

 

The remaining entity defendants are Bisno Management Company, LLC (“Bisno Management”); Bisno Development Enterprise, LLC (“Bisno Development”); and Bisno Real Estate Group, LLC (“Bisno Real Estate”).

 

Despite stating that he does business as the Law Office, Robert Bisno has reported to the California State Bar that Bisno Management is his place of business. (UF 25.) In fact, Bisno Management maintains a principal address of 14820 Mulholland Dr., Los Angeles, California 90077 – the same address as the Law Office. (UF 28.) Critically, this address is also the home address for Robert Bisno and Jeanette Bisno. (UF 30-31.) Bisno Development, Bisno Real Estate, and Bisno Family all similarly operate out of the home of Robert Bisno and Jeanette Bisno. (UF 32, 34, 34.)

 

Robert Bisno is the registered agent for service of process for Bisno Management, Bisno Development, Bisno Real Estate, and Bisno Family. (UF 29, 33, 35 37.)

 

Perhaps the most telling evidence on the alter ego issue, however, is Jeanette Bisno’s trial testimony in the Underlying Civil Case:

 

Q: How much do you have in the bank account?

A: Zero.

Q: Zero?

A: Probably.

Q: How much do you have in your savings?

A: Zero.

Q: You have no savings and you have no checking account, how do you support yourself?

A: I borrow money from the LLC.

 

(Willoughby Decl., Ex. W at p. 30:2-10.)

 

            Jeanette Bisno’s testimony creates a triable issue that she – and her husband, with whom she shares an address – use on the various entities that they maintain as personal sources of funds thereby comingling funds and disregarding corporate formalities.

 

            The Court notes that Robert Bisno states in his declarations that Jeanette Bisno does not own or control the entity defendants. Robert Bisno also declares that he gives Jeanette Bisno money from the LLCs when she asks him to, in his own discretion.

 

Noting that this is a dispute of fact, the Court does not reach a finding on whether Keller has proven alter ego as to any of the entity defendants. The Court does not need to. The Court finds that Keller has shown adequate factual merit to the allegation that the entities are alter egos of Robert Bisno and Jeanette Bisno for the purposes of the anti-SLAPP motion.

 

The Court therefore denies the anti-SLAPP motion as to the malicious prosecution claim against the Law Office, Bisno Management, Bisno Development, Bisno Real Estate, and Bisno Family.

 

Bane Act

 

The elements of a claim for violations of the Tom Bane Civil Rights Act are (1) the defendant interfered with or attempted to interfere with the plaintiff’s constitutional or statutory rights by threatening or committing violent acts; (2) the plaintiff reasonably believed that if he or she exercised his or her constitutional rights the defendant would commit violence against him or her or his or her property, or the defendant injured the plaintiff or his or her property to prevent him or her from exercising his or her constitutional rights or retaliated against the plaintiff for having exercised his or her constitutional rights; (3) the plaintiff was harmed; and (4) the defendant’s conduct was a substantial factor in causing the plaintiff’s harm. (Civ. Code, § 52.1; Austin B. v. Escondido Union School Dist., 149 Cal.App.4th 860, 882.) A Bane Act violation requires that the defendant have a specific intent to violate the plaintiff’s rights. (Cornell v. City & County of San Francisco (2017) 17 Cal.App.5th 766, 801-802.)

 

“Except as provided in paragraph (2), no attorney shall disclose or permit to be disclosed to a defendant, members of the defendant's family, or anyone else, the personal identifying information of a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section 1054.1, other than the name of the victim or witness, unless specifically permitted to do so by the court after a hearing and a showing of good cause.” (Pen. Code, § 1054.2.)

 

Protected Activity

 

Where there is not pending litigation, the question is whether the statements were made in anticipation of litigation. (Neville v. Chudacoff, supra, 160 Cal.App.4th at p. 1268.) The anticipated litigation must be “contemplated in good faith and under serious consideration” in order for the connected statements to qualify for protection. (Ibid.)

 

Keller’s Bane Act claim does not concern the Parking Lot Incident, but rather, the Bisno Parties’ alleged use of Keller’s information obtained in discovery through the criminal case to intimidate Keller and threaten her with violence if she continued to participate in the criminal case as a witness.

 

Keller states in her declaration that Robert Bisno sent people to her house and places of work to look for her, and called her, stating that he would sue her for everything she had and ruin her life. (Keller Decl. ¶¶ 10-14.) The Bane Act claim arguably concerns—in part—protected activity as to the disclosure of Keller’s witness information, the prosecution of the Underlying Civil Case, and the threats to sue her.

 

However, Defendants have not provided any reason why sending people to Plaintiff’s house and places of work constitutes a communication made in a judicial proceeding, nor does the Court believe that it is one.

 

“[A]n anti-SLAPP motion, like a conventional motion to strike, may be used to attack parts of a count as pleaded.” (Baral v. Schnitt (2016) 1 Cal.5th 376, 393 [emphasis added].) “Allegations of protected activity supporting the stricken claim are eliminated from the complaint, unless they also support a distinct claim on which the plaintiff has shown a probability of prevailing.” (Ibid.) “At the first step, the moving defendant bears the burden of identifying all allegations of protected activity, and the claims for relief supported by them. When relief is sought based on allegations of both protected and unprotected activity, the unprotected activity is disregarded at this stage. If the court determines that relief is sought based on allegations arising from activity protected by the statute, the second step is reached.” (Id. at p. 396.)

 

The Court therefore finds that Robert Bisno’s statements to Plaintiff that he would sue her are protected conduct. The Court similarly finds that Robert Bisno’s disclosure of Plaintiff’s witness information for the purpose of suing her, and the Robert and Jeanette Bisno’s subsequent prosecution of the Underlying Civil Case, constitute protected conduct. Robert Bisno’s action of sending people to Plaintiff’s home and workplace to look for her is not protected conduct.

 

            The Court proceeds to the second prong analysis as to the protected conduct only, and not the unprotected conduct.

 

Probability of Success

 

Litigation Privilege

 

As discussed above, California law does not permit liability for filing lawsuits, except in the case of malicious prosecution. (See Civ. Code, § 47.) This “litigation privilege[ ] has been referred to as ‘the backbone to an effective and smoothly operating judicial system.’ [Citation.]” (Silberg v. Anderson (1990) 50 Cal.3d 205, 214-215.) “The litigation privilege is absolute… . [Citation.]” (Kashian v. Harriman (2002) 98 Cal.App.4th 892.)

 

The litigation privilege applies to any communication: (1) made in judicial or quasi-judicial proceedings; (2) by litigants or other participants authorized by law; (3) to achieve the objectives of the litigation; and (4) that have some reasonable relevancy to the subject matter of the action. (Silberg v. Anderson (1990) 50 Cal. 3d 205, 212.) “It is also well settled that the absolute privilege … extends to preliminary conversations and interviews between a prospective witness and an attorney if they are some way related to or connected with a pending or contemplated action. (Ascherman v. Natanson (1972) 23 Cal.App.3d 861, 865.)

 

The litigation privilege applies to contemplated litigation; however, it “applies only when the communication has some relation to a proceeding that is contemplated in good faith and under serious consideration. The bare possibility that the proceeding might be instituted is not to be used as a cloak to provide immunity for defamation when the possibility is not seriously considered.” (Edwards v. Centex Real Estate Corp. (1997) 53 Cal.App.4th 15, 32 [internal citation and quotation marks omitted; emphasis in original].)

 

The Court stated in its earlier and now-superseded tentative ruling that the litigation privilege appears to apply to the prosecution of the Underlying Civil Case or to Robert Bisno’s calls to her threatening litigation because they were taken as a part of contemplated, and then actual, litigation.

 

            Plaintiff argues that her Bane Act claim is not subject to the litigation privilege because it arises out of her malicious prosecution claim under the primary rights theory.  Based on its review of this issue, the Court agrees with Plaintiff.

 

            “ ‘California has consistently applied the 'primary rights' theory, under which the invasion of one primary right gives rise to a single cause of action.’ [Citation.] ” (Bay Cities Paving & Grading, Inc. v. Lawyers' Mutual Ins. Co. (1993) 5 Cal.4th 854, 860.) “ ‘[T]he “cause of action” is based upon the harm suffered, as opposed to the particular theory asserted by the litigant. ... Even where there are multiple legal theories upon which recovery might be predicated, one injury gives rise to only one claim for relief.’ ” (Ibid.)

 

            Plaintiff argues that the conduct underlying her Bane Act claim is conduct that is malicious prosecution, and that her Bane Act claim is thus the same ‘claim for relief’ as her malicious prosecution claim – just asserted under a different theory. Understood this way, Plaintiff’s Bane Act claim – as to the protected conduct, at least – is not a claim that the Bisno Parties violated Plaintiff’s civil rights regardless of whether they committed malicious prosecution, but rather that the Bisno Parties violated Plaintiff’s civil rights by committing malicious prosecution. 

            To put matters another way:  Plaintiff will succeed on the protected portions of her Bane Act claim if and only if she succeeds on her malicious prosecution claim. If her malicious prosecution claim fails, so will the protected portions of her Bane Act claim relating to the litigation.

 

The Court first notes that California authority on the applicability of the litigation privilege to Bane Act claims for malicious prosecution is sparse. In Hagberg v. California Federal Bank (2004) 32 Cal.4th 350, the defendant moved for summary judgment against the plaintiff, including on the plaintiff’s Bane Act claim, on the theory that the conduct at issue was subject to the litigation privilege. (Hagberg v. California Federal Bank (2004) 32 Cal.4th 350, 358.) There, the plaintiff had not raised a claim for malicious prosecution. (Id. at p. 357.) The Court explained that “statements [that] are privileged pursuant to Civil Code section 47, subdivision (b) (section 47(b)),1 … can be the basis for tort liability only if the plaintiff can establish the elements of the tort of malicious prosecution.” (Id. at p. 355.) Although the plaintiff contended that the Bane Act formed an exception to the litigation privilege, the Court did not rule on that argument because it found that there was no triable issue that the underlying facts supported the plaintiff’s Bane Act claim. (Id. at pp. 375-376.) Hagberg thus raises the issue but does not resolve it.

 

“No case since Hagberg discusses application of Section 47(b) to a claim for violation of Section 52.1.” (Fenters v. Yosemite Chevron (E.D. Cal. 2010) 761 F.Supp.2d 957, 999.) In Fenters, the plaintiff raised a section 52.1 claim – i.e., a Bane Act claim – based on malicious prosecution. (Ibid.) There, the defendant similarly sought summary judgment under the litigation privilege. (Id. at p. 995.) The court denied summary judgment as to the plaintiff’s Bane Act claim, but did not explain its reasoning in great detail other than noting the absence of available authority on the issue. (Id. at p. 999.)

 

The Court finds Fenters to be helpful in resolving Plaintiff’s argument, however. Here, “the plaintiff can establish the elements of the tort of malicious prosecution.” (Hagberg, supra, 32 Cal.4th at p. 355.) That Plaintiff’s Bane Act claim is a separate theory of liability should not logically subject it to the litigation privilege when the underlying conduct alleged is conduct that, if merely labeled as a malicious prosecution claim, would unambiguously evade the effects of the litigation privilege.

 

The Court therefore finds that the litigation privilege does not apply to Plaintiff’s Bane Act claim.

 

Collateral Estoppel

 

Claim preclusion does not apply here. By Jeanette Bisno’s own admission, Plaintiff’s cross-complaint in the Underlying Civil Case only raised a Bane Act claim as to Jeanette Bisno’s conduct in the Parking Lot Incident. (Willoughby Decl., Ex. Z2 at p. 5:14-17.) Here, Plaintiff seeks recovery for the Bisno Parties’ actions that followed the initiation of the Underlying Criminal Case – i.e., the wrongful disclosure of Plaintiff’s personal information and subsequent use of that information to allegedly intimidate Plaintiff and file the Underlying Civil Case. This is a separate wrong.

 

Furthermore, Plaintiff’s present Bane Act claim is not a claim that should have been advanced in the Underlying Civil Case, because the alleged wrongful prosecution of the Underlying Civil Case is tied up in Plaintiff’s allegations of intimidation. Thus, Plaintiff sensibly waited for the end of the Underlying Civil Case to file this Bane Act claim.

 

Issue preclusion similarly does not apply here because factual issues in Plaintiff’s present Bane Act claim were not litigated or adjudicated in the Underlying Civil Case.

 

Statute of Limitations

 

“Because some of the provisions commonly treated by the courts as part of the Unruh Civil Rights Act derive from the common law and some do not, we conclude that no single statute of limitations applies to all. The one-year statute will apply to causes of action under provisions that evolved from the common law; the three-year statute will apply to others.” (Gatto v. County of Sonoma (2002) 98 Cal.App.4th 744, 759.)

 

Here, Plaintiff’s action does not arise out of a common law claim such as negligence or personal injury, but rather out of alleged threats to prevent her from testifying. Thus, it appears that a 3-year statute of limitations applies – at least, when considering the Bane Act claim on its own.

 

As discussed above, the protected portions of Plaintiff’s Bane Act claim arise out of the Bisno Parties’ alleged malicious prosecution of the Underlying Civil case. The protected conduct at issue is the Bisno Parties’ prosecution of the Underlying Civil Case, and Robert Bisno’s attendant alleged threats to Plaintiff.

 

“The nature of the cause of action and the primary right involved, not the form or label of the cause of action or the relief demanded, determine which statute of limitations applies.” (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 412.) Thus, the same statute of limitations analysis that applies to Plaintiff’s malicious prosecution claim applies to the protected conduct portions of Plaintiff’s Bane Act claim. The claim accrued upon favorable termination of the Underlying Civil Case. Plaintiff filed suit within one year. In any event, no party contends that the applicable statute of limitations is less than one year, and Plaintiff’s Bane Act claim is therefore timely.

 

            The Court therefore finds that Plaintiff has made an adequate showing of merit as to the statute of limitations issue to survive the second step of the anti-SLAPP analysis.

 

Factual Merit

 

As discussed above, the elements of a claim for violations of the Tom Bane Civil Rights Act are (1) the defendant interfered with or attempted to interfere with the plaintiff’s constitutional or statutory rights by threatening or committing violent acts; (2) the plaintiff reasonably believed that if he or she exercised his or her constitutional rights the defendant would commit violence against him or her or his or her property, or the defendant injured the plaintiff or his or her property to prevent him or her from exercising his or her constitutional rights or retaliated against the plaintiff for having exercised his or her constitutional rights; (3) the plaintiff was harmed; and (4) the defendant’s conduct was a substantial factor in causing the plaintiff’s harm. (Civ. Code, § 52.1; Austin B. v. Escondido Union School Dist., supra, 149 Cal.App.4th at p. 882.)

 

The protected conduct at issue is Robert and Jeanette Bisno’s prosecution of the Underlying Civil Case, and Robert Bisno’s attendant alleged threats to Plaintiff. Although the protected conduct does not appear to include threats of physical violence, the Court follows the persuasive precedent of the federal court in Fenters v. Yosemite Chevron, supra, 761 F.Supp.2d 957, 999, which denied summary judgment as to a Bane Act claim where malicious prosecution formed the underlying conduct at issue. Here, the Plaintiff has provided evidence that the Robert and Jeanette Bisno threatened to cause economic harm to Plaintiff, and maliciously prosecuted the Underlying Civil Case against her, in retaliation for her cooperation in the Underlying Criminal Case. Plaintiff has thus made a prima facie showing of merit sufficient for her Bane Act

 

            The Court therefore denies the anti-SLAPP motion against the Bane Act claim as to Robert Bisno and Jeanette Bisno.

 

Alter Ego

 

As discussed under Plaintiff’s malicious prosecution claim, the Court finds that Plaintiff has shown sufficient factual merit for her claims to go forward against the entity defendants under the theory of alter ego liability.

 

The Court therefore denies the anti-SLAPP motion as to the Bane Act claim against the Law Office, Bisno Management, Bisno Development, Bisno Real Estate, and Bisno Family.

 

Attorney Fee Request

 

Keller requests attorney’s fees.

 

“Except as provided in paragraph (2), in any action subject to subdivision (b), a prevailing defendant on a special motion to strike shall be entitled to recover that defendant's attorney's fees and costs. If the court finds that a special motion to strike is frivolous or is solely intended to cause unnecessary delay, the court shall award costs and reasonable attorney's fees to a plaintiff prevailing on the motion, pursuant to Section 128.5.” (Code Civ. Proc., § 425.16, subd. (c)(1).)

 

The Court finds that the anti-SLAPP motion was frivolous as to the malicious prosecution claim against Robert Bisno and Jeanette Bisno, but not as to the remaining defendants or as to the Bane Act claim.  The malicious prosecution issue was clear.  The Bane Act claim raised more complicated legal issues.

 

There was no reasonable basis to argue that Keller could not make a prima facie showing of her malicious prosecution claim against the two individual defendants. The Parking Lot Incident was recorded on video available to both Robert Bisno and Jeanette Bisno, and Jeanette Bisno admitted under oath that Keller never touched her. Further, the judge in the Underlying Criminal Matter’s comments as to the propriety of the Underlying Civil Case should have put Robert Bisno and Jeanette Bisno on notice that there were, at minimum, triable issues of fact that their actions constituted malicious prosecution.

 

The Court therefore determines that Keller may recover attorney’s fees against Defendants Robert Bisno and Jeanette Bisno associated with the portion of her opposition to the anti-SLAPP motion relating to the malicious prosecution. The Court needs time records from Keller’s counsel in a format that will allow the Court to allocate time between work on the malicious prosecution issue and work on the Bane Act issues. The Court will discuss with the parties at the hearing the procedure for submitting such records.

 

Demurrer

 

Legal Standard

 

As a general matter, in a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) “A demurrer tests the pleading alone, and not the evidence or facts alleged.” (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1315.) The court assumes the truth of the complaint’s properly pleaded or implied factual allegations. (Ibid.) The only issue a demurrer is concerned with is whether the complaint, as it stands, states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.)

 

Where a demurrer is sustained, leave to amend must be allowed where there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 348.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Ibid.; Lewis v. YouTube, LLC (2015) 244 Cal.App.4th 118, 226.) However, “[i]f there is any reasonable possibility that the plaintiff can state a good cause of action, it is error to sustain a demurrer without leave to amend.” (Youngman v. Nevada Irrigation Dist. (1969) 70 Cal.2d 240, 245).

 

Analysis

 

The Bisno Parties’ demurrer consists solely of the same res judicata arguments raised in the anti-SLAPP motion. For the reasons discussed under the anti-SLAPP motion, the Court does not find those arguments persuasive.

 

The Court overrules the demurrer.