Judge: Lee W. Tsao, Case: 22NWCV00027, Date: 2023-09-28 Tentative Ruling



Case Number: 22NWCV00027    Hearing Date: October 31, 2023    Dept: C

Francisco L. Quintero, et al. vs Victor M. Jimenez, et al.

CASE NO.: 22NWCV00027

HEARING:  10/31/23 

 

#6 TENTATIVE ORDER 

 

Cross-Defendant’s/Plaintiff’s motion to dismiss the Cross-Complaint is GRANTED. 

The Court GRANTS sanctions in the reduced total amount of $6,776.65.

 

Moving parties are ordered to give notice.

 

Background

This action for partition was filed by Plaintiffs/Cross-Defendants Francisco L. Quintero and Hilda M. Quintero (collectively “Cross-Defendants”) on January 13, 2022.

On March 1, 2022, Defendants/Cross-Complainants Victor M. Jimenez and Julieta M. Romero (collectively “Cross-Complainants”) filed a Cross-Complaint seeking quiet title, declaratory relief, intentional misrepresentation, unjust enrichment, promissory estoppel, and accounting.

On March 15, 2023, Cross-Defendants, deposed Julieta Romero and Victor Jimenez. The testimony of Victor Jimenez brought discrepancies in comparison to allegations made under penalty of perjury in the verified cross-complaint. When deposing Romero, Plaintiffs also discovered numerous discrepancies that do not coincide with the cross complaint.

On August 30, 2023, counsel for Cross-Defendants met and conferred with Cross-Complainants’ counsel to discuss dismissing the causes of action in the cross-complaint. (Rokita Decl., ¶ 4.) Parties did not agree.

On September 26, 2023, Cross-Defendants brought the instant motion to dismiss under CCP § 128.7.

On September 29, 2023, Cross-Defendants brought an ex parte application to continue trial, which was granted on October 2, 2023.

Trial is currently set for November 13, 2023.

 

Legal Standards

An attorney filing a pleading must make “an inquiry reasonable under the circumstances” to ensure that its “claims, defenses, and other legal contentions therein are warranted” and that “allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery.” (CCP § 128.7(b)(2)-(3).) Moreover, “to satisfy [the] obligation under [section 128.7] to conduct a reasonable inquiry to determine if his [or her] client’s claim was well-grounded in fact, the attorney must take into account [the adverse party’s] evidence.” (Bucur v. Ahmad, (2016) 244 Cal. App. 4th 175, 190.)

The Supreme Court of California has articulated that California Code of Civil Procedure Section 128.7 “provides a remedy for improperly speculative pleading.” Bockrath v. Aldrich Chem. Co., 21 Cal.4th 71, 82 (1999) (“Bockrath”). That provision “enables courts to deter or punish frivolous filings which disrupt matters, waste time, and burden courts’ and parties’ resources.” (In re Mark B., (2007) 149 Cal. App. 4th 61, 76.) Section 128.7 also permits a California Court to “impose sanctions for filing a pleading if the court concludes the pleading . . . was indisputably without merit, either legally or factually” or, in other words, “legally and factually frivolous.” (Peake v. Underwood, 227 Cal. App. 4th 428, 439.) The Fourth District Court of Appeal has further elucidated the concept of frivolity as follows:

A claim is factually frivolous if it is not well grounded in fact and it is legally frivolous if it is not warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law. In either case, to obtain sanctions, the moving party must show the party’s conduct in asserting the claim was objectively unreasonable. A claim is objectively unreasonable if any reasonable attorney would agree that [it] is totally and completely without merit.

(Id. (internal citations and quotation marks omitted); McCluskey v. Henry, (2020) 56 Cal. App. 5th 1197, 1206.) “When establishing a claim is factually or legally without merit under Code of Civil Procedure section 128.7, it is not necessary to show the party acted with an improper motive or subjective bad faith.” (Peake, 227 Cal. App. 4th at 449.)

Under CCP § 128.7(c)(1), “a motion for sanctions “shall be made separately from other motions or requests and shall describe the specific conduct alleged to violate subdivision.”

Discussion

i.             Cross-Defendants’ Arguments

In their motion, Cross-Defendants request that this Court impose the sanctions of dismissal and attorneys’ fees, because counsel for Cross-Complainants acted “objectively unreasonabl[y]” by not conducting an inquiry reasonable under the circumstances that would have “easily and incontestably” demonstrated that Victor Jimenez was unaware that a Cross-Complaint was filed on his behalf.

          Cross-Defendant argues that when deposed Defendant/Cross-Complainant Victor Jimenez brought significant discrepancies in comparison to allegations made under penalty of perjury in the verified cross complaint. During his deposition, Cross-Complainant Jimenez stated that he did not have a currently pending cross-complaint against the Plaintiffs, no one had the authority to sign documents on his behalf, that he did not recognize the signature attributed to him on the Cross-Complaint, his daughter would not have signed it on his behalf, and the reason Cross-Defendants are listed on the deed is due to him asking them to sign it. (Jimenez Depo 80:15-24; 112:2-24; 112:13-24; 111:25 – 112:1-11).

The Cross-Complaint shows that it was verified via Jimenez’s signature, signed under Penalty of Perjury. An attorney has an obligation under CCP § 128.7(b) to conduct a reasonable inquiry to determine if his client’s claim was well-grounded in fact. However, according to the testimony of Jimenez, he was unaware as to why he was deposed (Jimenez Depo 14:1-3), unaware that a Cross-Complaint was filed (Jimenez Depo 112:2-24), denied that a mortgage was ever taken out on the property (Jimenez Depo 103:4-5), and denied that he ever asked the Cross-Defendant’s to co-sign (Jimenez Depo 103:10-11). At Jimenez’s deposition, he stated that he was unaware as to why he was required to attend the deposition (Jimenez Depo 14:1-4).

Under CCP § 128.7(b)(3), an attorney is required to ensure that the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery. Upon initial review of the cross-complaint, it appears that the document was filed with the permission of cross-complainant since a verification was included. However, when asked if he recognized the verification at his deposition, Jimenez denied signing the document and was unaware of a lawsuit filed on his behalf.

As to Cross-Compliant Romero, in her deposition she stated that the only reason she was suing the Cross-Defendant’s is because they sued her first. When asked again, she claimed that she was only doing it to support her father.  (Romero Depo 49:7-23). However, her father was unaware that a cross-complaint was ever filed. Romero also alleged that she does not have an issue with the Cross-Defendants being named on the title. (Romero Depo 49:25 – 50:1-7). Cross-Defendants argue that Romero’s allegations clearly state that the suit was filed for an improper purpose, which was merely because the Cross-Defendants filed first.

ii. Cross-Complainants’ Opposition

In Opposition, Cross-Complainants argue that under CCP § 128.7 motion “shall be made separately from other motions or requests … .” (California Code of Civil Procedure §128.7(c)(1).) They argue that in the instant case, Counsel for Cross-Defendants is seeking sanctions in the amount of $34,600.20 and dismissal of the Cross-Complaint, which they contend is not allowable under 128.7.

Cross-Complainants also argue that the motion is untimely, as it was filed only thirty-five days prior to the now continued trial date and was thus unnecessary given that the issues could have been resolved at trial.

Cross-Complainants also argue that of the $34,600.20 Cross-Defendants are seeking to have Cross-Complainants pay, $32,124.43 is the amount Cross-Defendants, as Plaintiffs, incurred on matters having nothing to do with the Cross-Complaint. (Declaration of Robert P. Sievers ¶¶ 6-7.)

Cross-Complainants also argue that that when the Cross-Compliant was filed, it was done so in good faith and that Plaintiff Jimenez’s cognitive decline makes his deposition unjust. (Opp. at p. 3.)  Cross-Complainants attached a doctor’s report outlining the cognitive decline. (Declaration of Robert P. Sievers, Ex. 8, Report of Dr. Thomas Parisi p. 8.)

Iii. Cross-Defendants’ Reply

In Reply, Cross-Defendants offer that Section 128.7 “provides a remedy for improperly speculative pleading.” (Bockrath v. Aldrich Chem. Co., (1999) 21 Cal.4th 71, 82.) Section 128.7 provision “enables courts to deter or punish frivolous filings which disrupt matters, waste time, and burden courts’ and parties’ resources.” (In re Mark B., (2007) 149 Cal. App. 4th 61, 76.)

In regard to Jimenez’s cognitive decline, Cross-Defendants’ point to Romero’s testimony, who has now been named Jimenez’s Guardian ad Litem, that also suggests the motion was filed for frivolous reasons as her breach date would be barred by a statute of limitations and was only done to help support her father. (Reply, p. 4.)

Analysis

i.             The Capacity of Mr. Jimenez

The Court must first address the cognitive ability of Cross-Complainant Jimenez.  In their Opposition, the Cross-Complainants explain that a psychiatrist has determined that,

“Mr. Jimenez does not have the capacity to engage in a rational and meaningful discussion about a real estate legal matter in which he is involved. He is unable to consistently recall that he is facing a lawsuit, is unable to grasp and manipulate the information relative to the lawsuit, and is unable to appreciate the potential outcomes and thereby the possible consequences of the lawsuit.”

(Sievers Decl., Exhibit B, Report of Dr. Thomas Parisi, p. 8.)

In Reply, the Cross-Defendants do not debate the cognitive decline of Cross-Complainant Jimenez, however, Cross-Defendants argue that Cross-Complainants counsel was responsible for notifying them at the earlier of the cognitive decline.  Cross-Defendants evidence that in a declaration filed on September 29, 2023, for the ex parte motion to continue trial, Counsel noted that he had witnessed the cognitive decline of his client.  However, prior to the declaration, from March 2023-September 2023, Counsel had submitted responses to Form Interrogatories, Requests for Production, Special Interrogatories, and Requests for Admissions. Counsel also allowed his client to be deposed, and then again provided request for admissions (set two).  It was not until October 2, 2023, that Counsel notified Cross-Defendants of the dementia diagnosis. After notifying Cross-Defendants of the diagnosis, Counsel still noticed that he would be providing further responses to discovery. Counsel further did not provide a medical report outlining the diagnosis until October 6, 2023.

          The Court notes that deposition of Cross-Complainant Jimenez occurred in March 2023, statements made at the deposition that Jimenez did not remember signing the pleadings should have put Counsel on notice of the cognitive decline of his client.  However, Counsel provided responses to the requests for admissions (Set Two) on September 4, 2023.  He did not notify opposing counsel of the dementia diagnosis until October 4, 2023. 

A person over the age of 18 is presumed to have capacity. (Cal. Probate Code § 810(a).) The October doctor’s report does not provide evidence that Jimenez lacked capacity to answer questions during the March deposition. Since, there is no evidence that Jimenez lacked capacity and counsel for the Cross-Defendants were not made aware of a dementia diagnosis until nearly seven months after the deposition, the Court finds that Jimenez had capacity at the March 2023 deposition and thus will consider the statements made therein.

ii.            Whether the filings were “frivolous” under CCP § 128.7

“The purpose of section 128.7 is to deter frivolous filings.” (In re Marriage of Falcone & Fyke, (2008) 164 Cal. App. 4th 814, 826.) “[E]ven though an action may not be frivolous when it is filed, it may become so if later acquired evidence refutes the findings of a prefiling investigation and the attorney continues to file papers supporting the client’s claims. Thus, a plaintiff’s attorney cannot ‘just cling tenaciously to the investigation he had done at the outset of the litigation and bury his head in the sand.’” (Bucur, 244 Cal. App. 4th at 190, quoting Childs v. State Farm Mut. Auto. Ins. Co., (1994) 29 F.3d 1018, 1025.)

During his deposition, Cross-Complainant Jimenez stated that he did not have a currently pending cross-complaint against the Plaintiffs, no one had the authority to sign documents on his behalf, that he did not recognize the signature attributed to him on the Cross-Complaint, his daughter would not have signed it on his behalf, and the reason Cross-Defendants are listed on the deed is due to him asking them to sign it. (Jimenez Depo 80:15-24; 112:2-24; 112:13-24; 111:25 – 112:1-11).

As to Cross-Complainant Romero, in her deposition she stated that the only reason she was suing the Cross-Defendants is because they sued her first and to support her father (Romero Depo 49:7-23). Romero also commented that she did not have an issue with the Cross-Defendants being named on the title. (Romero Depo 49:25 – 50:1-7).

By the admissions of the Cross-Complainant’s Jimenez and Romero, they either did not know of the existence of the cross-complaint or did so because they were sued first. 

While counsel for the Cross-Complainants argue that when the cross-complaint was filed it was done so in good faith, this argument falls flat as after the March 2023 depositions of Jimenez and Romero as Council continued to file papers supporting the client’s claims and did not drop suit after the revelations.

Also, the Court notes, Counsel did not make an effort to discuss the cognitive decline of Jimenez at this time. Therefore, he seemingly maintained a cross-complaint his client claimed to have no idea about.  Further, Romero discussed only filing the crossclaim to help her father and because they had been sued prior. These statements made during the depositions should have given notice to Cross-Complainants’ counsel that the claims, as currently constituted, lack merit.  

iii.           Sanctions under CCP § 128.7

In California, a Court finding a violation of Section 128.7(b) may award sanctions, including dismissal and attorneys’ fees, from counsel. (CCP § 128.7(c)-(d); Peake v. Underwood, (2014) 227 Cal. App. 4th 428, 432-33, 448-50 (affirming lower Court’s sanctions of dismissal and attorneys’ fees pursuant to Section 128.7); Averill v. Superior Court, (1996) 42 Cal. App. 4th 1170, 1176 n.2 (“We note that under these circumstances section 128.7 might provide an alternative basis for dismissing this suit.”).)

In Opposition, Cross-Complainants argue that under CCP § 128.7 motion “shall be made separately from other motions or requests … .” (California Code of Civil Procedure §128.7(c)(1).) Counsel argues that the request for dismissal of the cross-complaint and request for monetary sanctions should be separated. However, the sanctions requests include the dismissal and the attorneys’ fees, which is allowable under California law. 

iv.           Timeliness of the Motion

Cross-Complainants believe that there is no purpose the filing of the instance 128.7 motion, other than the reallocation of attorneys’ fees and costs from Cross-Defendants to Cross Complainants, because trial was set for only thirty-five days after the initial filing of this motion.

Motions must be served on the parties and filed with the court sixteen days prior to the hearing. (CCP § 1005.)  This requirement was met.  Further, Cross-Defendants filed an ex parte application for a trial continuance to allow for a trial continuance to hear plaintiff’s motion to dismiss, which was granted on October 2, 2023. (See 10-02-2023 Minute Order.) 

Cross-Complainants further allege that due to litigation of the cross-complaint it cannot be held that the filing was frivolous.  However, Section 128.7 does not only address the filing of frivolous claims, but also from maintaining lawsuits deem frivolous, improper, or filed for an improper purpose.  Counsel met and conferred on August 30, 2023, during this meet and confer Counsel for Cross-Defendants discussed issues facing the cross-complaint.  (Rokita, ¶ 4.)  The parties could not agree on whether the Cross-Compliant causes of action should be dismissed, therefore the Cross-Defendants brought the matter before the Court, as is their right.

The Court therefore holds that the motion was timely.

v.            Third Cause of Action for Intentional Misrepresentation

CA Civ Code § 1710 defines intentional misrepresentation as: 1. The suggestion, as a fact, of that which is not true, by one who does not believe it to be true; 2. The assertion, as a fact, of that which is not true, by one who has no reasonable ground for believing it to be true; 3. The suppression of a fact, by one who is bound to disclose it, or who gives information of other facts which are likely to mislead for want of communication of that fact; or, 4. A promise, made without any intention of performing it.

The Cross-Complaint alleges that: (1) Cross-Defendants initially co-signed on the mortgage of the Subject Property to enable Cross-Complainants to purchase the Property since they were unable qualify on their own (Cross Complaint ¶ 15); (2) Cross-Defendants agreed to remain on title temporarily and orally represented that they would transfer title to Cross-Complainants after the mortgage was paid off or refinanced (Cross Complaint ¶ 54); (3) Cross-Defendants made the representations in or around October 1985 and knew that those representations were false (Cross Complaint ¶ 55); and (4) In or around January 2022, Francisco and Hilda breached the parties’ agreement by refusing to transfer title to the Property to Cross-Complainants and by attempting to partition the Property by sale for which they barely contributed any money as they only paid a fraction of the mortgage during the 6 years they resided at the Property. (Cross Complaint ¶ 77).

During his deposition, Cross-Complainant Jimenez stated that he did not have a currently pending cross-complaint against the Plaintiffs, no one had the authority to sign documents on his behalf, that he did not recognize the signature attributed to him on the Cross-Complaint, his daughter would not have signed it on his behalf, and the reason Cross-Defendants are listed on the deed is due to him asking them to sign it. (Jimenez Depo 80:15-24; 112:2-24; 112:13-24; 111:25 – 112:1-11).

 

During the Jimenez deposition, he testified that he never took a mortgage out on the property in his life and never asked the Cross-Defendants to co-sign on the property so that he could qualify for a mortgage (Jimenz Depo 103:4-7 and 103:8-11).  According to Jimenez, the Cross-Defendants never co-signed on the property or agreed to temporarily remain on title, the “false representations” alleged in Paragraph 55 of the Cross-Complaint never occurred nor could Jimenez have relied on these material representations if the conversation never happened. (Cross Complaint ¶ 57). It follows therefore, that Jimenez did not rely on the representations to his detriment. (Cross Complaint ¶ 58.)

Therefore, the third cause of action for intentional misrepresentation is dismissed.

vi.           Fourth Cause of Action for Unjust Enrichment

“One person should not be permitted to unjustly enrich himself at the expense of another, but should be required to make restitution of or for property or benefits received, retained, or appropriated, where it is just and equitable that such restitution is made”. (Melchior v. New Line Productions, Inc. (2003) 106 Cal.App.4th 779,793.) Under California law, for unjust enrichment matters, the Legislature has provided a two-year statute of limitations period covering contracts not founded upon an instrument of writing. (Code of Civil Procedure § 339(1).) Where the ground for rescission is fraud or mistake, the time does not begin to run until the discovery by the aggrieved party of the facts constituting the fraud or mistake. (Code of Civil Procedure § 339(3).)

Here, in her deposition, Romero states that she requested the transfer of the property in 2016. (Romero Depo 59:2-8.) In 2015, the Cross-Complaint alleges that Cross-Complainants became 100% owners of the property. (Cross-Complaint ¶¶ 25-27.) The Cross-Complaint alleges that the transfer of the property was to happen after the property was paid in full. (Cross-Complaint ¶¶ 29, 66.) It follows that the statute of limitations began to run then as she was made aware of the alleged benefit provided to Cross-Defendants. From the face of the Complaint, it seems that Cross-Complainants were aware of the alleged deal and knew they paid off the home in 2015.  Further, Romero states she requested the transfer in 2016.  Given these facts, the two-year statute of limitations began to run in 2016, at the latest.  This action was filed in 2022, six years after the statute of limitations began to run.  Therefore, this claim is barred by the statute of limitations.

Cross-Complainants’ fourth cause of action for unjust enrichment is dismissed.

vii.         The fifth cause of action for promissory estoppel

The elements of a promissory estoppel claim are “(1) a promise clear and unambiguous in its terms; (2) reliance by the party to whom the promise is made; (3) [the] reliance must be both reasonable and foreseeable; and (4) the party asserting the estoppel must be injured by his reliance.” (US Ecology, Inc. v. State of California (2005) 129 Cal.App.4th 887, 901.) Generally, the limitations period is four years for written contracts (Cal. Civ. Proc. Code, §337, subd. (a)), and two years for oral agreements. (Cal. Civ. Proc. Code, §339, subd. (1)). A contract cause of action does not accrue until the contract has been breached. (Spear v. Cal. State Automobile Assn. (1992) 2 Cal.4th 1035, 1042.)

The mortgage was paid off in 2015 and the Cross-Complainants were aware that they had paid off the mortgage. There is no indication that a delay in discovering the breach was caused by the Cross-Defendants after the 2016 request, such as a promise to transfer by a certain date. For the reasons noted above, this cause of action fails due to the statute of limitations running. In this instance, four years have lapsed. Therefore, this claim is barred by the statute of limitations.

Cross-Complainants’ fifth cause of action for promissory estoppel is dismissed.

viii.        The sixth cause of action for accounting

For an accounting claim to be available, a litigant must prove two elements: (1) a relationship that requires accounting exists between the plaintiff and the defendant, and (2) that some balance is owed to the plaintiff, which can only be ascertained with an accounting. (Teselle v. McLoughlin (2009) 173 Cal.App.4th 156, 179.) Therefore, when a plaintiff is alleging a right to recover a sum of damages that is certain or can be made certain by calculation, an action for accounting is not available. (Id.) There is no specific limitations period for an action for an accounting. Consequently, the four-year limitations period in the catch-all provision of Code of Civil Procedure section 343 applies.

Taking the dates most favorable to Cross-Complainants, for the reasons noted above, the accounting cause of action still fails, since the statute of limitations would have expired before the cross-complaint was filed.

Cross-Complainants’ sixth cause of action for accounting is dismissed.

ix.           The first cause of action for Quiet Title

Now having the facts before us, the Court will consider the first cause of action for Quiet Title. In Salazar v. Thomas, (2015) 236 Cal.App.4th467, 477, ruled that the likely statute of limitations applicable to various underlying causes of actions were as follows: 3 years for claims based on fraud or mistake; 4 years for claims based on the cancellation of an instrument; and 5 years for claims based on adverse possession.

The Court notes, Romero alleges that she had no issue with the Cross-Defendants being on title. (Romero Depo 49:24-25 – 50:1-3). Jimenez alleged in his deposition that he never discussed having the Cross-Defendants on title, in conflict with paragraph 36 of the cross-complaint. (Jimenez Depo 103:6-11).

Further, the statute of limitations has lapsed. The cross-complaint does not contain a claim for cancellation of a written instrument or adverse possession. The most appropriate claim made by Cross-Complainants would fall into the three-year statute of limitations based on fraud or mistake since Cross-Complainants alleged that they were defrauded by the Cross-Defendants.  Thus, the three-year statute of limitations has run and this claim is barred,

Cross-Complainants’ first cause of action for quiet title is dismissed.

x.            The second cause of action for declaratory relief

Declaratory relief is traditionally used for statutory and contract interpretation. (Von Durjais v. Bd. of Trustees, (1978) 83 Cal. App. 3d 687.) Declaratory relief is also “an appropriate method for obtaining a declaration that a statute or regulation is facially unconstitutional.” (Tejon Real Estate, LLC v. City of Los Angeles, (2014) 223 Cal. App. 4th 149, 154.) Declaratory relief has two elements a party must satisfy: “(1) a proper subject of declaratory relief, and (2) an actual controversy involving justiciable questions relating to [the party’s] rights or obligations.” (Jolley v. Chase Home Finance, LLC, (2013) 213 Cal. App. 4th 872, 909.)

Declaratory relief is not proper under the circumstances here under CCP § 1061 because all of the causes of action brought herein are barred by the statute of limitations.

Cross-Complainants’ second cause of action for declaratory relief is dismissed.

xi.           Monetary Sanctions

Having addressed the sanctions, the Court now turns to the amount in damages. 

Cross-Defendants request $34,600.20 in damages.  Counsel represents that the damages are calculated as 61.6 Hours spent working on the matter, 4 hours opposing the motion, and appearing at the hearing at a rate of $395 per hour, calculated at $25,912.00.  34.7 hours of the paralegal’s work on this matter, 1.6 hours finalizing/serving the opposition at a rate of $85.00 per hour for a total of $3,085.50.  Further, Counsel requests costs totaling $5,539.58, $13.12 in filing fees, and $50 in courtesy copies on expense for a total amount of $5,602.70. 

Cross-Complainant’s Counsel states that of the $34,600.20 Cross-Defendants are seeking to have Cross-Complainants pay, $32,124.43 is the amount incurred on matters having nothing to do with the Cross-Complaint.

California Code of Civil Procedure §128.7 is designed to be remedial not punitive. (Ly v. Majestic Industry Hills LLC (2009) 177 Cal.App.4th 585, 591.) Here, Cross-Defendants note that when the Cross-Complaint was filed it may not have been frivolous and that later-acquired evident refuting the finding of a pre-filing investigation may have determined that the action should not have been continued.  Therefore, time spent litigating the action prior to that determination will not be included in the award of sanctions.

In addition, appellate courts in California have held that an award of attorney fees that did not compensate for paralegal service time would not fully compensate the attorney. (Guinn v. Dotson (1994) 23 Cal.App.4th 262.) They further examined the legislative intent of attorney fee statutes and found considerable case history to support the concept that the generic term Attorney fees was intended to encompass paralegal fees, where the prevailing practice is to separately bill a client for paralegal service time. (Id.)

Utilizing a lodestar approach, the Court finds that sanctions should be reduced to only work connected with the instant motion after the determination that the claims were meritless.  The Court awards sanctions for the reasonable amount of $6,715.00 (calculated as 17 hours including the time spent opposing the instant motion and appearing at the hearing at a rate of $395 per hour and 2.6 hours at a rate of $85.) Plus, reimbursement of the filing fee of $61.65, for a reduced total amount of $6,776.65.

 

Conclusion

 

Cross-Complainants’ first cause of action for quiet title, second cause of action for declaratory relief. third cause of action for intentional misrepresentation, fourth cause of action for unjust enrichment, fifth cause of action for promissory estoppel, and sixth cause of action for accounting are dismissed.

 The Court GRANTS sanctions in the reduced total amount of $6,776.65.

 

Moving parties are ordered to give notice.