Judge: Lee W. Tsao, Case: 22NWCV00688, Date: 2023-01-31 Tentative Ruling

Case Number: 22NWCV00688    Hearing Date: January 31, 2023    Dept: C

OPTIMA ENERGY, INC., et al. v. CHOI, et al.

CASE NO.:  22NWCV00688

HEARING 1/31/23 @ 1:30 PM

 

#6

TENTATIVE RULING

 

Defendant Christopher Choi’s demurrer to Plaintiffs’ complaint is SUSTAINED with 10 days leave to amend as to the 5th, 11th, and 17th causes of action, and otherwise OVERRULED as to the remaining causes of action.

 

Opposing Party to give NOTICE.

 

 

Defendant Christopher Choi demurs to the 1st – 19th causes of action on the grounds that they do not state facts sufficient to constitute a cause of action, and are uncertain.

 

[The Court notes that Defendant Christopher Choi has filed a 19-page Demurrer, in violation of CRC 3.1113(d), which limits a memorandum to 15 pages.  This court will overlook Defendant’s  transgression this once.  Any subsequent filings beyond the page limitations will not be considered.]

 

Plaintiffs Optima Energy, Inc. and Planet Optima, JV (collectively, “Optima”)’s Complaint alleges that Defendants used Plaintiffs’ good name and reputation in the industry to present sham project contracts to the County of Los Angeles with forged signatures of property owners and managers to receive county funding that would be used, instead, to line Defendants’ pockets.  (Complaint, ¶ 2.)  Defendants falsified proposals and misused Optima’s resources, including the Californian, Whispering Fountains, and Belcourt projects with no valid incentive, signature, or planned construction dates.  Based thereon, the Complaint asserts causes of action for:

 

1.        Forgery

2.        Fraudulent Misrepresentation

3.        Negligent Misrepresentation

4.        Intentional Misrepresentation

5.        Conversion

6.        Misappropriation

7.        Identity Theft (Ca. Civ. Code §§ 1798.92 – 1798.97)

8.        Breach of Employment Contract

9.        Breach of Implied Covenant of Good Faith and Fair Dealing

10.    Fraudulent Concealment

11.    Unjust Enrichment

12.    Negligence

13.    Negligent Supervision and Hiring

14.    Violation of B&P Code § 17200, et seq.

15.    Intentional Interference of Prospective Economic Advantage

16.    Negligent Interference of Prospective Economic Advantage

17.    Tortious Interference with Business Contracts

18.    Violation of California Uniform Trade Secrets Act

19.    Promissory Fraud

 

On January 19, 2023, Plaintiffs dismissed the 1st, 7th, and 13th causes of action.

 

UNCERTAINTY

 

“A demurrer for uncertainty is strictly construed, even where a complaint is in some respects uncertain, because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly's of California, Inc. (1993) 14 Cal.App.4th 612, 616.) A demurrer for uncertainty will be sustained only where the complaint is so bad that a defendant cannot reasonably respond. (Ibid.)

 

The court finds that the Complaint is not so uncertain that Defendant cannot reasonably respond.  The demurrer based on uncertainty is OVERRULED.

 

2nd, 3rd, 4th, 10th, and 19th CAUSES OF ACTION

 

FRAUDULENT/INTENTIONAL MISREPRESENTATION:  The elements are:  1) misrepresentation (false representation, concealment, or nondisclosure); 2) knowledge of falsity (scienter); 3) intent to defraud or induce reliance; 4) justifiable reliance; and 5) damages.  (See CC § 1709.)  Fraud actions are subject to strict requirements of particularity in pleading.  (Committee on Children’s Television, Inc. v. General Foods Corp. (1983) 35 Cal. 3d 197, 216.)  A plaintiff must allege what was said, by whom, in what manner (i.e. oral or in writing), when, and, in the case of a corporate defendant, under what authority to bind the corporation.  (See Goldrich v. Natural Y Surgical Specialties, Inc. (1994) 25 Cal.App.4th 772

 

The court finds that Choi’s misrepresentations are adequately pled at ¶¶ 29 42, 52-56, 61-67, 70, and 72.  ¶ 103 alleges scienter.  ¶ 108 alleges intent to induce reliance.  ¶¶ 110-111 allege Plaintiffs’ justifiable reliance, and ¶ 112 alleges resulting damages.  The court finds the fraud allegations are sufficiently particular.

 

NEGLIGENT MISREPRESENTATION:  The elements are: (1) the defendant made a false representation as to a past or existing material fact; (2) the defendant made the representation without reasonable ground for believing it to be true; (3) in making the representation, the defendant intended to deceive the plaintiff; (4) the plaintiff justifiably relied on the representation; and (5) the plaintiff suffered resulting damages.  (Majd v. Bank of Am, N.A. (2015) 243 Cal.App. 4th 1293, 1307 citing West v. JPMorgan Chase Bank, N.A. (2013) 214 Cal. App.4th 780, 792.)

 

¶ 114 incorporates the prior fraud allegations, and ¶ 118 alleges that Defendants had no reasonable grounds to believe that the misrepresentations were true.  The court finds the fraud allegations are sufficiently particular.

 

“[T]he elements of a cause of action for FRAUD BASED ON CONCEALMENT are: (1) the defendant must have concealed or suppressed a material fact, (2) the defendant must have been under a duty to disclose the fact to the plaintiff, (3) the defendant must have intentionally concealed or suppressed the fact with the intent to defraud the plaintiff, (4) the plaintiff must have been unaware of the fact
and would not have acted as he did if he had known of the concealed or suppressed fact, and (5) as a result of the concealment or suppression of the fact, the plaintiff must have sustained damage.”  (Kaldenbach v. Mutual of Omaha Life Ins. Co. (2009) 178 Cal. App. 4th 830, 850.)  “There are four
circumstances under which that duty arises: (1) when the defendant is in a fiduciary relationship with the plaintiff; (2) when the defendant had exclusive knowledge of material facts not known to the plaintiff; (3) when the defendant actively conceals a material fact from the plaintiff; and (4) when the defendant makes partial representations but also suppresses some material facts.” (Immobiliare, LLC v. Westcor Land Title Insurance Co., 424 F. Supp.3d 882, 888-89 (E.D. Cal. 2019) (internal quotations omitted).

 

¶ 181 incorporates the prior fraud allegations, which includes Choi’s concealment or suppressed material facts, and ¶¶ 182-183 additionally alleges that Defendant Choi was under a duty to disclose these facts.  ¶ 186 alleges that Plaintiffs were unaware of the concealed facts, and ¶¶ 188-190 alleges resulting damages. The court finds the fraud allegations are sufficiently particular.

 

PROMISSORY FRAUD:  The elements are:  1) specific factual circumstances beyond contract breach; and 2) inferring a contemporaneous intent not to perform.  (Hills Transportation Co. v. Southwest Forest Ind., Inc. (1968) 266 Cal.App.2d 702, 707; Tenzer v.  Superscope, Inc. (1985) 39 Cal.3d 18, 30;  Agosta v. Astor (2004) 120 Cal.App.4th 596, 603, 607; Cicone v.  URS Corp.  (1986) 183 Cal.App.3d 194, 206 - fraudulent intent may be alleged merely as a conclusion.)

 

¶ 266 incorporates the prior allegations.  ¶ 267 additionally alleges that Choi made misrepresentations about his numerous connections and pending projects, and ¶ 268 alleges that instead, Defendant’s intent was to steal Plaintiffs’ confidential information and reputation to competitively advantage his own businesses and affiliations.  The court finds the fraud allegations are sufficiently particular.

 

Demurrers to the 2nd, 3rd, 4th, 10th, and 19th causes of action are OVERRULED.

 

5th CAUSE OF ACTION

 

CONVERSION: The elements are:  1) Plaintiff's ownership or right to possession of personal property; 2) defendant's disposition of the property inconsistent with plaintiff's rights; and 3) resulting damages.  (Fremont Indemnity Co. v. Fremont General Corp. (2007) 148 Cal.App.4th 97, 119; PCO, Inc. v. Christensen, Miller, Fink, Jacobs, Glaser, Weil & Shapiro, LLP (2007) 150 Cal.App.4th 384, *5 - money cannot be the subject of a cause of action for conversion unless there is an identifiable sum.)

 

Although Plaintiffs allege that Defendants converted money, Plaintiffs fail to allege an identifiable sum.  Accordingly, the demurrer is SUSTAINED with 10 days leave to amend.

 

6th CAUSE OF ACTION

 

Common law MISAPPROPRIATION has three elements: “(1) a plaintiff must have invested substantial time and money in developing a property, (2) the defendant must have appropriated the property at little or no cost, and (3) the plaintiff was injured by the defendant’s conduct.”  (Lebas Fashion Imports of USA, Inc. v. ITT Hartford Ins. Group (1996) 50 Cal. App. 4th 548, 564.)

 

¶¶ 147-153 allege that Plaintiffs made a substantial investment of time and money in cultivating business relationship and techniques, Defendant appropriated Defendant’s business relationships and techniques for their own use and profits, and Plaintiffs have suffered resulting damages.

 

Accordingly, the demurrer is OVERRULED.

 

8th CAUSE OF ACTION

 

BREACH OF EMPLOYMENT CONTRACT:  The elements for a breach of contract cause of action are: (1) the contract; (2) plaintiff’s performance or excuse for nonperformance; (3) defendant’s breach; and (4) resulting damages.  (Reichert v. General Ins. Co. (1968) 68 Cal.2d 822, 830.)  In alleging a breach of contract cause of action, it is necessary to specify whether the contract is written, oral or implied by conduct.  (CCP § 430.10(g).)  To plead a written contract, a plaintiff must do one of the following: (1) set forth the contract in haec verba; or (2) plead the contract’s legal effect by alleging the substance of its relevant terms.  (4 Witkin, California Procedure 4th Ed., 479-481.)  In order to plead an oral contract, a plaintiff must plead its legal effect, i.e., allege the substance of the contractual terms.  (Id. at 483.)

 

¶ 163 allege that Plaintiffs and Defendant Choi entered into employment agreements.  ¶ 165 alleges the terms of the agreement.  ¶ 166 alleges Plaintiffs’ performance, ¶¶ 167-170 allege Defendant’s breach, and ¶ 171 and 175 allege Plaintiffs’ resulting damage.

 

Demurrer is OVERRULED.

 

9th CAUSE OF ACTION

 

BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING:  The elements are:  1) existence of contractual relationship; 2) implied duty; 3) breach; and 4) causation of damages.  (E.g., Smith v. San Francisco (1990) 225 Cal.App.3d 38, 49; 1 Witkin Sum. Cal. Law (10th ed. 2005) Contracts § 800.)

Choi contends the underlying contract is defective, and therefore, the bad faith cause of action is defective for the same reasons.  However, as discussed above, the court finds the contract cause of action is adequately pled.

 

Accordingly, the demurrer is OVERRULED.

 

11th CAUSE OF ACTION

 

UNJUST ENRICHMENT:  Under the law of restitution, an individual may be required to make restitution if he is unjustly enriched at the expense of another. A person is enriched if he receives a benefit at another's expense. (Ghirardo v. Antonioli (1996) 14 Cal.4th 39, 51.)

 

There is a split of authority across the appellate courts regarding whether unjust enrichment is a cause of action or a principle of law.  (Jogani v. Superior Court (2008) 165 Cal.App.4th 901, 911 and Melchior v. New Line Prods., Inc. (2003) 106 Cal.App.4th 779, 794 hold that unjust enrichment is a principle underlying various doctrines and remedies, including quasi-contract. On the other hand, Hirsch v. Bank of America (2003) 107 Cal.App.4th 708, First Nationwide Savings v. Perry (1992) 11 Cal.App.4th 1657, and Lectrodryer v. Seoul Bank (2000) 77 Cal.App.4th 723 view it as a separate cause of action.)

 

This court follows the Jogani line of cases and finds that Unjust Enrichment is not a cause of action.  However, Plaintiffs may still allege it as a theory supporting the remedy of rescission.  A complaint may state multiple legal theories upon which recovery might be predicated for one claim for relief.  (Newhall Land & Farming Co. v. Superior Court (1993) 19 Cal.App. 4th 334, 351.)

 

Accordingly, demurrer is SUSTAINED with 10 days leave to amend.  Plaintiffs are ORDERED to strike the title, “Eleventh cause of action  Unjust Enrichment and ¶ 191” (Complaint, 30:3-7), but the allegations at ¶¶ 192-199 may remain. 

 

12th CAUSE OF ACTION

 

NEGLIGENCE:  The elements are:  1) Legal duty owed to plaintiffs to use due care; 2) breach of duty; 3) causation; and 4) damage to plaintiff.  (Ladd v. County of San Mateo (1996) 12 Cal.4th 913, 917.)

 

Defendant Choi contends he owes no duty to Plaintiffs.  However, ¶ 202 adequately alleges Defendant’s duty.  ¶ 203 alleges breach, ¶ 204 alleges causation, and ¶ 205 alleges resulting damages.

 

Demurer is OVERRULED. 

 

14th CAUSE OF ACTION

 

VIOLATION OF B&P CODE § 17200, ET SEQ.: The Unfair Business Practices Act shall include “any unlawful, unfair or fraudulent business act or practice.” (B&P Code § 17200.)  A plaintiff alleging unfair business practices under these statutes must state with reasonable particularity the facts supporting the statutory elements of the violation.  (Khoury v. Maly's of California, Inc. (1993) 14 Cal.App.4th 612, 619.)  Even a single incident - a one-time act that is unfair, unlawful or fraudulent - is sufficient to state a claim under 17200.  (Klein v. Earth Elements, Inc. (1997) 59 Cal.App.4th 965, 969 fn. 3.) 

 

The court finds the Fraud and unfair business practices prongs are adequately pled.  Demurrer is OVERRULED.

 

15th CAUSE OF ACTION

 

INTENTIONAL INTERFERENCE OF PROSPECTIVE ECONOMIC ADVANTAGE:  To prevail on a cause of action for intentional interference with prospective economic advantage in California, a plaintiff must plead and prove (1) an economic relationship between the plaintiff and some third party, with the probability of future economic benefit to the plaintiff; (2) the defendant's knowledge of the relationship; (3) the defendant's intentional acts designed to disrupt the relationship; (4) actual disruption of the relationship; and (5) economic harm to the plaintiff proximately caused by the defendant's acts. (Reeves v. Hanlon (2004) 33 Cal.4th 1140, 1152 n. 6.)  A plaintiff that chooses to bring a claim for interference with prospective economic advantage has a more rigorous pleading burden since it must show that the defendant's conduct was independently wrongful other than the fact of interference itself.  (Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134; Della Penna v. Toyota Motor Sales, U.S.A., Inc. (1995) 11 Cal.4th 376, 393.) 

 

¶ 227 alleges Plaintiffs’ prospective business relationships with third parties, ¶ 228 alleges Defendant’s knowledge of those relationships, ¶ 229 alleges Defendant’s intentional interference, ¶ 231 alleges actual disruption, and ¶ 232 alleges resulting harm.  The Fraud allegations sufficiently allege Defendant’s independently wrongful acts.

 

Demurrer is OVERRULED.

 

16th CAUSE OF ACTION

 

NEGLIGENT INTERFERENCE WITH PROSPECTIVE ECONOMIC RELATIONS:  The elements are:  an economic relationship between the plaintiff and a third party; that contained a reasonably probable future economic benefit or advantage to plaintiff; defendant knew of the existence of the relationship and was aware, or should have been, that if it did not act with due care, its actions would interfere with the relationship and cause plaintiff to lose in whole or in part the probable future economic benefit or advantage; the defendant was negligent; the negligence caused damage to plaintiff because of actual interference or disruption; and plaintiff lost in whole or in part the economic benefits or advantage reasonably expected from the relationship.  (North Amer. Chem. Co. v. Sup. Ct.  (1997) 59 Cal. App. 4th 764, 786.)  Both intentional and negligent varieties of interference with prospective economic relations require the plaintiff to plead facts showing that the defendant engaged “wrongful conduct” that falls outside the bounds of fair competition. (Della Penna v. Toyota Motor Sales, U.S.A., Inc. (1995) 11 Cal.4th 376, 393.)

 

¶ 236 alleges Plaintiffs’ prospective business relationships with third parties, ¶ 237 alleges Defendant’s knowledge of those relationships, ¶ 238 alleges Defendant’s intentional interference, ¶ 240 alleges actual disruption, and ¶ 244 alleges resulting harm.  The Fraud allegations sufficiently allege Defendant’s independently wrongful acts.

 

Demurrer is OVERRULED.

 

17th CAUSE OF ACTION

 

TORTIOUS INTERFERENCE WITH BUSINESS CONTRACTS:  The elements are:  1) valid contract between plaintiff and third party; 2) defendant's knowledge of that; 3) defendant's intentional acts designed to induce disruption of the relationship; 4) actual disruption; and 5) resulting damage.  (Reeves v. Hanlon (2004) 33 Cal. 4th 1140, 1148; Scripps Clinic v. Superior Court (2003) 108 Cal. App. 4th 917, 929.)

 

The court finds the Complaint fails to allege valid contracts between Plaintiffs and third parties.  Instead, Plaintiffs allege at ¶ 247 that they “had an opportunity for valid contracts.”  Such is insufficient to support a claim for interference with contract. 

 

Accordingly, the demurrer is SUSTAINED with 10 days leave to amend.

 

18th CAUSE OF ACTION

 

VIOLATION OF CALIFORNIA UNIFORM TRADE SECRETS ACT:  Essential elements of a trade secret misappropriation cause of action are:  1) the existence of a trade secret; and 2) misappropriation of that trade secret.  (CC § 3426.1.)  The California Uniform Trade Secrets Act (“CUTSA”) defines a “trade secret” as “information, including a formula, pattern, compilation, program, device, method, technique, or process,” that “[d]erives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use” and [i]s the subject of efforts that are reasonable under the circumstances to maintain its secrecy.”  (CC § 3426.1(d)(1), (2).)

 

CUTSA “does not displace a contract claim ... and does not displace noncontract claims that, although related to a trade secret misappropriation, are independent and based on facts distinct from the facts that support the misappropriation claim.”  (Angelica Textile Services, Inc. v. Park (2014) 220 Cal.App.4th 495, 506 - reversing summary judgment where trial court improperly invoked UTSA preemption to grant summary judgment on the plaintiff’s conversion claims, unfair competition claims and breach of fiduciary claims.  See also, Integral Dev. Corp. v. Tolat (9th Cir. 2017) 675 F. App’x 700, 704 - “The plain language of CUTSA also provides that it does not preempt “contractual remedies, whether or not based upon misappropriation of a trade secret.”)

 

Further, CUTSA “does not affect ... civil remedies that are not based upon misappropriation of a trade secret.”  (CC § 3426.7(b).)  If a breach of fiduciary duty is not “based on the same nucleus of facts as [the] trade secret misappropriation,” CUTSA will not preempt the claim.  (See K.C. Multimedia, Inc. v. Bank of Am. Tech. & Operations, Inc. (2009) 171 Cal.App.4th 939); Integral Dev. Corp. v. Tolat (9th Cir. 2017), 675 F. App’x 700, 704.)

 

At this juncture, the court finds that the complaint adequately alleges independent common law causes of action that are not based on the same nucleus of facts as the trade secret misappropriation claim.  Accordingly, the demurrer is OVERRULED.