Judge: Malcolm Mackey, Case: 22STCV29915, Date: 2023-04-04 Tentative Ruling

Case Number: 22STCV29915    Hearing Date: April 4, 2023    Dept: 55

BRADLEY LAW v. EVENTUS HOLDINGS, LLC,                                 22STCV29915

Hearing Date:  4/4/23,  Dept. 55.

#7:   

MOTION TO COMPEL ARBITRATION.

MOTION TO STAY AND TO COMPEL ARBITRATION.

 

Notice:  Okay

Opposition

 

MP:    

Defendants EVENTUS HOLDINGS, LLC, NATIONAL PAYMENT SYSTEMS, LLC, SABIN BURRELL, and JOHN HYNES.

Defendant JONATHAN BECKMAN.

 

RP:      Plaintiffs.

 

Summary

 

On 9/14/22, plaintiffs filed a Complaint.

On 10/28/22, plaintiffs filed a First Amended Complaint, alleging that defendants BECKMAN, BURRELL, HYNES, NATIONAL and EVENTUS, including as managers and membership interest owners of plaintiffs, through their mutual and continuing scheme, including under-reporting residual income of plaintiffs and over-reporting operating expenses, stole all assets of plaintiffs, and 50% of Plaintiff LAW’s ownership interest therein, in violation of operating agreements and in breach of related covenants of good faith and fair dealing.

The causes of action are:

1. BREACH OF CONTRACT – OPERATING  AGREEMENTS;

2. BREACH OF COVENANT OF GOOD FAITH  AND FAIR DEALING - OPERATING AGREEMENTS;

3. DECLARATORY RELIEF - LAW IS SOLE MEMBER AND MANAGER;

4. BREACH OF FIDUCIARY DUTY;

5. LEGAL MALPRACTICE;

6. CONSTRUCTIVE FRAUD;

7. TORTIOUS INTERFERENCE WITH CONTRACT -  OPERATING AGREEMENTS;

8. AIDING AND ABETTING BREACH OF  FIDUCIARY DUTY;

9. NEGLIGENCE;

10. IMPOSITION OF CONSTRUCTIVE TRUST;

11. ACCOUNTING OF COMPANY ASSETS AND PROCEEDS;

12. CIVIL PENALTIES UNDER PENAL CODE  SECTION 496(c).

 

 

MP Positions

 

Moving parties request an order compelling plaintiffs’ into arbitration on the question of whether Plaintiffs’ claims are released by the Settlement Agreement, and staying this action, on grounds including the following:

 

·         A settlement agreement among some of the parties provides that the disputes as to defendants Eventus and National Payments Systems, LLC. are to be resolved through arbitration.

·         Plaintiff Beckman bargained for a settlement agreement and arbitration provision on behalf of himself and Plaintiffs.

·         The arbitration provision applies to all plaintiffs.

·         Beckman had actual authority to bind the Plaintiff Entities based on his status as Tax & Business Manager and the majority owner of each.

·         From Movants’ perspective, there was ample evidence that Beckman also had authority to act as ostensible agent for Plaintiffs who knew about it.

·         The agreement benefitted Law and Beckman.  While Law did not sign the 2022 Agreement,  Law was  aware of the circumstances leading to the 2022 Agreement; Law met with Beckman and other key members leading up to the mediations that gave rise to the 2022 Agreement; Law directly and materially benefitted from the terms of the 2022 Agreement; Law supported the execution of the 2022 Agreement; and Law was aware that the 2022 Agreement required all disputes arising out of the 2022 Agreement to be arbitrated.

·         Beckman simply released legal claims, which did not require approval of a majority of the members under operating agreements.

·         The arbitration provision provides that “[a]ny action or proceeding arising out of the interpretation or alleged breach of this Agreement shall be resolved through confidential arbitration.” (Griffin Decl., Ex. A, Sec. IV.).

·         The FAA does not enable discovery here, and Plaintiffs’ complaints about non-responses to their discovery relate to irrelevant questions about cash payments to Beckman and how it was “received and determined” and how that value compares to Law’s perception of the value of the Plaintiff Entities.

·         The Complaint’s claim for malpractice against Hynes also is arbitrable. E.g., Sargon Enterprises, Inc. v. Browne George Ross LLP, 15 Cal. App. 5th 749, 755.

·         Moving parties are not required to provide a complete and unredacted copy of the Settlement Agreement.

 

 

RP Positions

 

Opposing parties advocate denying, for reasons including the following:

 

·         Movants failed to meet the burden to show arbitration compelling grounds.  They present a substantially redacted copy of the contract and without its exhibits, including a term sheet. Plaintiffs demanded an unredacted copy and offered Defendants a confidentiality stipulation but Defendants refused.

·         Mr. Law and none of the Plaintiffs are a party to the Settlement Agreement nor signed the arbitration agreement therein.

·         Beckman did not have authority as Tax and Business Manager to sign the disputed  Settlement Agreement (Griffin Decl., Ex. "A") because Section 4.2 of each Operating Agreement required approval of the majority of members.

·         Movants proffered no evidence Law and Plaintiff Entities are/were members, managers, shareholders, directors, officers, partners, employees, representatives, agents, attorneys, heirs, affiliates, subsidiaries, successors, transferees and assigns of JDB at the time of the agreement's execution. Nor are they. (Law Decl., ¶¶ 13-15).

·         None of Plaintiffs' claims arise out of an interpretation of the Settlement Agreement nor a breach thereof.  The Settlement Agreement's arbitration clause is particularly narrow both omitting a general reference to disputes "related to" the agreement and specifically providing for arbitration only of two types of disputes: those "arising out of the interpretation or alleged breach of this Agreement". (Griffin Decl., Ex. A, §IV.P).

·         Plaintiffs request they be permitted their right to conduct limited discovery in relation to the Motion to compel them to arbitrate. See Bouton v. USAA Casualty Ins. Co. (2008) 167 Cal.App.4th 412,427.  Plaintiffs served their November 18, 2022 limited discovery requests on Movants and  Beckman seeking in part an unredacted version of the Settlement Agreement and other  information related to the Settlement Agreement's internal arbitration agreement that Movants and Beckman are attempting to force on Plaintiffs.

·         Pursuant to the FAA, which movants contend applies, courts employ a summary judgment standard under 12 FRCP 56, with all inferences to be drawn in the non-moving party's favor, and that if a genuine  issue of material facts exists the court must hold a trial. Hansen v. LMB Mortgage Services, Inc. (9th Cir. 2021) 1 F4th 667,670. If a jury trial is demanded, then the court must proceed with a jury trial. Ibid. Plaintiffs demand a jury trial and have already posted jury fees.

·         Plaintiffs' claims against attorney Hynes are not arbitrable. As such, the Court should exercise its discretionary powers under CCP § 1281.2( c) to avoid inconsistent rulings. T

·         Since the Settlement Agreement's arbitration clause does not "clearly and unmistakably" empower the arbitrator to decide the issue of arbitrability, it is an issue for this court to decide. AT & T Technologies, Inc. v. Communications Workers of America (1986) 475 U.S. 643, 649.

 

 

 

Tentative Ruling

 

Both motions are granted.

Moving defendants and opposing plaintiffs shall arbitrate the controversies between them as to the First Amended Complaint, in accordance with the agreement to arbitrate.  This entire case is stayed until such arbitration has been completed.

The moving parties’ evidence suffices to meet the burden to show the arbitration agreement, without them needing to file an unredacted agreement. 

Parties seeking to compel arbitration meet their initial burden simply by reciting the terms of the governing provision, or by attaching a copy of the provisions, unless there is a dispute over authenticity that is beyond merely contesting the preliminary showing.  Sprunk v. Prisma LLC (2017) 14 Cal.App.5th 785, 793;  Ruiz v. Moss Bros. Auto Group, Inc. (2014) 232 Cal.App.4th 836, 846   (“In the face of … failure to recall signing … had the burden of proving by a preponderance of the evidence that the electronic signature was authentic….”).  See also  Condee v. Longwood Mgt. Corp. (2001) 88 Cal.App.4th 215, 219 (once petitioners allege that an arbitration agreement exists, the burden shifts to respondents to prove the falsity of the purported agreement, and no evidence or authentication is required to find the arbitration agreement exists);  Espejo v. So. Cal. Permanente Med. Group (2016) 246 Cal.App.4th 1047, 1060 (“defendants … met their initial burden by attaching to their petition a copy of the purported arbitration agreement bearing … electronic signature. Once … challenged …, defendants were then required to establish by a preponderance of the evidence that the signature was authentic.”);  Brodke v. Alphatec Spine Inc. (2008) 160 Cal.App.4th 1569, 1575-76 (petition or motion to compel arbitration must allege arbitration agreement exists, and cannot contest it).   But see  Avila v. So. Cal. Specialty Care, Inc. (2018) 20 Cal.App.5th 835, 844  (“The party seeking to compel arbitration bears the burden of proving the existence of a valid arbitration agreement.”);  Molecular Analytical Systems v. Ciphergen Biosystems, Inc. (2010) 186 Cal.App.4th 696, 705 (“To satisfy the moving party's initial burden, the petition or motion must be ‘accompanied by prima facie evidence of a written agreement to arbitrate the controversy’ in question.”);  Toal v. Tardif (2009) 178 Cal. App. 4th 1208, 1219  (“To the extent Condee conflicts with Rosenthal, our Supreme Court's decision is controlling.”);   Bouton v. USAA Casualty Ins. Co. (2008) 167 Cal.App.4th 412, 423-24 (“in considering a Code of Civil Procedure section 1281.2 petition to compel arbitration, a trial court must make the preliminary determinations whether there is an agreement to arbitrate and whether the petitioner is a party to that agreement (or can otherwise enforce the agreement).”);   Segal v. Silberstein  (2007) 156 Cal.App.4th 627, 633 (“petitioner bears the burden of proving the existence of a valid arbitration agreement….”);  Giuliano v. Inland Empire Personnel, Inc.  (2007) 149 Cal.App.4th 1276, 1284 (“‘petitioner bears the burden of proving the existence of a valid arbitration agreement by the preponderance of the evidence….’”); Rosenthal v. Great Western Fin. Securities Corp. (1996) 14 Cal.4th 394, 413 (as to a petition to compel arbitration, “petitioner bears the burden of proving its existence by a preponderance of the evidence.”);  Banner Ent., Inc. v. Sup. Ct. (1998) 62 Cal.App.4th 348, 356 (citing Rosenthal, supra).

The subject arbitration provisions are expressly applicable to a wide array of third parties that includes plaintiffs.

A non-signatory can be compelled to arbitrate where there was intent to benefit that third party under the contract.  Benasra v. Marciano (2001) 92 Cal.App.4th 987, 991-93.  Arbitration agreements are binding upon third party beneficiaries, and third parties having an agency or similar relationship with the signatory party.  Matthau v. Sup. Ct. (2007) 151 Cal.App.4th 593, 599.  Parties seeking to compel arbitration on the ground of agency have the burden to show an agent’s express or implied consent to have the contracting party act as an agent in agreeing to arbitration.  Warfield, v. Summerville Senior Living, Inc. (2007) 158 Cal.App.4th 443, 448.  "A nonsignatory to an agreement to arbitrate may be required to arbitrate, and may invoke arbitration against a party, if a preexisting confidential relationship, such as an agency relationship between the nonsignatory and one of the parties to the arbitration agreement, makes it equitable to impose the duty to arbitrate upon the nonsignatory."  Westra v. Marcus & Millichap Real Estate Investment Brokerage Co., Inc. (2005) 129 Cal. App. 4th 759, 765.  Accord Smith v. Microskills San Diego L.P. (2007) 153 Cal. App. 4th 892, 897.  “When a plaintiff brings a claim which relies on contract terms against a defendant, the plaintiff may be equitably estopped from repudiating the arbitration clause contained in that agreement…. There is no reason why this doctrine should not be equally applicable to a nonsignatory plaintiff.”  JSM Tuscany, LLC v. Sup. Ct. (2011)193 Cal. App. 4th 1222, 1239, 1241  (“there is no rational basis to limit this conclusion to claims expressly based on … breach …. The equitable estoppel doctrine extends to claims that are dependent upon or inextricably intertwined with the obligations imposed by the contract containing the arbitration clause.”).

The arbitration provision’s scope encompasses settlement agreement releases, and so plaintiffs’ claims arise out of interpretation and breach of the agreement. 

In order to determine arbitration-clause scope, courts should give effect to the parties’ intentions, in light of the usual and ordinary meaning of the language, and the circumstances of the agreement.  Titolo v. Cano (2007) 157 Cal.App.4th 310, 317.  “‘Doubts as to whether an arbitration clause applies to a particular dispute are to be resolved in favor of sending the parties to arbitration. The court should order them to arbitrate unless it is clear that the arbitration clause cannot be interpreted to cover the dispute.’” California Correctional Peace Officers Ass'n v. State (2006) 142 Cal.App.4th 198, 205.

Where the Federal Arbitration Act applies, state procedural rules nonetheless govern the determination of a motion to compel arbitration. Vivid Video Inc. v. Playboy Ent. Group, Inc. (2007) 147 Cal.App.4th 434, 440.  “[S]ection 9 of the FAA is procedural in nature and does not apply to state court litigation.”  Swissmex-Rapid S.A. de C.V. v. SP Systems, LLC (2012) 212 Cal.App.4th 539, 546.  “Even when the Federal Arbitration Act applies, state law governs such matters as who is bound by and who may enforce an arbitration agreement.”  Thomas v. Westlake (2012) 204 Cal.App.4th 605, 614 n. 7.

Parties’ following statutes providing for arbitration or references, results in a waiver of a jury trial, without the need for predispute agreements to expressly so state.  Woodside Homes of California, Inc. v. Sup.Ct. (2006) 142 Cal. App. 4th 99, 103, 104.  Predispute arbitration agreements are specifically authorized by statute. (Code Civ. Proc., § 1281 [“A written agreement to submit to arbitration an existing controversy or a controversy thereafter arising is valid, enforceable and irrevocable, save upon such grounds as exist for the revocation of any contract”].)…. Contracting parties can voluntarily agree to waive their constitutional right to have their dispute resolved in a judicial forum by a jury.”  Murrey v. Sup.Ct. (2023) 87 Cal. App. 5th 1223, 1236.

Where the Federal Arbitration Act applies, state procedural rules nonetheless govern the determination of a motion to compel arbitration. Vivid Video Inc. v. Playboy Ent. Group, Inc. (2007) 147 Cal.App.4th 434, 440.  “[S]ection 9 of the FAA is procedural in nature and does not apply to state court litigation.”  Swissmex-Rapid S.A. de C.V. v. SP Systems, LLC (2012) 212 Cal.App.4th 539, 546.

The Court finds that there is no presence of a nonarbitrable claim, nor any possibility of conflicting rulings.

 The ground for denying arbitration based on there being a third party, and a possibility of conflicting rulings (CCP §1281.2(c)), does not apply where all nonsignatories are subject to arbitration agreements.  Laswell v. AG Seal Beach, LLC (2010) 189 Cal.App.4th 1399, 1405.  “[T]he presence of a nonarbitrable cause of action is not sufficient by itself to invoke the trial court's discretion to deny arbitration under Code of Civil Procedure section 1281.2, subdivision (c)….”  Laswell v. AG Seal Beach, LLC (2010) 189 Cal.App.4th 1399, 1409.  In applying Code of Civil Procedure Section 1281.2(c) judges may rely on complaint allegations to determine that there is a possibility of conflicting rulings if a motion to compel arbitration were granted, and evidence is not required. Abaya v. Spanish Ranch I, L.P. (2010) 189 Cal.App.4th 1490, 1498-99.  Under Code of Civil Procedure Section 1281.2(c), judges have broad discretion as to whether to deny arbitration where there are third parties to a pending court action arising out of the same transaction or series of related transactions, in which there is a possibility of conflicting rulings on a common issue of law or fact.  Molecular Analytical Systems v. Ciphergen Biosystems, Inc. (2010) 186 Cal.App.4th 696, 704-05;  Birl v. Heritage Care, LLC (2009) 172 Cal. App. 4th 1313, 1318;  Best Interiors, Inc. v. Millie & Severson, Inc. (2008) 161 Cal.App.4th 1320, 1329;  Cronus Investments, Inc. v.  Concierge Services (2005) 35 Cal.4th 376, 383, 394;  Whaley v. Sony Computer Entm't Am. (2004) 121 Cal.App.4th 479, 488; Powers v.  Dickson, Carlson & Campillo (1997) 54 Cal.App.4th 1102, 1115 (citing CCP §1281.2(c)).

Where a court has ordered arbitration, it shall stay the pending action, until an arbitration is had in accordance with the order to arbitrate, or another earlier time, and the stay may be with respect to an issue that is severable.  CCP §1281.4;  Cruz v. PacifiCare Health Systems, Inc. (2003) 30 Cal. 4th 303, 320;  Twentieth Century Fox Film Corp. v. Sup. Ct. (2000) 79 Cal.App.4th 188, 192;  Heritage Provider Network, Inc. v. Sup. Ct.  (2008) 158 Cal.App.4th 1146, 1152, 1154 n. 12.