Judge: Mark C. Kim, Case: 22LBCV00251, Date: 2022-09-15 Tentative Ruling

Case Number: 22LBCV00251    Hearing Date: September 15, 2022    Dept: S27

  1. Background Facts

Plaintiff, Jose A. Perez filed this action against Defendants, Anel Mejia, Martina Valderrama, and all persons claiming rights in the subject property.  Plaintiff filed his complaint on 6/03/22.  Plaintiff’s complaint includes causes of action for fraud, quiet title, declaratory relief, and partition. 

 

The crux of Plaintiff’s complaint is that he was incarcerated in 2018, and while he was incarcerated, the mother of his children, Mejia, convinced him to change title into her name with the promise that she would annul the document once he was released.  Plaintiff alleges he owned the subject property with Valderrama, who is the mother of Mejia. 

Plaintiff alleges he signed a quitclaim deed on 5/14/18, pursuant to which Mejia and Valderrama became the owners of the property.  He alleges he was released in June of 2018, but Mejia denied him access to his home upon his release. 

 

  1. Demurrer

a.     Legal Standard on Demurrer

A demurrer is a pleading used to test the legal sufficiency of other pleadings. It raises issues of law, not fact, regarding the form or content of the opposing party’s pleading.  It is not the function of the demurrer to challenge the truthfulness of the complaint; and for purpose of the ruling on the demurrer, all facts pleaded in the complaint are assumed to be true, however improbable they may be.

 

A demurrer can be used only to challenge defects that appear on the face of the pleading under attack; or from matters outside the pleading that are judicially noticeable. Blank v. Kirwan 39 Cal.3d 311 (1985). No other extrinsic evidence can be considered (i.e., no “speaking demurrers”). A demurrer is brought under CCP § 430.10 [grounds], § 430.30 [as to any matter on its face or from which judicial notice may be taken], and § 430.50(a) [can be taken to the entire complaint or any cause of action within].  Specifically, a demurrer may be brought per CCP § 430.10(e) if insufficient facts are stated to support the cause of action asserted.  Per CCP §430.10(a) a demurrer may be brought where the court has no jurisdiction of the subject of the cause of action alleged in the pleading.  Furthermore, demurrer for uncertainty will be sustained only where the complaint is so bad that the defendant cannot reasonably respond.  CCP § 430.10(f). 

 

However, in construing the allegations, the court is to give effect to specific factual allegations that may modify or limit inconsistent general or conclusory allegations. Financial Corporation of America v. Wilburn, 189 Cal.App.3rd 764, 769 (1987). And, if the facts pled in the complaint are inconsistent with facts which are incorporated by reference from exhibits attached to the complaint, the facts in the incorporated exhibits control. Further, irrespective of the name or label given to a cause of action by the plaintiff, a general demurrer must be overruled if the facts as pled in the body of the complaint state some valid claim for relief. Special demurrers are not allowed in limited jurisdiction courts. (CCP § 92(c).)

 

Leave to amend must be allowed where there is a reasonable possibility of successful amendment. Goodman v. Kennedy, 18 Cal.3d 335, 348 (1976). The burden is on the complainant to show the Court that a pleading can be amended successfully. (Id.)

 

Finally, CCP section 430.41 requires that “[b]efore filing a demurrer pursuant to this chapter, the demurring party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer.” (CCP § 430.41(a).) The parties are to meet and confer at least five days before the date the responsive pleading is due. (CCP § 430.41(a)(2).) Thereafter, the demurring party shall file and serve a declaration detailing their meet and confer efforts. (CCP § 430.41(a)(3).)

 

b.     Meet and Confer

Defense Counsel did not provide a meet and confer declaration with the demurrer.  The Court understands that Plaintiff is self-represented.  This does not, however, excuse the obligation to meet and confer prior to filing the demurrer. 

 

The hearing on the demurrer is continued to 10/31/22, the date on which the Court already has a Case Management Conference scheduled in this action.  Defense Counsel must initiate meet and confer communications forthwith.  The parties must discuss all issues presented by way of demurrer in an attempt to resolve them without the need for a hearing.  If the parties are unable to resolve their issues, they must file opposition and reply at least nine and five court days, respectively, prior to the continued hearing date. 

 

Defendants are ordered to give notice.

 

Parties who intend to submit on this tentative must send an email to the court at gdcdepts27@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.orgIf the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar.  If a party submits on the tentative, the party’s email must include the case number and must identify the party submitting on the tentative.  If the parties do not submit on the tentative, they should arrange to appear remotely.