Judge: Melvin D. Sandvig, Case: 24CHCV00482, Date: 2024-09-09 Tentative Ruling
Case Number: 24CHCV00482 Hearing Date: September 9, 2024 Dept: F47
Dept. F47
Date: 9/9/24
Case #24CHCV00482
DEMURRER TO THE
FIRST AMENDED COMPLAINT
Demurrer filed on 8/7/24.
MOVING PARTY: Defendants Armen Bahadourian; Park Place
Cali Electro-Motors and Dan Hoogenraad
RESPONDING PARTY: Plaintiffs Feliks Zibelberg and City
Wide Printing, Inc.
NOTICE: ok
Demurrer is to the entire First Amended Complaint:
1. Breach of Contract
2. Intentional Misrepresentation/Fraud
3. Negligent Misrepresentation
RULING: The demurrer is sustained with 30 days
leave to amend.
SUMMARY OF FACTS & PROCEDURAL HISTORY
This action arises out of an agreement to purchase two
golf carts. Plaintiff alleges that on or
about 12/16/22, Defendant Armen Bahadourian (Bahadourian), who is alleged to be
the owner and operator of Defendant Park Place Cali-Electro Motors (Park Place),
offered to sell two golf carts to Plaintiffs Feliks Zibelberg and City Wide
Printing, Inc. (collectively, Plaintiffs; Plaintiff, singular, refers to
Zibelberg) for a total price of $72,700.00.
(FAC ¶¶3-4, 12). Plaintiffs
allege that during the negotiations it was discussed that the golf carts would
be delivered within 10-14 weeks and Bahadourian represented that he and
Defendant Dan Hoogenraad (Hoogenraad) “had spoken and agreed and would assemble
and deliver the carts to Plaintiff.”
(FAC ¶12). The First Amended
Complaint alleges that Plaintiff Zibelberg accepted “Defendant’s,” singular,
offer to sell the golf carts in writing.
(FAC ¶13).
Plaintiff alleges that on 1/3/23, Bahadourian provided
Plaintiff with two separate “Price Sheets,” that Plaintiff alleges had been
provided to Bahadourian by Hoogenraad and his business which Plaintiff signed
and returned. (FAC ¶14, Ex.1, 2). The “Price Sheets” make no reference to
Hoogenraad or his alleged business. (See
FAC ¶¶5-6, Ex.1-2). Plaintiff alleges
that the “Price Sheets” represent the agreement/written contract between the
parties. (FAC ¶¶14, 32). Thereafter, on 1/9/23, “Plaintiff paid the
one half required deposits to Park Place.”
(FAC ¶15, Ex.3, 4).
Plaintiff alleges that Defendants, plural, failed to
deliver the carts by March 2023 as agreed.
(FAC ¶16). When the carts were
still not delivered as of 1/5/24, Plaintiff alleges that Hoogenraad
communicated with Plaintiff stating that the carts were in the process of being
built, but he did not have a specific delivery date and the deposits were
considered earnest money and non-refundable.
(FAC ¶19). Plaintiffs allege that
Bahadourian and Hoogenraad offered a $5,000.00 discount on each cart with a
prospective February 2024 delivery date which Plaintiff rejected. (FAC ¶20).
Thereafter, on 2/15/24, Plaintiff filed this action against
Bahadourian, Park Place, Hoogenraad and So Cal Custom Dan for: (1) Breach of
Contract, (2) Intentional Misrepresentation/Fraud and (3) Negligent
Misrepresentation. On 4/2/24,
Bahadourian and Park Place filed an answer to the complaint. On 4/29/24, Hoogenraad filed a demurrer to
the complaint which was scheduled for hearing on 6/25/24. On 6/10/24, Plaintiffs filed the subject
First Amended Complaint alleging the same 3 causes of action.
After meet and confer efforts failed to resolve the
issues Bahadourian, Park Place and Hoogenraad had with the First Amended Complaint, on 8/7/24, these three
defendants filed and served the instant demurrer to the entire First Amended
Complaint. Despite the fact that
Bahadourian and Park Place answered the original complaint, they can demur to
the First Amended Complaint. See Hawthorne
(1891) 88 Cal. 159; Bristol Convalescent Hospital (1968) 258 CA2d 848; Ogier
(1955) 132 CA2d 496; Cohen (1966) 244 CA2d 650; CCP 586(a)(1). Plaintiff has opposed the demurrer. No reply to the opposition has been
filed.
ANALYSIS
Meet-and-Confer
Contrary to the assertion in the opposition, the demurrer
is accompanied by the declaration of attorney Adam Apollo who states: “I was
able to meet with Plaintiff’s counsel by phone in real time, and he indicated
neither dismissal nor amendment would be forthcoming to address my issues, thus
necessitating this demur [sic].” (See
Opposition, p.3:11-p.4:3; Apollo Decl. ¶3 attached to the Demurrer at p.10; CCP
430.41(a)(3)).
1st cause of action – Breach of Contract
In order to state a claim for breach of contract, a
plaintiff must allege: (1) the contract, (2) plaintiff’s performance or excuse
for nonperformance, (3) defendant’s breach and (4) resulting damage to
plaintiff. See Richman
(2014) 224 CA4th 1182, 1186. If facts
appearing in exhibits to the complaint contradict those alleged, the facts in
the exhibits take precedence. Holland
(2001) 86 CA4th 1443, 1446. Additionally,
a demurrer admits the truth of all material facts properly pleaded, but not
contentions, deductions or conclusions of fact or law. See Serrano (1971) 5 C3d 584,
591; Division (EAT), LLC (2022) 86 CA5th 439, 452; Travelers
Indemnity Co. of Connecticut (2021) 70 CA5th 341, 358-359.
Plaintiffs have failed to adequately allege the contract
at issue (i.e., the parties and terms).
The allegations within the breach of contract cause of action allege
that “Plaintiff [singular] and Defendant [singular] entered into a written
contract.” (FAC ¶32). However, at other points, the First Amended
Complaint alleges that “Plaintiffs,” plural, paid “Defendants,” plural, and
“Defendants,” plural, breached the contract.
(See FAC ¶¶33-36). The
documents attached to the First Amended Complaint, which Plaintiffs allege to
be the agreement and evidence of deposit payments, refer only to Park Place and
Plaintiffs. (See FAC ¶¶14, 24-25,
Ex.1-4).
Plaintiffs fail to plead facts, as opposed to conclusions,
to establish that any of the other Defendants are parties to the alleged
written contract. (See FAC ¶¶5, 10). Additionally, Plaintiffs allege that
Defendants breached the contract(s) by failing to deliver the carts in or about
March of 2023. (See FAC ¶¶16-17,
35, Ex.1, 2). However, a delivery date
for the carts is not included in the writings attached to the First Amended
Complaint, which Plaintiffs contend form the written agreement between the
parties. (FAC ¶¶14, 24, Ex.1, 2). Rather, Plaintiffs allege that the delivery
date was discussed during the negotiation process. (FAC ¶22).
Because the contract and its terms are not adequately
alleged, Plaintiffs have also failed to adequately allege Defendants’ breach
thereunder.
2nd cause of action – Intentional
Misrepresentation and Fraud & 3rd cause of action – Negligent
Misrepresentation
The elements of a fraud cause of action are: (1) a misrepresentation,
(2) knowledge of falsity, (3) intent to defraud, (4) justifiable reliance on
the misrepresentation and (5) resulting damage. Stansfield (1990) 220 CA3d 59, 73. The same elements comprise a cause of action
for negligent misrepresentation, except there is no requirement of intent to
induce reliance. Cadlo (2004) 125
CA4th 513, 519. Each element of a fraud and/or
negligent misrepresentation cause of action must be pled with factual
specificity. Stansfield, supra;
Cadlo, supra.
In support of their fraud cause of action, Plaintiffs
allege:
“Defendant Bahadourian and
Hoogenraad, along with their respective businesses, represented to Plaintiff
that they would deliver the golf carts on tine [sic] if Plaintiff pays the
requested funds to which Plaintiff complied in full.”
(See FAC ¶38).
Plaintiffs go on to allege that although they performed
under the written agreement, “Defendants Bahadourian and Hoogenraad refused,
and has continued to refuse, to deliver the requested golf carts to Plaintiff
Zibelberg.” (FAC ¶39). However, the other allegations in the First
Amended Complaint indicate in or around December of 2023 and/or January of
2024, Bahadourian and Hoogenraad agreed to discount each cart with a
prospective delivery date of February 2024, which Plaintiff rejected. (FAC ¶20).
Such allegations directly contradict Plaintiffs claim that Defendants
have refused and continue to refuse to deliver the golf carts and knew any
representation was false when made.
With regard to the negligent misrepresentation cause of
action, Plaintiffs allege that:
“46. Defendants Bahadourian and
Hoogenraad represented to Plaintiff that they would deliver the golf carts to
Plaintiff within a timer [sic] after Plaintiff made the required payment.
Plaintiff did make the payments.
47. Defendants, and each of them,
and more specifically Defendants Bahadourian and Hoogenraad made the
representations to Plaintiff Zibelberg that they could and would protect
Plaintiffs' rights by delivering the golf carts in a timely fashion being fully
aware of the obligations of Plaintiffs to its ordering customers.”
The allegations in paragraph 47 are so ambiguous that it
cannot be determined what was purportedly represented. Also, without any supporting facts, Plaintiffs
go on to conclude that Bahadourian and Hoogenraad had no reasonable ground to
believe their representations to Plaintiff were true. (FAC ¶48).
Further, Plaintiffs have failed to specifically allege
which of the Defendants made what specific misrepresentation, when they were
made and/or how. As noted above, the
contract does not include a completion/delivery date.
CONCLUSION
The demurrer is sustained. Due to the liberal policy of allowing leave
to amend and because this is only the First Amended Complaint and the first
time the pleading is before the Court, Plaintiffs are given the opportunity to
try to cure the defects in their pleading.
A Second Amended Complaint is due to be filed and served
within 30 days.