Judge: Michael E. Whitaker, Case: 24SMCV02135, Date: 2025-01-07 Tentative Ruling



Case Number: 24SMCV02135    Hearing Date: January 7, 2025    Dept: 207

TENTATIVE RULING

 

DEPARTMENT

207

HEARING DATE

January 7, 2025

CASE NUMBER

24SMCV02135

MATTER

Request for Default Judgment

 

Plaintiff Laurence M. Berman APC dba Berman Litigation Group (“Plaintiff”) requests for default judgment against Defendants Joseph Rubin (“Rubin”) and The Coachella Lighthouse, LLC (“Coachella”) (together, “Defendants”) in the amount of $320,346.05, which is composed of special damages as alleged in the Complaint in the amount of $302,096.67; prejudgment interest in the amount of $17,380.90; and costs in the amount of $868.48.

 

A.    Damages

 

            This case arises from allegations that Defendants failed to pay Plaintiff for legal services rendered.  Plaintiff’s Complaint alleges two causes of action for (1) Breach of Contract and (2) Common Count.  Coachella was served with a copy of the summons and complaint via substitute service on May 31, 2024, and Rubin was served via substitute service on June 3, 2024.  Default was entered against Defendants on August 23, 2024, and the Doe defendants were dismissed on December 2, 2024.

 

            Plaintiff’s Complaint seeks $302,096.67 in special damages. (See Compl.)  Therefore, Plaintiff does not seek damages that are in excess of what is pled in the Complaint. (See Code Civ. Proc., § 580, subd. (a) [“The relief granted to the plaintiff, if there is no answer, cannot exceed that demanded in the complaint”]; Levine v. Smith (2006) 145 Cal.App.4th 1131, 1136-1137 [“when recovering damages in a default judgment, the plaintiff is limited to the damages specified in the complaint”].) 

 

            In support of the request, Plaintiff has provided the Declaration of Laurence M. Berman, attached to which are billing records substantiating $255,124.69 in legal fees and $13,812.14 in unreimbursed costs, for a total outstanding principal balance of $268,936.83. 

 

            To this principal balance, Plaintiff has also charged interest at an annual rate of 10% from March 1, 2023 through the May 6, 2024 filing of the Complaint in the amount of $33,159.84. 

 

            However, Plaintiff has not provided an authenticated copy of any written agreement to substantiate the requested 10% interest rate. 

 

            Further, $268,936.83 principal balance x 10% ÷ 365 days/year = $73.68 daily interest, and $73.68 daily interest x 432 days from March 1, 2023 through the May 6, 2024 filing of the Complaint = $31,830.33, not $33,159.84.

 

            Therefore, the Court finds that Plaintiff has not demonstrated entitlement to the requested $302,096.67 in damages.

 

B.    Prejudgment Interest

 

            The interest computation for the $17,380.90 requested is stated as follows:  

 

·       $302,096.70 principal x 10% annual interest ÷ 365 days/yr = $82.77 daily interest

 

            As a threshold matter, as discussed above, Plaintiff has not provided an authenticated copy of a written agreement to substantiate the 10% contractual interest rate, as opposed to the 7% non-contractual interest rate.  Further, $82.77 daily interest x 205 days from May 6, 2024 when the Complaint was filed to November 27, 2024 when the Default Judgment package was filed = $16,967.85, not the requested $17,380.90.

 

            Therefore, Plaintiff has not demonstrated entitlement to the requested prejudgment interest.

 

C.    Costs

 

            Plaintiff also requests $838.22 in costs composed of $435 in filing fees and $404.22 in process server fees.  (CIV-100.)  Plaintiff’s request for costs is granted as Plaintiff is the prevailing party in this action. (Code Civ. Proc., § 1032, subd. (a)(4).)

 

CONCLUSION

 

            For the foregoing reasons, the Court continues the Order to Show Cause re Entry of Default Judgment to February 18, 2025 at 8:30 A.M. in Department 207. 

 

            Further, the Court orders Plaintiff to file a supplemental declaration in support of the default judgment request and a revised proposed default judgment in conformity with the Court’s ruling on or before February 4, 2025. 

 

 

DATED:  January 7, 2025                             ________________________________

                                                                        Michael E. Whitaker

                                                                        Judge of the Superior Court