Judge: Michael E. Whitaker, Case: 24SMCV02176, Date: 2024-09-12 Tentative Ruling

Case Number: 24SMCV02176    Hearing Date: September 12, 2024    Dept: 207

TENTATIVE RULING

 

DEPARTMENT

207

HEARING DATE

September 12, 2024

CASE NUMBER

24SMCV02176

MOTION

Motion to Compel Arbitration

MOVING PARTY

Plaintiff Steven Berglas

OPPOSING PARTY

Defendants David Voss; Rachel Silverman; and Voss, Silverman & Braybrooke LLP

 

MOTION

 

Plaintiff Steven Berglas (“Plaintiff”) moves to compel Defendants David Voss; Rachel Silverman; and Voss, Silverman & Braybrooke LLP (“Defendants”) to arbitrate Plaintiff’s claims for (1) professional negligence; (2) breach of fiduciary duty; and (3) breach of contract. 

 

Defendants oppose the motion and Plaintiff replies.

 

EVIDENTIARY OBJECTIONS

 

            The Court rules as follows with respect to Defendants’ Evidentiary Objections:

 

  1. Overruled
  2. Overruled

 

The Court rules as follows with respect to Plaintiff’s Evidentiary Objections:

 

  1. Saunders Decl. ¶ 4: Overruled
  2. Saunders Decl. ¶ 6: Overruled
  3. Saunders Decl. ¶ 6: Overruled
  4. Saunders Decl. ¶ 7: Overruled

 

ANALYSIS

 

1.     MOTION TO COMPEL ARBITRATION – LEGAL STANDARDS

 

            “[T]he advantages of arbitration include a presumptively less costly, more expeditious manner of resolving disputes.  It follows a party to a valid arbitration agreement has a contractual right to have its dispute with another party to the contract resolved quickly and inexpensively.”  (Henry v. Alcove Investment, Inc. (1991) 233 Cal.App.3d 94, 99–100 [cleaned up].)  Thus, “on petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists.”  (Code Civ. Proc., § 1281.2; see also

EFund Capital Partners v. Pless (2007) 150 Cal.App.4th 1311, 1320 [the language in section 1281.2 compelling arbitration is mandatory].) The right to compel arbitration exists unless the court finds that the right has been waived by a party’s conduct, other grounds exist for revocation of the agreement, or where a pending court action arising out of the same transaction creates the possibility of conflicting rulings on a common issue of law or fact.  (Code Civ. Proc., § 1281.2, subds. (a)-(c).)   

 

            “On a petition to compel arbitration, the trial court must first determine whether an agreement to arbitrate the controversy exists.  Because the existence of the agreement is a statutory prerequisite to granting the petition, the petitioner bears the burden of proving its existence by a preponderance of the evidence.  The party seeking arbitration can meet its initial burden by attaching to the petition a copy of the arbitration agreement purporting to bear the respondent's signature.”  (Bannister v. Marinidence Opco, LLC (2021) 64 Cal.App.5th 541, 543-544 [cleaned up].)  The party seeking to compel arbitration must also “plead and prove a prior demand for arbitration and a refusal to arbitrate under the agreement.”  (Mansouri v. Superior Court (2010) 181 Cal.App.4th 633, 640-641.) 

 

            And while the moving party on a motion to compel arbitration “bears the burden of proving the existence of a valid arbitration agreement by a preponderance of the evidence, [a] party opposing the petition bears the burden of proving by a preponderance of the evidence any fact necessary to its defense.  The trial court sits as the trier of fact, weighing all the affidavits, declarations, and other documentary evidence, and any oral testimony the court may receive at its discretion, to reach a final determination.”  (Ruiz v. Moss Bros. Auto Group, Inc. (2014) 232 Cal.App.4th 836, 842 [cleaned up]; see also Pinnacle Museum Tower Assn. v. Pinnacle Market Development (US), LLC (2012) 55 Cal.4th 223, 236 [“The party seeking arbitration bears the burden of proving the existence of an arbitration agreement, and the party opposing arbitration bears the burden of proving any defense, such as unconscionability”].) 

 

2.     ENFORCEABLE ARBITRATION AGREEMENTS

 

The Legal Services Agreement between Plaintiff and Defendant Voss, Silverman & Braybrooke LLP (“VS&B”) provides:

 

Any controversy and/or dispute between the parties regarding the construction and/or application of any portion of this agreement, and all claims for damages or other relief upon or pertaining to this agreement or its breach, including, without limitation, disputes concerning fees, costs, malpractice, and/ or professional misconduct, or any combination thereof, shall be submitted to binding arbitration without right of appeal (except as specifically provided by law) upon written request of either party, with all proceedings conducted pursuant to the California Arbitration Act, California Code of Civil Procedure Section 1280, et seq., before a single neutral arbitrator. The arbitrator shall be either an attorney with at least fifteen years of litigation experience in the state of California or a retired judge, and shall be affiliated with either Judicate West or Alternative Dispute Resolution Services unless the parties agree in writing to use another arbitrator.

 

In the event that the parties for whatever reason fail to reach an agreement on a designated arbitrator within twenty days following either party's written request for arbitration, the parties agree that the selection of arbitrator may be made unilaterally by the administration office of Judicate West.

 

Discovery under the arbitrator's own rules shall not apply unless all parties so agree in writing. In any such arbitration, the arbitrator must award the prevailing party his/her arbitration fees. The arbitrator is without discretion, and must award these fees. Should the arbitrator fail to do so, the Los Angeles Superior Court is empowered to review both the facts and the law as to the arbitrator's denial of arbitration fees to the prevailing party. For the purposes of this section, the prevailing party is the party which makes a positive net recovery in any amount.

 

(Ex. A to Paluch Decl.)

 

Defendants argue that Plaintiff knowingly waived the right to arbitration. 

 

a.      WAIVER

 

            “Waiver of the right to arbitrate does not require a voluntary relinquishment of a known right.  For example, a party may waive the right by an untimely demand even without any intent to forgo the procedure.  In this circumstance, waiver is similar to a forfeiture arising from the nonperformance of a required act.”  (Hoover v. American Income Life Ins. Co. (2012) 206 Cal.App.4th 1193, 1203 (hereafter Hoover) [cleaned up].)  “Although participation in litigation of an arbitrable claim does not itself waive a party's right later to seek arbitration, at some point, litigation of the issues in dispute justifies a finding of waiver.”  (Id. at p. 1204.)  On the issue of what constitutes a “reasonable time” to demand arbitration, the Hoover court noted:

 

There is no fixed stage in a lawsuit beyond which further litigation waives the right to arbitrate. Rather, the court views the litigation as a whole in determining whether the parties' conduct is inconsistent with a desire to arbitrate.  A defendant's removal of a case filed in state court to federal court does not by itself constitute an implicit waiver of the right to compel arbitration.  But, a defendant's removal of a case to federal court, coupled with participation in several months of litigation, waives the right to arbitrate because electing to proceed in federal court on an arbitrable dispute is presumptive waiver of the right to arbitrate.

 

(Ibid. [cleaned up].)  On the issue of prejudice, the Hoover court stated:

 

The presence or absence of prejudice from the litigation is a determinative issue.  Because of the strong policy favoring arbitration, prejudice typically is found only where the petitioning party has unreasonably delayed seeking arbitration or substantially impaired an opponent's ability to use the benefits and efficiencies of arbitration.  Prejudice sufficient for waiver will be found where instead of seeking to compel arbitration, a party proceeds with extensive discovery that is unavailable in arbitration proceedings.

 

(Id. at p. 1205 [cleaned up].)  Similarly, in finding there was no waiver to arbitrate, the California Supreme Court noted, in part:

 

Although we have found no California or United States Supreme Court decisions on point, other courts that have addressed this issue hold that a petitioning party does not waive its arbitration rights merely by seeking to change judicial venue of an action prior to requesting arbitration. In so holding, those courts reason that a party is not required to litigate the issue of arbitration in an improper or inconvenient venue, and that a party's position on venue does not necessarily reflect a position on arbitrability. We agree with that reasoning, and find it consistent with California and federal case law holding that a waiver determination requires the consideration of all circumstances, including the absence or presence of prejudice.

 

(St. Agnes Medical Center v. PacifiCare of Cal. (2003) 31 Cal.4th 1187, 1205 (hereafter St. Agnes) [cleaned up].) 

 

            In Hoover, the appellate court held that the defendant waived its right to arbitration by “actively litigating this action for more than a year and causing prejudice to Hoover.”  (Hoover, supra, 206 Cal.App.4th at p. 1203.)  In particular, the Hoover court determined that the defendant waived its right because it “[d]id not introduce the question of arbitration for almost a full year and [the defendant] conducted litigation in a style inconsistent with the right to arbitrate.  The two failed efforts to remove the case to federal court and [the defendant’s] recalcitrant responses to discovery suggest its policy has been one of delay rather than seeking a more prompt and expeditious resolution through arbitration.  During that time, [the defendant] availed itself of discovery mechanisms like depositions not available in arbitration.  [The defendant] also solicited putative class members, in an effort to reduce the size of the class. Hoover was certainly strongly affected and prejudiced by [the defendant’s] delay, causing significant legal expenses.”

(Id. at p. 1205 [cleaned up]; but see St. Agnes, supra, 31 Cal.4th at p. 1201 [“a waiver generally does not occur where the arbitrable issues have not been litigated to judgment].) 

 

Defendants argue Plaintiff knowingly waived the right to arbitration because Plaintiff commenced a total of three proceedings around the same time all based on the same allegations: (1) an arbitration proceeding filed on May 7 with ADR Services; (2) this action, filed May 8; and (3) a fee dispute arbitration through the Los Angeles County Bar Association filed around the same time, yet Plaintiff failed to serve the May 7 arbitration demand.  (Saunders Decl. ¶¶ 3-5.) 

 

Defendants further contend Plaintiff failed to serve the May 7 arbitration demand and only sent the summons and complaint for this action with a notice of acknowledgment and receipt (Saunders Decl. ¶¶ 6-7), although Defendants concede that on May 8 they received service of the arbitration demand (Saunders Decl. ¶ 4 and Ex. A). 

 

Plaintiff clarifies on reply that (1) Plaintiff’s counsel served the May 7 demand for arbitration via email on May 7 and via personal service on May 8 (Paluch Reply Decl. ¶¶ 3, 5 and Exs. B & E); (2) Plaintiff’s counsel served Defendants an updated copy of the arbitration demand via email on May 8 and via personal service on May 9 (Paluch Reply Decl. ¶¶ 4-5 and Exs. C & F); and (3) the parties telephonically discussed arbitration on or about May 28, 2024, at which point Defendants took the position that the demand for arbitration was invalid because Plaintiff did not personally sign it (Paluch Reply Decl. ¶¶ 6-7 and Ex. D.)

 

The LA County Bar Association fee arbitration dispute was dismissed on or about June 18 on the grounds that “any right to proceed to a fee arbitration under the Mandatory Fee Arbitration Act was waived by the filing of the Complaint and the filing of the Demand with ADR Services.”  (Saunders Decl. ¶ 5 and Ex. B.)  On July 9, 2024, Defendants’ counsel sent a letter to ADR Services, objecting to the arbitration proceedings in light of the action filed in Los Angeles Superior Court, to which Plaintiff’s counsel did not respond or object, and on July 10, ADR Services confirmed “they would not be proceeding further.”  (Saunders Decl. ¶¶ 13-14 and Ex. G.)

 

Plaintiff’s counsel also met and conferred regarding Defendants’ demurrer and indicated an intent to file an amended complaint, but did not discuss contemplating moving to compel arbitration before filing the instant motion.  (Saunders Decl. ¶¶ 12, 16 and Ex. F.)  On reply, Plaintiff’s counsel indicates that on August 26, 2024, Plaintiff filed a case management conference statement indicating the case is subject to binding arbitration.  (Paluch Reply Decl. ¶ 2 and Ex. A.)  The Court notes that statement was filed nearly two weeks after the Motion to Compel Arbitration was filed on August 13.

           

            Ultimately, the Court does not find on these facts that Plaintiff waived the right to arbitrate.  This case was only pending for about three months before Plaintiff moved to arbitrate. Plaintiff simultaneously filed arbitration proceedings with this lawsuit, and refused to dismiss the civil action because Defendants’ counsel refused to agree to a tolling agreement.  (Saunders Decl. ¶ 11.)  Plaintiff served the arbitration demand multiple times between May 7-9, and only sent a notice of acknowledgment and receipt to Defendants’ counsel on July 9, at counsel’s request.  (Saunders Decl. ¶ 11.)  It was Defendants’ counsel who contacted ADR Services that same day, requesting that the arbitration be dismissed, which it was the following day.  (Saunders Decl. ¶¶ 13-14 and Ex. G.)  And although initial sets of form interrogatories and requests for production have been served, it was Defendants who served the discovery, not Plaintiff.  (Saunders Decl. ¶ 15.)  Said discovery was served the same day this motion was filed and served.  (See id.) 

 

CONLUSION

 

            In conclusion, Plaintiff has met his burden to compel arbitration, and the Court specifically finds that the Arbitration Agreement between Plaintiff and VS&B is valid and enforceable, and Plaintiff has not waived the right to arbitrate.  Therefore, the Court grants Plaintiff’s motion to compel arbitration. 

 

            Further, the Court stays this case, pending the resolution of arbitration proceedings, and vacates the Case Management Conference. 

 

            Further, the Court sets a Status Conference regarding the Arbitration on April 23, 2025 at 8:30 A.M. in Department 207.  The parties shall meet and confer in advance of the Status Conference, and file a Joint Report regarding the status of the Arbitration no later than 5 court days before the Status Conference. 

 

            Plaintiff shall provide notice of the Court’s ruling and file the notice with a proof of service forthwith.

 

 

 

 

DATED:  September 12, 2024                                               ___________________________

                                                                                          Michael E. Whitaker

                                                                                          Judge of the Superior Court