Judge: Michael P. Linfield, Case: 21STCV33378, Date: 2023-05-04 Tentative Ruling

Case Number: 21STCV33378    Hearing Date: May 4, 2023    Dept: 34

SUBJECT:         Motion to Continue Trial and All Pretrial Dates and Deadlines, Including the Discovery Motion Hearings

 

Moving Party:  Plaintiff NIVO-1, LLC

Resp. Party:    Defendants Ami Kimoto, Weimin Liu, and Lin Dee Liu

 

 

SUBJECT:         Motion to be Relieved as Counsel

 

Moving Party:  Plaintiff’s Counsel June D. Coleman

Resp. Party:    Defendants Ami Kimoto, Weimin Liu, and Lin Dee Liu

 

 

The Motion to Continue is GRANTED in part.  The trial is continued until December ___, 2023; the discovery deadlines are not extended.  There shall be no further continuances.

 

The Motion to be Relieved as Counsel is GRANTED.

 

BACKGROUND:

 

On September 10, 2021, Plaintiffs NIVO-1, LLC and Anne Kihagi filed their Complaint against Defendants Ami Kimoto, Weimin Liu, and Lin Dee Liu regarding causes of action arising from a series of loans the Parties were involved in.

 

On October 29, 2021, Plaintiffs filed their First Amended Complaint.

 

On January 24, 2022, the Court: (1) determined that Plaintiff Anne Kihagi is a vexatious litigation, pursuant to Code of Civil Procedure section 391; and (2) entered a order prohibiting her from filing any new litigation in the courts of California in propria persona without first obtaining leave of the president judge or justice of the court where the new litigation is to be filed, pursuant to Code of Civil Procedure section 391.7, subdivision (a).

 

On May 11, 2022, the Court dismissed with prejudice Plaintiff Anne Kihagi from the First Amended Complaint because Plaintiff Anne Kihagi failed to post a security bond as previously ordered by the Court on February 4, 2022.

 

On April 14, 2023, June D. Coleman, who is Counsel for Plaintiff NIVO I, LLC, filed her MC-051, Motion to be Relieved as Counsel. Counsel Coleman concurrently filed: (1) MC-052, Declaration; (2) MC-053, Proposed Order; and (3) multiple sets of POS-040, Proofs of Service.

 

On April 17, 2023, Defendants Lin Dee Liu, Ami Kimoto, and Weimin Liu (“Defendants”) filed their Answer to the First Amended Complaint.

 

On April 18, 2023, Plaintiff NIVO 1, LLC filed its Motion to Continue Trial and All Pretrial Dates and Deadlines, Including the Discovery Motion Hearings (“Motion to Continue”). In support of its Motion to Continue, Plaintiff concurrently filed Declaration of June D. Coleman.

 

On April 27, 2023, Defendants filed their Combined Memorandum of Points and Authorities in Opposition to Plaintiff’s Motions to Withdraw and Continue Trial (“Combined Opposition”). Defendants concurrently filed: (1) Declaration of Ravi D. Sahae; and (2) Proof of Service.

 

On May 1, 2023, Plaintiff NIVO 1, LLC filed its Reply. Plaintiff concurrently filed Supplemental Declaration of June D. Coleman.

 

ANALYSIS:

 

 

I.            Motion to Continue Trial and All Related Trial Dates

       

A.  Legal Standard

 

Pursuant to California Rules of Court Rule 3.1332(b), “[a] party seeking a continuance of the date set for trial, whether contested or uncontested or stipulated to by the parties, must make the request for a continuance by a noticed motion or an ex parte application under the rules in chapter 4 of this division, with supporting declarations. The party must make the motion or application as soon as reasonably practical once the necessity for the continuance is discovered.”

 

“Although continuances of trials are disfavored, each request for a continuance must be considered on its own merits. The court may grant a continuance only on an affirmative showing of good cause requiring the continuance.” (Cal. Rules of Court, Rule 3.1332(c); See also In re Marriage of Falcone (2008) 164 Cal.App.4th 814, 823

(“Continuances are granted only on an affirmative showing of good cause requiring a continuance.”).)

 

Rule 3.1332(c) indicates that circumstances that may indicate good cause include “the unavailability of trial counsel because of death, illness, or other excusable circumstances,” “[a] party's excused inability to obtain essential testimony, documents, or other material evidence despite diligent efforts,” and “[a] significant, unanticipated change in the status of the case a result of which the case is not ready for trial.”

 

Other factors to consider under California Rules of Court, Rule 3.1332(d) include:

 

“(1) The proximity of the trial date;

 

(2) Whether there was any previous continuance, extension of time, or delay of trial due to any party;

 

(3) The length of the continuance requested;

 

(4) The availability of alternative means to address the problem that gave rise to the motion or application for a continuance;

 

(5) The prejudice that parties or witnesses will suffer as a result of the continuance;

 

(6) If the case is entitled to a preferential trial setting, the

reasons for that status and whether the need for a continuance outweighs the need to avoid delay;

 

(7) The court's calendar and the impact of granting a continuance on other pending trials;

 

(8) Whether trial counsel is engaged in another trial;

 

(9) Whether all parties have stipulated to a continuance;

 

(10) Whether the interests of justice are best served by a continuance, by the trial of the matter, or by imposing conditions on the continuance; and

 

(11) Any other fact or circumstance relevant to the fair determination of the motion or application.”

 

B.      Discussion

 

1.       The Parties’ Arguments

 

Plaintiff NIVO-1, LLC (“Plaintiff’) moves the Court to continue trial, the final status conference, and all other pretrial dates and deadlines. (Motion to Continue, p. 6:3–5.) Plaintiff argues that good cause exists here because it will be without competent counsel since Plaintiff’s current counsel, June Coleman, just had knee surgery and is not currently able to represent Plaintiff. (Id. at pp. 5:22–24, 6:5–7.)

 

In support of the Motion to Continue, Counsel Coleman declares: (1) that Counsel had been told for months prior to her knee surgery that she would be able to continue work part time within a couple weeks of surgery; (2) that on March 23, 2023, Counsel was told for the first time at her pre-operation appointment that she would not be able to work part time for weeks or even months; (3) that Counsel had surgery for a total knee replacement on March 29, 2023; (4) that Counsel is currently taking opioids for pain relief throughout the entire day and is on medical leave until May 12, at which point her medical status will be reevaluated; (5) that Nicole Strickler, one of the owners of Counsel’s law firm, has been unsuccessful in discussing continuances with Defense Counsel; (6) that Counsel is the only California attorney in her firm; and (7) that no attorney in Counsel’s law firm practices in the areas of law raised in this litigation. (Decl. Coleman, ¶¶ 2–4.)

 

Defendants oppose the Motion to Continue, arguing: (1) that continuances are disfavored; (2) that Plaintiff’s evidentiary showing is insufficient; (3) that Plaintiff cannot show good cause because Plaintiff’s Counsel is a competent law firm; (4) that Plaintiff’s Motion to Continue is nothing but intentional delay tactics and gamesmanship to cover up for inexcusable neglect; (5) that Plaintiff should be estopped from seeking any other trial date; (6) that a continuance would be prejudicial and cannot relieve Plaintiff of its discovery negligence; (7) that if a continuance is granted, it should be conditioned on Plaintiff’s payment of the $5,625.00 awarded on Defendants’ Motion to Expunge Lis Pendens and an extension for the discovery motion cutoff regarding Defendants’ timely propounded discovery requests. (Combined Opposition, pp. 2:19, 3:17, 6:10–11, 8:24-25, 11:2, 13:12–13, 14:22–28, 15:1–7.)

 

Plaintiff reiterates its arguments in its Reply. Plaintiff also argues: (1) that the motions should be granted based on the factors discussed in California Rules of Court, rule 3.1332(d); and (2) the judicial officer that heard the coordination petition did not reply upon the trial date but rather relied on the complexity of the cases. (Reply, pp. 6:10:3–4, 12:2–3.)

 

2.       Consideration of the Relevant Factors

 

a.       Prior Litigation Behavior

 

This Court has previously found that Plaintiff and Plaintiff’s Counsel have not acted professionally at multiple points in this litigation. For example, in its Minute Order dated August 31, 2022, the Court noted how the Court “firmly believes that Plaintiff is playing games” because the frivolous arguments made in Plaintiff’s Opposition to the Motion to Expunge Lis Pendens and the arguments Plaintiff’s Counsel made at that hearing. The Court also dismissed with prejudice of former-Plaintiff Anne Kihagi, who was determined to be a vexatious litigant and failed to post her court-ordered bond.

 

Nearly three weeks after Plaintiff’s Counsel had a total knee surgery, Plaintiff filed its Motion to Continue— which will be heard less than one month before Trial — on the grounds that Plaintiff’s Counsel is currently unable to provide competent representation due to the aforementioned knee surgery.

 

The Court continues to be concerned about Plaintiff’s actions in this matter.  Among other questions raised by these pleadings are:

 

·        When did Plaintiff’s Counsel find out she needed surgery?

·        Why was this issue not brought to the Court’s attention at the time Plaintiff’s Counsel knew she would need surgery?

·        Why did it take nearly three weeks after Plaintiff’s Counsel already had surgery for the Motion to Continue to be filed?

·        Did Counsel believe that part-time work in the month before trial would meet the professional standard of care required of her?

·        Why didn’t Plaintiff’s Counsel have a plan in place for Plaintiff’s representation in the event that she could not return to work on time?

·        Has any work been done on finding Plaintiff new counsel?

 

Further, it appears that Plaintiff has chosen not to conduct discovery and prepare for trial. According to Defense Counsel:

 

“Plaintiff has conducted no discovery in this action, at all. Plaintiff has not propounded any written discovery, conducted any non-party discovery, or taken any depositions. Nor has Plaintiff responded to Defendant’s discovery (other than tardy and barred objections), produced any documents, or appeared for deposition, despite Defendant’s timely discovery requests. [Citation omitted.] And Plaintiff has not designated any expert witness either, despite acknowledging in the coordination opposition [citation omitted] that this case involves expert testimony. Expert disclosure was due on April 12, 2023, pursuant to Defendant’s timely expert demand.” (Decl. Sahae, ¶ 5.)

 

 

b.       The Potential Prejudice to Defendants is Minimal

 

Defendants have not presented the Court with evidence to show that there would be substantial prejudice to Defendants if trial were continued.

 

c.           The Prejudice to Plaintiff of Denying a Continuance would be Enormous

 

If the Court does not continue trial, then Plaintiff will very likely lose this case because it is without an attorney.

 

Aside from narrow exceptions such as in small claims court, the California Supreme Court has long held that corporations cannot represent themselves in propria persona in court. (Merco Constr. Engineers, Inc. v. Mun. Ct. (1978) 21 Cal.3d.724, 730.)

 

Here, Defendants correctly point out that Plaintiff’s Counsel is the Messer Strickler Burnette, Ltd. law firm, of which June Coleman is only a part. However, Counsel Coleman has declared, among other things, that Counsel Coleman is the only California attorney in her firm and that no attorney in Counsel Coleman’s law firm practices in the areas of law raised in this litigation. Although Plaintiff has not explained why other members of her firm were not brought in pro hac vice prior to this point, that issue is now irrelevant.

 

Plaintiff is in a situation where it must obtain new counsel prior to Trial if it seeks to try this case. To do so less than four weeks before Trial is virtually impossible, and it is not clear to what extent it is Plaintiff’s fault that its Counsel has acted in this manner.

 

d.       There are No Prior Continuances

 

Trial is currently scheduled for May 30, 2023. This is the original trial date. No continuances have been previously granted in this case.

 

3.       There is Good Cause for a Continuance

 

Weighing the factors, the Court finds that there is good cause for a continuance. While former-Plaintiff Kihagi and Plaintiff’s Counsel may well have acted unprofessionally, it is not clear to what extent the current situation is Plaintiff NIVO-1’s fault. No prior continuances have been requested or granted, which weighs significantly in favor of allowing this continuance.

 

Given these circumstances, the Court will grant one continuance; no further continuances shall be allowed.

 

However, the Court declines to extend the discovery deadlines. Aside from Defense Counsel’s declaration, the Court does not have any evidence (much less sufficient evidence) to determine whether Plaintiff has or has not conducted discovery in this matter. More importantly, Plaintiff’s Counsel’s current medical emergency is not an excuse for Plaintiff to have failed to conduct discovery since Plaintiff filed this case more than 1½ years ago.

 

Lastly, the Court declines to condition the continuance on the payment of previously-awarded monetary sanctions.

 

 

C.      Conclusion

 

The Motion to Continue is GRANTED in part.  The trial is continued until December ___, 2023; the discovery deadlines are not extended.  There shall be no further continuances.

 

 

II.        Motion to be Relieved as Counsel

 

A.      Legal Standard

 

An attorney moving to be relieved as counsel under California Code of Civil Procedure section 284(2) must meet the requirements set out in California Rules of Court, rule 3.1362.

 

To comply with rule 3.1362, the moving party must submit the following forms: (1) Notice of Motion and Motion to be Relieved as Counsel; (2) Declaration in Support of Attorney's Motion to be Relieved as Counsel; and (3) Order Granting Attorney's Motion to be Relieved as Counsel. (Cal. Rules of Court, rule 3.1362(a), (c), (e).)

 

The moving party must serve the aforementioned forms on the client and all other parties who have appeared in the case. (Cal. Rules of Court, rule 3.1362(d).) Further, when the client is served by mail, the attorney's declaration must show that the client's address was confirmed within the last 30 days and how it was confirmed. (Id.) 

 

Absent a showing of resulting prejudice, an attorney’s request for withdrawal should be granted.  (People v. Prince (1968) 268 Cal.App.2d 398, 406.)

 

B.      Discussion

 

Counsel Coleman’s Motion to be Relieved as Counsel complies with all of the requirements of California Rules of Court, rule 3.1362, in that Counsel provided notice of motion and motion to be relieved as counsel; proposed order granting attorney’s motion to be relieved as counsel; and declaration in support of the motion to be relieved as counsel. The declaration states that Plaintiff has consented to Counsel Coleman’s withdrawal as counsel and that Counsel is currently incapable of provided competent representation due to her recent surgery. Additionally, the declaration states that Counsels’ client has been served by mail at its last known address, which was confirmed current within the past 30 days by conversation. (See Declaration, Item 3.b.(1)(c).)

 

Clearly, Plaintiff needs to be represented by counsel.  However, since the Court is continuing the trial, this issue is now moot.

 

C.      Conclusion

 

The Motion to be Relieved as Counsel is GRANTED.