Judge: Michael P. Linfield, Case: 23STCV21399, Date: 2024-01-17 Tentative Ruling

Case Number: 23STCV21399    Hearing Date: January 17, 2024    Dept: 34

SUBJECT:        Demurrer to the Complaint

 

Moving Party: Defendants Band of Outlaws and Renee Mytar

Resp. Party:    Plaintiff Runway Fash Inc.

                                   

       

The Demurrer is OVERRULED.

 

BACKGROUND:

 

On September 6, 2023, Plaintiff Runway Fash Inc. filed its Complaint against Defendants Band of Outlaws, Renee Mytar, and Alan Luu on causes of action arising from the Parties’ business relationships.

 

On November 3, 2023, Defendant Alan Luu filed an Answer to the Complaint.

 

On December 1, 2023, Defendants Band of Outlaws and Renee Mytar (“Defendants”) filed their Demurrer to the Complaint.

 

On December 13, 2023, Plaintiff filed its Opposition to the Demurrer.

 

On December 19, 2023, Defendants filed their Reply to the Demurrer.

 

ANALYSIS:

 

I.          Legal Standard

 

“The party against whom a complaint or cross-complaint has been filed may object, by demurrer or answer as provided in Section 430.30, to the pleading on any one or more of” various grounds listed in statute. (Code Civ. Proc., § 430.10.)

 

“When any ground for objection to a complaint, cross-complaint, or answer appears on the face thereof, or from any matter of which the court is required to or may take judicial notice, the objection on that ground may be taken by a demurrer to the pleading.” (Code Civ. Proc., § 430.30, subd. (a).)

 

“A demurrer to a complaint or cross-complaint may be taken to the whole complaint or cross-complaint or to any of the causes of action stated therein.” (Code Civ. Proc., § 430.50, subd. (a).)

 

“In reviewing the sufficiency of a complaint against a general demurrer, we are guided by long-settled rules. We treat the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law. We also consider matters which may be judicially noticed. Further, we give the complaint a reasonable interpretation, reading it as a whole and its parts in their context.” (Blank v. Kirwan (1985) 39 Cal.3d 311, 318, citations and internal quotation marks omitted.)

 

II.       Discussion

 

Defendants demur to the entire Complaint, as well as to each of the twelve causes of action within it.

 

A.      Demur to the Entire Complaint

 

1.      Legal Standard

 

“The party against whom a complaint or cross-complaint has been filed may object, by demurrer or answer as provided in Section 430.30, to the pleading on any one or more of the following grounds:

 

. . .

 

“(e)¿The pleading does not state facts sufficient to constitute a cause of action.

 

“(f)¿The pleading is uncertain. As used in this subdivision, ‘uncertain’ includes ambiguous and unintelligible.”

 

(Code Civ. Proc., 430.10, subds. (e)–(f).)

 

2.      Discussion

 

Defendants demur to the entire Complaint, arguing that it is uncertain and does not allege the facts upon which relief can be granted. (Demurrer, p. 10:8–9.)

 

        The Court disagrees with this argument. The Complaint is sufficiently certain, unambiguous and intelligible, and sufficiently alleges facts upon which relief can be granted.

 

        The Court OVERRULES the Demurrer to the entire Complaint.

 

B.      First Through Fifth Causes of Action — Breach of Contract

 

1.      Legal Standard

 

To state a cause of action for breach of contract, a plaintiff must be able to establish “(1) the existence of the contract, (2) plaintiff’s performance or excuse for nonperformance, (3) defendant’s breach, and (4) the resulting damages to the plaintiff.” (Oasis W. Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 821.)

 

If a breach of contract claim “is based on alleged breach of a written contract, the terms must be set out verbatim in the body of the complaint or a copy of the written agreement must be attached and incorporated by reference.” (Harris v. Rudin, Richman & Appel (1999) 74 Cal.App.4th 299, 307.)

 

“In an action based on a written contract, a plaintiff may plead the legal effect of the contract rather than its precise language.” (Constr. Protection Servs., Inc. v. TIG Specialty Ins. Co. (2002) 29 Cal.4th 189, 198–199.)

 

2.      Discussion

 

Defendants demur to the first five causes of action for breach of action, arguing: (1) that the first four of these causes of action do not succeed because the Parties’ agreement from 2023 contains an integration clause; and (2) that the fifth cause of action for breach of contract does not succeed because Exhibit 6 attached to the Complaint shows that Plaintiff did not perform under their agreement from 2023. (Demurrer, pp. 13:23–24, 14:25–26.)

 

        Among other things, Plaintiff alleges: (1) that the Parties have multiple contracts; (2) that Plaintiff performed under the contracts; (3) that Defendants breached the contracts; and (4) that Plaintiff was harmed because of those breaches. (Complaint, ¶¶ 12–39.)

 

        The pleading sufficiently alleges each of the elements for the causes of action for breach of contract. Moreover, on a demurrer, the Court must assume the truth of the allegations. Disputes over facts or mixed questions of fact and law, such as whether Plaintiff actually performed under the relevant contract(s), are inappropriate for resolution on a demurrer.

 

        The Court OVERRULES the Demurrer to the first five causes of action for breach of contract.

 

C.          Sixth Cause of Action — Breach of the Implied Covenant of Good Faith and Fair Dealing

 

1.      Legal Standard

 

“A breach of the implied covenant of good faith and fair dealing involves something beyond breach of the contractual duty itself and it has been held that bad faith implies unfair dealing rather than mistaken judgment.” (Careau & Co. v. Sec. Pac. Bus. Credit, Inc. (1990) 222 Cal.App.3d 1371, 1394.)

 

“If the allegations do not go beyond the statement of a mere contract breach and, relying on the same alleged acts, simply seek the same damages or other relief already claimed in a companion contract cause of action, they may be disregarded as superfluous as no additional claim is actually stated. . . . [T]he only justification for asserting a separate cause of action for breach of the implied covenant is to obtain a tort recovery.” (Careau & Co., supra, at pp. 1394–1395.)

 

To recover in tort for breach of the implied covenant, the defendant must “have acted unreasonably or without proper cause.” (Careau & Co., supra, at p. 1395, citations and italics omitted.)

 

2.      Discussion

 

Defendants demur to the sixth cause of action for breach of implied covenant of good faith and fair dealing, arguing: (1) that this cause of action must fail because the breach of contract causes of action failed; and (2) that this cause of action must fail because it is duplicative of the breach of contract causes of action. (Demurrer, p. 16:4–8.)

 

The Court disagrees with these arguments.

 

First, the predicate for Defendants’ first argument is missing, because the Court overruled the Demurrer to the breach of contract causes of action.

 

Second, a cause of action for breach of implied covenant of good faith and fair dealing is not duplicative of a cause of action for breach of contract. Even if it were,[t]he court must, in every stage of an action, disregard any error, improper ruling, instruction, or defect, in the pleadings and proceedings which, in the opinion of said court, does not affect the substantial rights of the parties. . . .”¿ (Code Civ. Proc., § 475.)

 

The Court OVERRULES the Demurrer to the sixth cause of action for breach of implied covenant of good faith and fair dealing.

 

D.      Seventh Cause of Action — Fraud

 

1.      Legal Standard

 

“The elements of fraud are (a) a misrepresentation (false representation, concealment, or nondisclosure); (b) scienter or knowledge of its falsity; (c) intent to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Hinesley v. Oakshade Town Ctr. (2005) 135 Cal.App.4th 289, 294.)

 

The elements of a cause of action for negligent misrepresentation include “[m]isrepresentation of a past or existing material fact, without reasonable ground for believing it to be true, and with intent to induce another’s reliance on the fact misrepresented; ignorance of the truth and justifiable reliance on the misrepresentation by the party to whom it was directed; and resulting damage.” (Hydro-Mill Co., Inc. v. Hayward, Tilton & Rolapp Ins. Associates, Inc. (2004) 115 Cal.App.4th 1145, 1154, quotation marks omitted.)

 

The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Super. Ct. (1996) 12 Cal.4th 631, 645.)

 

To properly allege fraud against a corporation, the plaintiff must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

 

2.      Discussion

 

Defendants demur to the seventh cause of action for fraud, arguing: (1) that the allegations do not meet the heightened pleading requirements for a cause of action for fraud; and (2) that the allegations are actually breach of contract allegations that have morphed into fraud allegations. (Demurrer, p. 17:3–5.)

 

Plaintiff alleges: (1) that Defendants made representations to Plaintiff, including representations about that certain funds would be used to perform marketing work; (2) that these representations were not true as Defendants used the funds in other ways, such as by embezzling at least $55,800.00 of the advertising budget; (3) that these representations were made with the intent to defraud Plaintiff; (4) that when Defendants made these representations, they knew them to be false; (5) that Defendants made these representations to induce Plaintiff to act in reliance on these representations; (6) that at the time these representations were made by Defendants, Plaintiff did not know they were false and Plaintiff thus relied on those representations; and (7) that Plaintiff was harmed by its reliance on the intentional misrepresentations. (Complaint, ¶¶ 47–52.)

 

The pleading sufficiently alleges each of the elements of a cause of action for fraud and meets the heightened pleading requirements for this cause of action.

 

Further, this cause of action is not a mere restatement of the cause of action for breach of contract. Even if it were, such pleading does not affect the substantial rights of the Parties and thus must be ignored on a demurrer. (Code Civ. Proc., § 475.)

 

        The Court OVERRULES the Demurrer to the seventh cause of action for fraud.

 

E.          Eighth and Ninths Cause of Action — Intentional Interference with Prospective Economic Relations and Negligent Interference with Prospective Economic Relations

 

1.      Legal Standard

 

The elements of a claim for intentional interference with prospective economic advantage include “(1) an economic relationship between the plaintiff and some third party, with the probability of future economic benefit to the plaintiff; (2) the defendant’s knowledge of the relationship; (3) intentional or negligent acts on the part of the defendant designed to disrupt the relationship; (4) actual disruption of the relationship; and (5) economic harm to the plaintiff proximately caused by the acts of the defendant.” (Crown Imports, LLC v. Super. Ct. (2014) 223 Cal.App.4th 1395, 1404, citations, brackets, and quotation marks omitted.)

 

Further, “the alleged interference must have been wrongful by some measure beyond the fact of the interference itself. For an act to be sufficiently independently wrongful, it must be unlawful, that is, it is proscribed by some constitutional, statutory, regulatory, common law, or other determinable legal standard.” (Crown Imports, LLC, supra, at p. 1404, citation, ellipsis, and quotation marks omitted.)

 

“[A]n actor’s breach of contract, without more, is not ‘wrongful conduct’ capable of supporting a tort, including the tort of intentional interference with a prospective economic advantage.” (Drink Tank Ventures LLC v. Real Soda in Real Bottles, Ltd. (2021) 71 Cal.App.5th 528, 533, citations omitted.)

 

2.      Discussion

 

Defendants demur to the eighth cause of action for intentional interference with prospective economic relations (which is also known as intentional interference with prospective economic advantage), arguing that Plaintiff has not identified a specific third party with whom Plaintiff had an existing economic relationship. (Demurrer, p. 17:10–12.)

 

Defendants also demur to this cause of action, as well as to the ninth cause of action for negligent interference with prospective economic relations, on the basis that Plaintiff has not alleged actions that were independently wrongful. (Demurrer, p. 18:6–8.)

 

        Plaintiff opposes the Demurrer, arguing: (1) that this information is within Defendants’ knowledge since they destroyed and/or prevented access to Plaintiff’s data, including Plaintiff’s historical data in marketing to certain target clients; (2) that Plaintiff has listed eight specific instances of how Defendants interfered with Plaintiff’s economic relations; (3) that Plaintiff need not provide more particularity than it already has; and (4) that Plaintiff has pleaded independent wrongs, such as violation of the unfair competition law and conversion. (Opposition, p. 15:13–26.)

 

        The Court disagrees with Defendants’ arguments.

 

        First, Plaintiff has alleged various independent wrongs, such as fraud and conversion.

 

        Second, Plaintiff alleges inter alia that it “had numerous economic relationships with its customers and clients that probably would have resulted in significant economic benefits to Plaintiff.” (Complaint, ¶ 55.)

 

Although this allegation does not include any names of third parties or provide more information that would help the Court determine whether there is actually a probability of future economic benefit to Plaintiff, the Court must assume the truth of the allegation for the purposes of a demurrer. The Parties have not made the Court aware of any case law that requires the identification of such third parties and the prospective economic advantage in the Complaint at the demurrer stage. Of course, it will ultimately be Plaintiff’s burden to show these items in order to obtain the relief it seeks.

 

The Court OVERRULES the Demurrer to the eighth cause of action for intentional interference with prospective economic relations and the ninth cause of action for negligent interference with prospective economic relations.

 

F.       Tenth Cause of Action — Defamation Per Se

 

1.      Legal Standard

 

“Defamation is effected by either of the following: (a) Libel. (b) Slander.” (Civ. Code, § 44.)

 

“Libel is a false and unprivileged publication by writing, printing, picture, effigy, or other fixed representation to the eye, which exposes any person to hatred, contempt, ridicule, or obloquy, or which causes him to be shunned or avoided, or which has a tendency to injure him in his occupation.” (Civ. Code, § 45.)

 

“A libel which is defamatory of the plaintiff without the necessity of explanatory matter, such as an inducement, innuendo or other extrinsic fact, is said to be a libel on its face. Defamatory language not libelous on its face is not actionable unless the plaintiff alleges and proves that he has suffered special damage as a proximate result thereof. Special damage is defined in Section 48a of this code.” (Civ. Code, § 45a.)

 

“Slander is a false and unprivileged publication, orally uttered, and also communications by radio or any mechanical or other means which:

 

“1. Charges any person with crime, or with having been indicted, convicted, or punished for crime;

 

“2. Imputes in him the present existence of an infectious, contagious, or loathsome disease;

 

“3. Tends directly to injure him in respect to his office, profession, trade or business, either by imputing to him general disqualification in those respects which the office or other occupation peculiarly requires, or by imputing something with reference to his office, profession, trade, or business that has a natural tendency to lessen its profits;

 

“4. Imputes to him impotence or a want of chastity; or

 

“5. Which, by natural consequence, causes actual damage.”

 

(Civ. Code, § 46.)

 

“‘The sine qua non of recovery for defamation . . . is the existence of falsehood.’ Because the statement must contain a provable falsehood, courts distinguish between statements of fact and statements of opinion¿for purposes of defamation liability.¿Although statements of fact may be actionable as libel, statements of opinion are constitutionally protected.” (McGarry v. Univ. of San Diego (2007) 154 Cla.App.4th 97, 112, quoting Letter Carriers v. Austin (1974) 418 U.S. 264, 283.)

 

“[T]he question is not strictly whether the published statement is fact or opinion. Rather, the dispositive question is whether a reasonable fact finder could conclude the published statement declares or implies a provably false assertion of fact.” (Franklin v. Dynamic Details, Inc. (2004) 116 Cal.App.4th 375, 385, citations omitted.)

 

“Whether a statement declares or implies a provable false assertion of fact is a question of law for the court to decide, unless the statement is susceptible of both an innocent and a libelous meaning, in which case the jury must decide how the statement was understood.” (Franklin, supra, at p. 385, citations omitted.)

 

“To determine whether a statement is actionable fact or nonactionable opinion, we apply a totality of the circumstances test pursuant to which we consider both the language of the statement itself and the context in which it is made.” (Summit Bank v. Rogers (2012) 206 Cal.App.4th 669, 696, citation omitted.)

 

“In an action for defamation per se, the meaning is so clear from the face of the statement that the damages can be presumed. However, that presumption does not mean [a plaintiff] does not anticipate injury; nor does it mean there is no injury.” (Tilkey v. Allstate Ins. Co. (2020) 56 Cal.App.5th 521, 542, citation omitted.)

 

“Defamation requires both falsity and injury to reputation; the defamation per se analysis focuses on the latter, and even if context is necessary to show falsity it might not be needed for reputational harm. But a harmful meaning must still be clear to constitute defamation per se.” (Balla v. Hall (2021) 59 Cal.App.5th 652, 690, citations omitted.)

 

2.      Discussion

 

Defendants demur to the tenth cause of action for defamation per se, arguing: (1) that there was no defamation for the alleged slander because Plaintiff actually had not paid money owed to Defendants and was in default under the terms of their contract; (2) that, pursuant to Civil Code section 47, subdivision (c), this statement is privileged if made without malice; and (3) that there is no allegation that the purported defamatory statement was made with actual malice. (Demurrer, p. 19:15–24.)

 

The Court disagrees with Defendants’ arguments.

 

First, among other things, Plaintiff alleges: (1) that Defendants told Third Party Song Kim that Plaintiff failed to pay monies to Defendants regarding Third Party Song Kim’s services performed for the benefit of Plaintiff; (2) that these representations were false as Plaintiff did pay Defendants the fees associated with Third Party Song Kim’s services; and (3) that this defamatory conduct was malicious. (Complaint, ¶¶ 65–69.) The Court must assume the truth of the pleadings, and the pleadings contain sufficient allegations for a trier of fact to find that all the elements of defamation per se are present. (Civ. Code, §§ 45, 45a, 46.) Specifically, if false, the libel and/or slander alleged could be found by a trier of fact to injure Plaintiff in its occupation or have a natural tendency to lessen its profits. (Ibid.) Whether the allegation is true or false is a factual question inappropriate for determination on a demurrer.

 

“A privilege publication or broadcast is one made: . . . In a communication, without malice, to a person interested therein, (1) by one who is also interested, or (2) by one who stands in such a relation to the person interested as to afford a reasonable ground for supposing the motive for the communication to be innocent, or (3) who is requested by the person interested to give the information. . . .”  (Civil Code §47(c).)

 

        This portion of the subdivision has remained intact for decades. The omitted, latter portion of the subdivision discusses instances of employment, which merely clarify how the subdivision works in certain employment situations. However, the subdivision has always involved communications broader than just employment matters.

 

“Civil Code section 47, subdivision (c) codifies the common law privilege of common interest, which protected communications made in good faith on a subject in which the speaker and hearer shared an interest or duty. This privilege applied to a narrow range of private interests. The interest protected was private or pecuniary; the relationship between the parties was close, e.g., a family, business, or organizational interest; and the request for information must have been in the course of the relationship. . . . One authority explains the statutory interest as follows: (1) The ‘interest’ applies to a defendant who is protecting his own pecuniary or proprietary interest. (2) The required ‘relation’ between the parties to the communication is a contractual, business or similar relationship, such as between partners, corporate officers and members of incorporated associations, or between union members and union officers. (3) The request referred to must have been in the course of a business or professional relationship.

 

“This definition is not exclusive, however, and the cases have taken an ‘eclectic approach’ toward interpreting the statute. The lesson we deduce from these cases is that the scope of the privilege under section 47, subdivision 3 [now subd. (c)] is not capable of precise or categorical definition, and that its application in a particular case depends upon an evaluation of the competing interests which defamation law and the privilege are designed to serve.

 

“The common interest privilege is usually described as a qualified or conditional one, meaning it can be overcome by a showing of malice. But, this characterization is somewhat misleading. Section 47(3) [now § 47, subd. (c)] defines a privileged communication as one made without malice. Thus, if malice is shown, the privilege is not merely overcome; it never arises in the first instance. Malice for purposes of the statute means a state of mind arising from hatred or ill will, evidencing a willingness to vex, annoy or injure another person. Malice is not inferred from the communication. (Civ. Code, § 48.)

 

Application of the privilege involves a two-step analysis. The defendant has the initial burden of showing the allegedly defamatory statement was made on a privileged occasion, whereupon the burden shifts to the plaintiff to show the defendant made the statement with malice. The existence of the privilege is ordinarily a question of law for the court.”  (Kashian v. Harriman (2002) 98 Cal.App.4th 892, 914–915 [cleaned up].)

 

        Here, the Complaint does not contain many details about the context in which the allegedly false and defamatory publication was made or the type of business relationship between the Parties and third parties. Rather, the pleading only contains the allegation that Defendants “told [Third Party] Kim that, Plaintiff failed to pay monies to [Defendant] Band of Outlaws and as a result, [Defendants] could not pay [Third Party] Kim for his digital marketing services that he performed for the benefit of Plaintiff under the 2023 Agreement.” (Complaint, ¶ 65.)

 

        Based on these limited allegations, it does not appear that there was a close business relationship between Defendants and Third Party Song Kim — at least not of the type envisioned by Civil Code section 47, subdivision (c). Without such a sharing of “interest” as that term is used in subdivision (c), there is no litigation privilege. (Kashian, supra, 98 Cal.App.4th at pp. 914–915.)

 

        Finally, as to malice, it is not a requirement of defamation for there to be malice. Rather, as discussed in the paragraphs above about the litigation privilege, the presence of malice would mean the litigation privilege never arises in the first place. (Kashian, supra, 98 Cal.App.4th at p. 915.) Because Plaintiff has alleged that Defendants’ allegedly defamatory conduct was malicious and the Court must assume the truth of this allegation, the Court must overrule the Demurrer on the basis of litigation privilege pursuant to Civil Code section 47, subdivision (c). (Complaint, ¶ 69.)

 

        The Court OVERRULES the Demurrer to the tenth cause of action for defamation per se.

 

G.         Eleventh Cause of Action — Violation of Business and Professions Code Section 17200

 

1.      Legal Standard

 

“As used in this chapter, unfair competition shall mean and include any unlawful, unfair or fraudulent business act or practice and unfair, deceptive, untrue or misleading advertising and any act prohibited by Chapter 1 (commencing with Section 17500) of Part 3 of Division 7 of the Business and Professions Code.” (Bus. & Prof. Code, § 17200.)

 

2.      Discussion

 

Defendants demur to the eleventh cause of action for violation of Business and Professions Code section 17200 (also known as the “unfair competition law” or the “UCL”), arguing: (1) Plaintiff does not allege an independent statute, regulation, or law of which Defendants are in violation; (2) that Plaintiff does not meet the unlawful prong; (3) that Plaintiff does not meet the unfair prong; and (4) that Plaintiff does not meet the fraudulent prong. (Demurrer, pp. 20:20, 21:1–3, 21:20.)

 

        The Court disagrees with Defendants’ arguments.

 

        Plaintiff has alleged that Defendants engaged in outright fraud, unfair conduct (e.g., embezzling funds meant for social media campaigns), and unlawful conduct (e.g., defamation per se, fraud, etc.) These allegations are sufficient for the eleventh cause of action to withstand demur.

 

        The Court OVERRULES the Demurrer to the eleventh cause of action for violation of the UCL.

 

H.      Twelfth Cause of Action — Conversion

 

1.      Legal Standard

 

“Conversion is the wrongful exercise of dominion over the property of another. The elements of a conversion claim are: (1) the plaintiff’s ownership or right to possession of the property; (2) the defendant’s conversion by a wrongful act or disposition of property rights; and (3) damages.” (Lee v. Hanley (2015) 61 Cal.4th 1225, 1240.)

 

“It is not necessary that there be a manual taking of the property; it is only necessary to show an assumption of control or ownership over the property, or that the alleged converter has applied the property to his own use. Money can be the subject of an action for conversion if a specific sum capable of identification is involved. Neither legal title nor absolute ownership of the property is necessary. A party need only allege it is entitled to immediate possession at the time of conversion. However, a mere contractual right of payment, without more, will not suffice.” (Farmers Ins. Exch. v. Zerin (1997) 53 Cal.App.4th 445, 451–52 [cleaned up].)

 

2.      Discussion

 

Defendants demur to the twelfth cause of action for conversion, arguing: (1) that Plaintiff did not have the right to the accounts at issue; (2) that Defendants had a contractual right to withhold transferring ownership if Plaintiff did not pay its invoices; and (3) that Plaintiff’s allegations that Defendants stole Plaintiff’s accounts, applications, and budgets are unintelligible, ambiguous, and contradicted by evidence attached to the Complaint itself. (Demurrer, pp. 22:15–21, 23:3–8.)

 

The Court disagrees with Defendants’ arguments.

 

Among other things, Plaintiff alleges: (1) that Plaintiff possessed or had a right to possess multiple, specifically-listed accounts, applications, budgets, service fees, and refund amounts; (2) that Defendants substantially interfered with Plaintiff’s property by knowingly or intentionally preventing Plaintiff from having access to specifically-listed accounts and applications; (3) that Defendants wrongfully took possession of Plaintiff’s specifically-listed budgets, service fees, and refund amounts; (4) that Plaintiff did not consent to Defendants’ conduct; (5) that Plaintiff was harmed by Defendants’ conduct; and (6) that Defendants’ conduct was a substantial factor in causing Plaintiff harm. (Complaint, ¶¶ 77–81.)

 

The pleading sufficiently alleges all of the elements for a cause of action of conversion, and the allegations cross well beyond issues with “a mere contractual right of payment.” (Farmers, supra, 53 Cal.App.4th at pp. 451–452.) Further, as previously stated, the pleading is sufficiently intelligible and unambiguous, and the Court must assume the truth of the allegations made.

 

The Court OVERRULES the Demurrer to the twelfth cause of action for conversion.

 

III.     Conclusion

 

The Demurrer is OVERRULED.