Judge: Michael Shultz, Case: 22CMCV00346, Date: 2023-06-29 Tentative Ruling

INSTRUCTIONS: If the parties wish to submit on the tentative ruling and avoid a court appearance on the matter, the moving party must:

1. Contact the opposing party and all other parties who have appeared in the action and confirm that each will submit on the tentative ruling.

2. No later than 4:00 p.m. on the court day before the hearing, call the Courtroom (310-761-4302) advising that all parties will submit on the tentative ruling and waive hearing; and

3. Serve notice of the Court's ruling on all parties entitled to receive service.

If this procedure is followed, when the case is called the Court will enter its ruling on the motion in accordance with its tentative ruling. If any party declines to submit on the tentative ruling, then no telephone call is necessary, and all parties should appear at the hearing. If there is neither a telephone call nor an appearance, then the matter may either be taken off calendar or ruled on. 

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Case Number: 22CMCV00346    Hearing Date: June 29, 2023    Dept: A

22CMCV00346 RHDM Oil, Inc. et al v. Mohummed S. Islam and Rahima Islam

Thursday, June 29, 2023 at 8:30 a.m.

 

[TENTATIVE] ORDER DENYING MOTION BY DEFENDANTS/ TO EXPUNGE LIS PENDENS BY DEFENDANT/CROSS-COMPLAINANT, MOHUMMED S. ISLAM

 

I.            BACKGROUND

The first amended complaint (“FAC”) alleges that Plaintiffs leased commercial real property from Defendant, Mohummed S. Islam (“Landlord” or “Defendant”) pursuant to a written lease agreement for use of the premises as a gas station and food mart.  Plaintiffs allege Defendant forcefully and wrongfully evicted Plaintiffs and locked them out of the premises without complying with the requirements for unlawful detainer. Defendant allegedly failed to give written notice to Plaintiffs about the sale of the premises although Plaintiffs had the contractual right to exercise an option to purchase. Plaintiffs allege claims for breach of contract, abuse of process, civil conspiracy, forcible detainer, and for declaratory relief.

On October 10, 2022, Plaintiffs filed a Notice of Pendency of Action (lis pendens) contending that the complaint affects possession of the real property at issue in the litigation.

Defendant Landlord filed a first amended cross-complaint against the tenant Plaintiffs, RHDM Oil, Inc. (“RHDM”), and Mohammed Ehtesham Ansari (“Ansari”), alleging that Cross-Defendant breached the lease agreement by failing to pay rent and taxes and engaged in fraudulent conduct.

II.            ARGUMENTS        

      Defendant Landlord moves to expunge the lis pendens as it is improper. The Plaintiffs’ complaint does not allege a real property claim, rather it asserts breach of a contractual right of first refusal in the event Defendant intended to sell the real property. It is Plaintiffs’ burden to establish a probable validity of a real property claim. The lis pendens creates a cloud on title and should be expunged to enable Landlord to sell the real property. Alternatively, the Court should exercise its discretion to require Plaintiffs to post an undertaking to compensate Defendant for damages caused by the improper lis pendens. Defendant requests attorney’s fees incurred to prepare this motion.

      In opposition, the tenant Plaintiffs argue the motion is defective as Defendant did not give required notice of the motion which results in prejudice to Plaintiffs who cannot prepare an adequate opposition. Plaintiffs contend that the FAC alleges multiple real property claims. The declaratory relief action affects Plaintiffs’ possession of the real property at issue.

      In reply, Defendant Landlord contends that Plaintiffs do not have cash for purchase of the premises. The allegations that Landlord wrongfully evicted Plaintiffs are irrelevant to Landlord’s desire to sell the property. Plaintiffs should not be allowed to interfere with the sale of the property to a third property.

III.            LEGAL STANDARDS

      Defendant untimely served the motion by email on June 7, 2023. Sixteen court days of notice is required, increased by two court days for service by email, in this case by June 2, 2023. (Code Civ. Proc., § 1005 subd. (b).) ; Code Civ. Proc., § 1010.6, subd. (a)(4)(A). However, it is well settled that a party who files an opposition on the merits, appears at the hearing, does not request a continuance, and does not demonstrate prejudice waives “any defects or irregularities in the notice of motion.” (Carlton v. Quint (2000) 77 Cal.App.4th 690, 697.) Despite insufficient notice, Plaintiffs were able to prepare an opposition which the court has considered. (Id. [“One who has been notified to attend a certain proceeding and does do so cannot be heard to complain of alleged insufficiency of the notice; it has in such instance served its purpose.”].) Plaintiffs have not demonstrated any prejudice from the defective notice. (Reedy v. Bussell (2007) 148 Cal.App.4th 1272, 1289.)

IV.             DISCUSSION

A.      The lis pendens is properly supported by real property claims.

        A lis pendens is a recorded instrument that gives constructive notice of a pending lawsuit affecting title to or possession of real property. (Code Civ. Proc., § 405.4.) The practical effect of the document is to prevent the real property’s transfer until the litigation is resolved or the lis pendens is expunged or released.  (J&A Mash & Barrel, LLC v. Superior Court of Fresno County (2022) 74 Cal.App.5th 1, 15.)

      The court shall  expunge the lis pendens if the complaint does not contain a real property claim or the claimant has not established by a preponderance of evidence the probable validity of the real property claim.  (Code Civ. Proc., §§  405.31, 405.32.) To determine whether the complaint states a real property claim, the court considers the allegations of the complaint only; no independent evidence is required. (Urez Corp. v. Superior Court (1987) 190 Cal.App.3d 1141, 1149 [“The issue is simply whether the action as pleaded is one that affects title or possession of the subject property.”]. (Id.)

      Plaintiffs have alleged a real property claim in the declaratory relief claim and the claim for forcible detainer. Plaintiffs allege that Defendant forcibly removed, evicted, and locked Plaintiffs out of the premises. (FAC, ¶ 23). A person is guilty of forcible entry, where the person enters peaceably upon real property and turns out the party in possession by force, threats, or menacing conduct. (Code Civ. Proc., § 1159). Pursuant to that section, Plaintiffs are entitled to restitution of the premises, which is the “primary remedy.”  (Allen v. McMillion (1978) 82 Cal.App.3d 211, 219.”

      Additionally, the declaratory relief claim requests damages and “any such other and further relief as the Court deems proper.” (FAC .pdf p. 16, l. 6.) Therefore, the lis pendens is supported by real property claims.

B.      Plaintiffs have met their burden of showing probable validity of their claims.

        The burden falls on Plaintiffs to establish a probable validity of the claim by a preponderance of evidence, defined as “more likely than not that plaintiff will obtain a judgment against the defendant on the claim”. (Code Civ. Proc., § 405.32.)

1)      Evidence

a)      Plaintiffs’ request for judicial  notice is granted. (Evid. Code, § 452(d).)

                        The court takes judicial notice of the court records in the unlawful detainer action: Case No. 22CMCV00220, Mohummed S. Islam (Landlord)  v. RHDM Oil, Inc., et al. (RJN, Ex. 1-4). The Hon. Michael Shultz granted the tenants’ ex parte application to vacate and set aside the default judgment entered against the Landlord, who subsequently dismissed the unlawful detainer action. (RJN, Exs. 3 and 4.)

b)      Plaintiffs’ objections to the Declaration of Defendant, Mohummed Islam.

                        #1. Paragraph 4. SUSTAIN. Lacks foundation and hearsay. Landlord does not provide any documentary evidence of all the amounts purportedly owed by Plaintiff pursuant to the lease agreement.

                        #2. Paragraphs 2-4. SUSTAINED. Irrelevant. The offers to buy the premises prepared by a commercial real estate agent and the present package for purchase is irrelevant to whether Plaintiffs can prove probable validity of the claim.

c)      Plaintiffs’ objections to the Declaration of Lorrain Anderson (Defendant’s counsel).

                  #5-7. SUSTAIN. Ms. Anderson’s efforts to convey the proposed buyer’s offer to Plaintiffs are irrelevant to the motion.

d)      Plaintiffs’ objections to the Declaration of David Yashar (Real Estate Agent).

                  #8-10. SUSTAIN. Mr. Yashar’s preparation of the offers to purchase the property is irrelevant to the motion.

2)      Plaintiffs have established the probable validity of prevailing on the claim for defendant’s breach of contract by failing to give the tenant Plaintiffs the option to buy the property.

            Pursuant to the lease, Defendant Landlord was obligated to provide Plaintiffs with express written notice that the property was available for sale. (Mot. Ex. A, ¶ 37, .pdf p. 18.) Plaintiffs declare that Defendant never informed them that one of Monem’s family members would be making an offer to purchase. Defendant did not provide Plaintiffs with express written notice of the sale as required by the lease, precluding Plaintiffs from exercising their option to purchase. (Decl., Mohammad Ansari, ¶¶ 19-20.)

            Defendant argues that the option was not sufficiently certain to be enforced since it contemplated appraisals and negotiations. (Mot., 5:24-26.)  Defendant’s case authority instructs that the first question to be decided in determining ambiguity is whether the contract language is reasonably susceptible to the interpretation urged by Plaintiffs. (Epic Communications, Inc. v. Richwave Technology, Inc. (2015) 237 Cal.App.4th 1342, 1354). Defendant has not demonstrated that the contractual obligation to provide Plaintiffs with an express written notice of sale -- which would have triggered Plaintiff’s obligations to exercise the option -- is ambiguous.

3)      Plaintiffs have established the probability of prevailing on the claim for forcible detainer under Civil Code § Code Civ. Code, §. Proc., § 1159.

            Plaintiffs declare that Defendant forcibly removed them from the premises by changing the locks and threatening Plaintiffs and their family with physical harm and financial ruin if Plaintiffs attempted to re-take control of the property. (Plaintiffs’ decl., ¶ 5). Plaintiffs were precluded from accessing the property by Defendant from July 2020 to September 8, 2022. ((Id.)., ¶ 6.) Nor has Defendant proffered any evidence addressing the unlawful detainer action in  Case No. 21CMCV00310, in which Plaintiffs assert they were never served with a notice to pay rent or quit or any other pleading in the unlawful detainer action. ((Id.)., ¶ 16.)

4)      Defendant has not persuasively argued that Plaintiffs should post an undertaking.

            Defendant requests that if expungement is denied, the Court should require Plaintiffs to post a bond to compensate Defendant for any damages which may be caused by maintaining the lis pendens. (Mot. 4:5-9.) (Code Civ. Proc., § 405.34). A court can set an amount high enough to cover damages that Defendant is likely to suffer if the lis pendens is not removed, such as carrying costs of the property or lost profits on resale. (Elder v. Carlisle Ins. Co. (1987) 193 Cal.App.3d 1313, 1319 [The undertaking “serves to protect only against damages that actually result from the nonexpungement."]; (CMSH Co. v. Antelope Development, Inc. (1990) 223 Cal.App.3d 174, 181 [“comparing the difference between the fair market value of the property at the time of the filing of the lis pendens with its fair market value at the time of its termination.”].)

            Defendant did not proffer any evidence that Plaintiffs are unlikely to prevail on any of their claims in the first instance. Nor has Defendant demonstrated why it would be just for Plaintiffs to carry the costs of the property where Plaintiffs have been barred from the property and can no longer operate the business. Additionally, Defendant has not offered any evidence to permit a determination of damages that Defendant is likely to suffer if the lis pendens is not removed. Accordingly, the alternative request is DENIED.

5)      As the prevailing party, Plaintiffs are entitled to an award of fees and costs.

            The court shall direct that the party prevailing on the motion be awarded the reasonable attorney’s fees and costs in making or opposing the motion unless the court finds that the other party acted with substantial justification or if imposing fees and costs would be unjust. (Code Civ. Proc., § 405.38.) Sanctions are awarded against the party, not counsel. (Doyle v. Superior Court (1991) 226 Cal.App.3d 1355, 1359.)

            Defendant has not established that it acted with substantial justification.  Plaintiffs’ counsel incurred fees of $6,760 (20.8 hours x $325 per hour) to review the motion and prepare the opposition, review the reply, and in anticipation of appearing at the hearing. Accordingly, the Court orders Defendant, Mohummed S. Islam, to pay $6,760 to Plaintiffs within 10 days.

V.            CONCLUSION

      Based on the foregoing, Defendant’s motion to expunge the lis pendens is DENIED. The Court awards fees and costs to Plaintiffs as described above.