Judge: Michael Shultz, Case: 22CMCV00412, Date: 2023-05-04 Tentative Ruling

Case Number: 22CMCV00412    Hearing Date: May 4, 2023    Dept: A

22CMCV00412 Private Equity Funding, Inc. v. PR Logistics, LLC, et al.

Thursday, May 4, 2023 at 8:30 a.m.

 

[TENTATIVE] ORDER SUSTAINING DEMURRER IN PART AND OVERRULING DEMURRER IN PART.

 

I.        BACKGROUND

              The first amended complaint (“FAC”) alleges that Defendants failed to pay for packaging and shipping supplies sold to Defendants totaling $42,961.54. Plaintiff alleges claims for fraud, negligence, breach of contract, and open book account.

II.      ARGUMENTS

              Defendants, PR Logistics, LLC (“Logistics”); Link Logistics Solutions, Inc. (“Link”); and ALG Worldwide (“ALG) (collectively, “the Corporate Defendants”) and Robert Reznik (“Reznick”); Julieta Colio (“Colio”; and Jenny Lepe (“Lepe”) (collectively, “individual Defendants”) demur to all causes of action. Defendants contend the fraud claims are not alleged with specificity, and the facts do not state a basis for liability against Reznick, Link, and ALG.

              Plaintiff argues that the corporate defendants are properly joined since they all transacted interchangeably with Plaintiff. The facts are specifically alleged to survive demurrer. The alter ego allegations are sufficient to state claims against corporate and individual defendants.

              In reply, Defendants contend that individual employees’ statements do not create personal guarantees on behalf of the corporate defendants. All defendants should be dismissed except PR Logistics, Inc.

III.    LEGAL STANDARDS

              The bases for demurrer are limited by statute and may be sustained for reasons including failure to state facts sufficient to state a cause of action and uncertainty. (Code Civ. Proc., § 430.10.) A demurrer “tests the sufficiency of a complaint as a matter of law and raises only questions of law.” (Schmidt v. Foundation Health (1995) 35 Cal.App.4th 1702, 1706.) The court must assume the truth of (1) the properly pleaded factual allegations; (2) facts that can be reasonably inferred from those expressly pleaded; and (3) judicially noticed matters. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) The court may not consider contentions, deductions, or conclusions of fact or law. (Moore v. Conliffe (1994) 7 Cal.4th 634, 638.)

IV.    DISCUSSION

A.      Demurrer to the claims for (1) negligent and (2) intentional misrepresentation and (4) fraud is SUSTAINED as to Link, ALG, Reznick, and Lepe.

A claim for fraud requires facts to support the following elements: (1) a mis-representation, (2) made with knowledge of its falsity, (3) Defendant intended to defraud Plaintiff, i.e., induce Plaintiff’s reliance, (4) Plaintiff justifiably relied on the misrepresentation, (5) causing damage. (Nagy v. Nagy (1989) 210 Cal.App.3d 1262, 1268.)

A claim for negligent misrepresentation requires the same elements except for the second element, which requires that the misrepresentation is made without reasonable ground for believing it to be true. (Ragland v. U.S. Bank National Assn. (2012) 209 Cal.App.4th 182, 196.) As in negligence, “the responsibility for negligent misrepresentation rests upon the existence of a legal duty, imposed by contract, statute or otherwise, owed by a defendant to the injured person. [Citation.] The determination of whether a duty exists is primarily a question of law.” (Bock v. Hansen (2014) 225 Cal.App.4th 215, 228.)

Fraud claims are subject to strict requirements of particularity in pleading. (Id.) The particularity requirements necessitate pleading facts showing “how, when, where, to whom, and by what means the representations were tendered." (Stansfield v. Starkey (1990) 220 Cal.App.3d 59, 73.) The requirement “applies not only to the alleged misrepresentation, but also to the elements of causation and damage." (Moncada v. West Coast Quartz Corp. (2013) 221 Cal.App.4th 768, 776.)

              Where fraud is alleged against a corporation, the pleading standards are even greater. Plaintiff must allege “the names of the persons who made the allegedly fraudulent representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written." (Lazar v. Superior Court (1996) 12 Cal. 4th 631, 645.)

              The fraud claims are alleged generally. The only specific allegation is made against Colio, Logistic’s director, who allegedly provided assurance and guarantee of Logistic’s financial solvency and ability to cover orders placed, and that the corporate defendants would make prompt and timely payments in the future. (FAC, ¶ 24.) Otherwise, the FAC refers to all Defendants and their alleged statements collectively and without specificity.

              The fourth cause of action for fraud is based on the same facts alleged in the first and second causes of action and are duplicative. (Award Metals, Inc. v. Superior Court (1991) 228 Cal.App.3d 1128, 1135 [stating identical allegations in two causes of action “is merely duplicative pleading which adds nothing to the complaint by way of fact or theory. For that reason, the demurrer should have been sustained”].)

 

B.      Demurrer to the alter ego allegations is OVERRULED.

              To recover on an alter ego theory, a plaintiff must allege facts to show a unity of interest and ownership and an unjust result if the corporation is treated as the sole actor.  (Leek v. Cooper (2011) 194 Cal.App.4th 399, 415.) Conclusory allegations are permitted and entitles plaintiff “to seek by discovery the facts by which that allegation might be proved.” (Los Angeles Cemetery Asso. v. Superior Court of Los Angeles County (1968) 268 Cal.App.2d 492, 494 [74 Cal.Rptr. 97].)

       Plaintiff identifies the circumstances under which the individuals are alter egos of the corporate defendants, namely, unitary control, commingling funds and assets, using assets for personal benefit, disregarding legal formalties, and inadequate capitalization among other allegations. (FAC, ¶ 11-15.) Plaintiff alleges that adherence to the fiction of separateness would sanction a fraud or promote injustice. (FAC ¶ 14.)

 

C.      Demurrer to the third cause of action for breach of contract is SUSTAINED.

               The claim for breach of contract is based on the six unpaid invoices evidencing the parties’ agreement and are adequately alleged as between Plaintiff and Coolio/Logistics. (FAC Ex. A). The elements of a claim for breach of contract are (1) the existence of a valid and existing contract between the parties, (2) Plaintiff’s performance or excuse for non-performance, (3) Defendant’s breach; and (4) resulting damage. (Richman v. Hartley (2014) 224 Cal.App.4th 1182, 1186.) A contract can be alleged either verbatim or according to its legal intendment and effect. An oral contract may be pleaded generally as to its effect, “because it is rarely possible to allege the exact words.” (Scolinos v. Kolts (1995) 37 Cal.App.4th 635, 640.) To plead a contract by its legal effect, plaintiff must “allege the substance of its relevant terms.” (Heritage Pacific Financial, LLC v. Monroy (2013) 215 Cal.App.4th 972, 993.)

              The other entity Defendants are alleged to be liable as alter egos. The claim is uncertain as to the individuals, Reznick and Lepe.

 

D.     Demurrer to the fifth cause of action for open book account is SUSTAINED.

              This claim is based on the same alleged facts that Defendants failed to pay for the six invoices. The elements of an open book account cause of action are: “1. That [plaintiff] and [defendant] had financial transactions …; [¶] 2. That [plaintiff] … kept [an] account of the debits and credits involved in the transactions; [¶] 3. That [defendant] owes [plaintiff] money on the account; and [¶] 4. The amount of money that [defendant] owes [plaintiff]. (State Comp. Ins. Fund v. ReadyLink Healthcare, Inc. (2020) 50 Cal.App.5th 422, 449.)

              This claim is adequately alleged as to Colio and Logistics, and against the other corporate defendants as alter egos. The claim is uncertain as there are no actionable facts alleged against the individuals, Reznick and Lepe.

 

V.      CONCLUSION

              If there is a reasonable possibility that the defect in a complaint can be cured by amendment, it is an abuse of discretion to sustain a demurrer without leave to amend.(Association of Community Organizations for Reform Now v. Department of Industrial Relations (1995) 41 Cal.App.4th 298, 302.) For the foregoing reasons, demurrer is SUSTAINED with 10 days leave to amend as to all causes of action and OVERRULED as to the alter ego theory of liability.