Judge: Michael Shultz, Case: 23STCV01110, Date: 2025-01-21 Tentative Ruling

DEPARTMENT 40 - MICHAEL J. SHULTZ  - LAW AND MOTION RULINGS
The Court issues tentative rulings on certain motions.The tentative ruling will not become the final ruling until the hearing [see CRC 3.1308(a)(2)]. If the parties wish to submit on the tentative ruling and avoid a court appearance, all counsel must agree and choose which counsel will give notice. That counsel must 1) email Dept 40 by 8:30 a.m. on the day of the hearing (smcdept40@lacourt.org) with a copy to the other party(ies) and state that all parties will submit on the tentative ruling, and 2) serve notice of the ruling on all parties. If any party declines to submit on the tentative ruling, then no email is necessary and all parties should appear at the hearing in person or by Court Call. 




Case Number: 23STCV01110    Hearing Date: January 21, 2025    Dept: 40

23STCV01110 Karen Flores v. Everbrands, Inc., et al.

Tuesday, January 21, 2025

 

[TENTATIVE] ORDER DENYING PLAINTIFF’S MOTION TO COMPEL DEPOSITION OF YON LAI; REQUEST FOR TERMINATING SANCTIONS, OR ALTERNATIVELY FOR ISSUE AND EVIDENTIARY SANCTIONS OR MONETARY SANCTIONS

 

[TENTATIVE] ORDER DENYING PLAINTIFF’S MOTION TO COMPEL DEPOSITION OF MICHAEL FLORMAN; REQUEST FOR TERMINATING SANCTIONS, OR ALTERNATIVELY FOR ISSUE AND EVIDENTIARY SANCTIONS OR MONETARY SANCTIONS

 

 

I.        BACKGROUND      

       The complaint alleges wage and hour claims in violation of the Labor Code and a claim for unfair competition and business practices against Defendants, Everbrands, Inc., (“Everbrands”), Yon Lai (“Lai”), and Michael Florman (“Florman”), who allegedly employed Plaintiff. The individual defendants are alleged to be officers of Everbrands.

II.      ARGUMENTS

       Plaintiff argues that Lai and Florman are self-represented since their counsel withdrew. Plaintiff served Lai on September 9, 2024 by mail, with a notice to appear for deposition. His email address and telephone number were not included in the order permitting Lai’s counsel to withdraw. Lai has not responded to any letters sent by Plaintiff. Lai has a history of discovery abuse for which the court previously issued over $15,000 in sanctions against Defendants. The court should impose more severe sanctions in the form of terminating, issue or evidentiary sanctions, or alternatively monetary sanctions.

       With respect to Florman, Plaintiff also seeks terminating sanctions and other sanctions for his repeated refusal to participate in this matter. Florman also fails to respond to any of Plaintiff’s correspondence or telephone calls. His email and telephone number were not included in the order relieving former counsel. Both individual defendants have engaged in a history of discovery abuse, and monetary sanctions will not achieve the desired goal of requiring Defendants to participate in discovery.    

       Defendants Lai and Florman contend the motion is defective for numerous reasons including that they are untimely filed, Plaintiff did not meet and confer, that Plaintiff served the individual defendants at an address for a company in which Lai is a passive investor. Neither party received the deposition notice.       

       In reply, Plaintiff states the court should strike the opposition, which was prepared by counsel for Everbrands, Inc., Noel McCauley, who is not counsel for Lai or Florman. As self-represented parties, neither Lai nor Florman can seek an award of attorney’s fees incurred against Plaintiff.

III.    DISCUSSION

       The court grants Plaintiff’s motion to strike the declaration of McCauley, who does not represent Lai or Florman as McCauley concedes. (McCauley decl., ¶ 2.) The court’s file does not contain a substitution of attorney form or a limited scope representation form for either party.

       The motions are denied for procedural reasons. Plaintiff did not serve the motion on all parties. The motion regarding Lai was not served on Florman, and the motion regarding Florman was not served on Lai, however, a party may be deemed to have waived any irregularity by appearing at the hearing, opposing the motion, not asking for a continuance and not demonstrating any prejudice resulting from the defective notice. (Carlton v. Quint (2000) 77 Cal.App.4th 690, 697.)

   Notices of deposition must be served on all other parties appearing in the action. (Code Civ. Proc., § 2025.240 subd. (a).) The Notice of Florman’s Deposition was served only on Florman but not Lai and Evergreen. (Plaintiff’s Ex. 2.) The Notice of Lai’s Deposition was served only on Lai. (Plaintiff’s Notice of Errata). Florman’s opposition was served only on Plaintiff and Florman in violation of Code Civ. Proc., § 1005 (b).

       This case suffers from more fundamental defects that have not been addressed or cured by the parties. The Hon. Justice Richardson granted former counsel’s motions to be relieved as counsel for all Defendants. (M.O. 7/9/24.) However, only one signed order has been filed relieving counsel as attorney for Everbrands.  (Ord. 7/24/24.) The proposed orders relieving former counsel as to Lai and Florman received 3/28/24 are unsigned. Former counsel confirmed only the mailing address of Everbrands, but did not disclose contact information for Lai or Florman. (Decls. 3/28/24.)

       The order granting a motion to be relieved requires the clients to disclose a confirmed, current address and telephone number. (Cal. Rules of Court, Rule 3.1362.) Defendants Florman and Lai are ordered to provide written notice of their current address and telephone number to the court and all parties. Without this information, Plaintiff’s ability to meet and confer with Florman and Lai on any issue is hampered and also prevents this court from serving notices to either party to require their appearance.

IV.    CONCLUSION

       Based on the foregoing, Plaintiff’s two motions to compel the depositions of Yon Lai and Michael Florman are DENIED.