Judge: Peter A. Hernandez, Case: 23STCV18469, Date: 2025-04-30 Tentative Ruling

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Case Number: 23STCV18469    Hearing Date: April 30, 2025    Dept: 34

Plaintiffs Fountain Topco LLC and 4 Over LLC’s Motion for Leave to File a Third Amended Complaint is GRANTED.

 

Background

 

            On July 25, 2024, Plaintiffs Fountain Topco LLC and 4 Over LLC (“Plaintiffs”) filed a complaint against Defendants ACE American Insurance Company and USI Insurance Services, LLC (“Defendants”) arising from Plaintiffs’ insurance coverage with Defendants alleging causes of action for:

 

1.                 Breach of Contract;

2.                 Tortious Breach of The Implied Covenant of Good Faith and Fair Dealing;

3.                 Negligence; and

4.                 Breach Of Fiduciary Duty.

 

On September 17, 2024, Plaintiffs filed a First Amended Complaint (“FAC”) against Defendants alleging causes of action for:

 

1.                 Breach of Contract;

2.                 Tortious Breach of The Implied Covenant of Good Faith and Fair Dealing;

3.                 Negligence; and

4.                 Fraudulent Concealment.

 

On October 23, 2024, Defendant ACE American Insurance Company filed an answer to Plaintiffs’ FAC.

 

On January 22, 2025, the court sustained Defendant USI Insurance Services, LLC’s Demurrer to Plaintiffs’ fourth cause of action in the FAC with leave to amend.

On February 11, 2025, Plaintiffs filed a Second Amended Complaint (“SAC”).

 

On March 27, 2025, Plaintiffs filed this Motion to File a third amended complaint. On April 17, 2025, Defendant USI Insurance Services, LLC filed an opposition. On April 23, 2025, Plaintiffs filed a reply.

 

Legal Standard

 

Under Code of Civ. Proc. section 473, subd. (a)(1), “[t]he court may, in furtherance of justice, and on any terms as may be proper, allow a party to amend any pleading.”¿Amendment may be allowed at any time before or after commencement of trial. (Code Civ. Proc., § 576.) “[T]he court’s discretion will usually be exercised liberally to permit amendment of the pleadings. The policy favoring amendment is so strong that it is a rare case in which denial of leave to amend can be justified.” (Howard v. County of San Diego (2010) 184 Cal.App.4th 1422, 1428 (internal citations omitted).) “If the motion to amend is timely made and the granting of the motion will not prejudice the opposing party, it is error to refuse permission to amend . . .”¿ (Morgan v. Sup. Ct. (1959) 172 Cal.App.2d 527, 530.) Prejudice includes “delay in trial, loss of critical evidence, or added costs of preparation.” (Solit v. Tokai Bank, Ltd. New York Branch (1999) 68 Cal.App.4th 1435, 1448.)¿¿¿¿ 

¿¿ 

A motion to amend a pleading before trial must include a copy of the proposed amendment or amended pleading, which must be serially numbered to differentiate it from previous pleadings or amendments. (Cal. Rules of Court, rule 3.1324(a).) The motion must also state what allegations are proposed to be deleted or added, by page, paragraph, and line number.¿(Cal. Rules of Court, rule 3.1324(a).) Finally, a separate supporting declaration specifying the effect of the amendment, why the amendment is necessary and proper, when the facts giving rise to the amended allegations were discovered, and the reason the request for amendment was not made earlier must also accompany the motion. (Cal. Rules of Court, rule 3.1324(b).)¿¿¿ 

 

Discussion

 

            Plaintiffs seeks leave to file a third amended complaint to allege two additional causes of action against Defendant USI Insurance Services, LLC (“USI”) for negligent misrepresentation and fraudulent misrepresentation while also adding additional allegations to support Plaintiffs’ cause of action for fraudulent concealment. (Motion, at p. 4.) Plaintiffs note that leave to amend is liberally granted, that the amendments would not cause prejudice to Defendants as no trial date has been set, and that amendment would be in the interest of justice and judicial efficiency. (Id., at pp. 8-10.)

 

            In opposition, USI argues that this would be Plaintiffs’ fourth attempt to plead a claim warranting punitive damages. (Opp., at p. 2.) USI also argues that Plaintiffs have failed to comply with the mandatory requirements of Rule 3.1324 as Plaintiffs do not identify the edits to be made, do not specify when the facts giving rise to the amended allegations were discovered, and fail to explain why amendment was not made earlier. (Id., at pp. 3-6.)

 

            Plaintiffs comply with the requirements of Rule 3.1324 by providing a redlined copy of the third amended complaint, identifying the changes to be made, and a supporting declaration identifying why the amendment is necessary. (Appendix of Proposed Changes, at pp. 11-15; Schneider Decl., ¶¶ 7-10, Exhs. A-B.) The court also finds that any prejudice to Defendants would be minimal as no trial date has been set. Thus, Defendants will have ample time to contest the amended pleading. 

 

Accordingly, Plaintiffs’ motion is granted.

 

Conclusion

 

Plaintiffs Fountain Topco LLC and 4 Over LLC’s Motion for Leave to File a Third Amended Complaint is GRANTED.





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