Judge: Peter A. Hernandez, Case: 24STCV21653, Date: 2025-01-23 Tentative Ruling

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Case Number: 24STCV21653    Hearing Date: January 23, 2025    Dept: 34

 

1.               Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc.’s Demurrer to Plaintiff Kourosh Dayan’s Complaint is OVERRULED.

 

2.               Defendant Shaoul Levy’s Demurrer to Plaintiff Kourosh Dayan’s Complaint is OVERRULED.

 

3.               Defendant Shaoul Levy’s Motion to Strike Portions of Plaintiff Kourosh Dayan’s Complaint is DENIED.

 

Background 

 

            On August 23, 2024, Plaintiff Kourosh Dayan (“Plaintiff”) filed a complaint against Defendants Daryoush Dayan, Shaoul Levy, and 7101 Sunset Managing Member Inc. (“Defendants”) arising from ownership of commercial real estate assets alleging causes of action for:

 

1.               Breach of Fiduciary Duty; and

2.               Breach of Contract.

 

On November 12, 2024, Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc. filed this Demurrer to Plaintiff’s complaint. On January 9, 2024, Plaintiff filed an opposition.

 

On November 22, 2024 Defendant Shaoul Levy filed this Demurrer and Motion to Strike. On January 9, 2024, Plaintiff filed oppositions.

 

1.               Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc.’s Demurrer

 

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 considering demurrers, courts read the allegations liberally and in context. In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994.) “A demurrer tests the pleading alone, and not the evidence or facts alleged.” (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1315.) As such, the court assumes the truth of the complaint’s properly pleaded or implied factual allegations. (Ibid.) The only issue a demurrer is concerned with is whether the complaint, as it stands, states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.)

 

            Where a demurrer is sustained, leave to amend must be allowed where there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 348.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Id.; Lewis v. YouTube, LLC (2015) 244 Cal.App.4th 118, 226.) However, “[i]f there is any reasonable possibility that the plaintiff can state a good cause of action, it is error to sustain a demurrer without leave to amend.” (Youngman v. Nevada Irrigation Dist. (1969) 70 Cal.2d 240, 245).

 

Discussion

 

Request for Judicial Notice

 

Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc.’s request for judicial notice is granted as to exhibits A, F, and I, and denied as to all other exhibits. “A court may properly take judicial notice of its own records. (Evid. Code, § 452, subd. (e).)” (Garcia v. Sterling (1985) 176 Cal.App.3d 17, 21.)

 

Merits

 

            Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc. (“Moving Defendants”) demur, pursuant to Code of Civil Procedure section 430.10, subdivisions (e), to the first and second causes of action for breach of a fiduciary duty and breach of contract in Plaintiff’s complaint, on the basis that Plaintiff fails to state facts sufficient to constitute causes of action.

 

1st Cause of Action – Breach of Fiduciary Duty

            “The elements of a cause of action for breach of fiduciary duty are the existence of a fiduciary relationship, breach of fiduciary duty, and damages.” (Oasis West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 820.) “A fiduciary relation in law is ordinarily synonymous with a confidential relation. It is also founded upon the trust or confidence reposed by one person in the integrity and fidelity of another, and likewise precludes the idea of profit or advantage resulting from the dealings of the parties and the person in whom the confidence is reposed.” (Rickel v. Schwinn Bicycle Co. (1983) 144 Cal.App.3d 648, 654, quoting Bacon v. Soule (1912) 19 Cal.App. 428, 434.) “Traditional examples of fiduciary relationships in the commercial context include trustee/beneficiary, directors and majority shareholders of a corporation, business partners, joint adventurers, and agent/principal.” (Wolf v. Superior Court (2003) 107 Cal.App.4th 25, 30.)¿

            Moving Defendants argue that Plaintiff makes conclusory allegations that Moving Defendants Daryoush Dayan is an immediate family member. (Demurrer, at p. 11.) Moving Defendants contend that such allegations overstate the limited fiduciary duties owed to Plaintiff. (Id., at p. 12.) Moving Defendants argue that the mere existence of a close family relationship does not create a fiduciary duty. (Ibid.) Moreover, Moving Defendants contend that the only fiduciary duty owed to Plaintiff are those duties California Corporations Code section 17704.09 imposes upon the manager of a limited liability company which are limited to a duty of care and loyalty. (Id., at p. 13.) Moving Defendants also argue that Plaintiff’s allegations do not demonstrate a breach of a fiduciary duty. (Ibid.) Moving Defendants also point to Corporations Code section 17704.09(f)(3) which provides that “a member does not have any fiduciary duty to the limited liability company or to any other member solely by reason of being a member” in a manager-managed LLC. (Id., at p. 14.)

 

            In opposition, Plaintiff argues that fiduciary duties arise from the control and influence a party has over a company. (Opp., at p. 5.) Plaintiff contends that Moving Defendants do not seem to deny that they have control and influence over the companies in question imposing a fiduciary duty. (Ibid.)

 

            In the complaint, Plaintiff alleges that Defendants owed a fiduciary duty of loyalty and to act with the utmost good faith towards Plaintiff as managing members and business partners in closely held entities. (Complaint, ¶ 33.) Plaintiff also alleges that Defendants breached such duties by refusing to allow Plaintiff to exercise his rights under the operating agreement to purchase the membership interests of the companies at issue and by attempting to release the debt Defendants owe to these companies. (Id., ¶ 34.) As a result, Plaintiff suffered harm. (Id., ¶ 36.) The court finds these allegations are sufficient to plead a cause of action for a fiduciary against Moving Defendants.

           

            The demurrer is overruled as to the first cause of action.

 

2nd Cause of Action – Breach of Contract

 

            To state a cause of action for breach of contract, 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 West Realty, LLC v. Goldman (2011) 51 Cal.4th 811, 821.) 

 

            Moving Defendants argues that Plaintiff alleges the breach of the operating agreements for the corporate entities involved, and the breach of loan agreements between Defendants and the companies. (Demurrer, at p. 14.) Moving Defendants contend that Plaintiff fail to plead sufficient facts to support a claim for breach of any of these contracts. (Ibid.) As to the operating agreement, Moving Defendants argue that it is clear that the selling members are only required to transfer their interests to the purchasing member once the purchasing member delivers a cash payment. (Id., at p. 15.) As such, Moving Defendants note that the allegations establish that Plaintiff refused to make this cash payment eliminating Defendants’ obligation to transfer their interests of the corporate entities and therefore did not breach. (Ibid.) As to the loan agreements, Moving Defendants argue that Plaintiff fails to allege any facts establishing the formation of any agreement between the parties for the terms of the loans made to the companies’ members by the companies. (Ibid.)

 

            In opposition, Plaintiff argues that Moving Defendants ask the court to resolve factual issues pertaining to the breach of the operating agreements which is improper for a demurrer. (Opp., at p. 7.) Plaintiff also argues that the covenant of good faith and fair dealing imposed by the loans between the companies and Defendants provides grounds to allege the cause of action for breach of contract. (Id., at p. 8.)

 

            Plaintiff alleges that a contract exists pointing to the operating agreement and Defendants promise to repay loans provided by the corporate entities at issue. (Complaint, ¶ 39.) Plaintiff also alleges full performance. (Id., ¶ 40.) Plaintiff then alleges a breach by Defendants of bother the operating agreement and loan repayments which resulted in Plaintiff’s damage. (Id., ¶¶ 41-42.) The court finds that Plaintiff sufficiently alleges a cause of action for breach of contract. Additionally, "'[t]he hearing on demurrer may not be turned into a contested evidentiary hearing through the guise of having the court take judicial notice of documents whose truthfulness or proper interpretation are disputable.'"  (Richtek USA, Inc. v. uPI Semiconductor Corporation (2015) 242 Cal.App.4th 651, 660 (quoting Fremont Indemnity Co. v. Fremont General Corp. (2007) 148 Cal.App.4th 97, 113-14).) Moving Defendants attempt to bring forth facts for the court to determine that Plaintiff’s cause of action for breach of contract fails or that no contract existed for the repayment of the loans. Such determination is improper for a demurrer.

 

            The demurrer is overruled as to the second cause of action.                               

 

2.               Defendant Shaoul Levy’s Demurrer

 

Legal Standard

           

            See above.

 

Discussion

 

Request for Judicial Notice

 

Defendant Shaoul Levy’s request for judicial notice is granted as to exhibits A, E, G, H, I and j, and denied as to all other exhibits. “A court may properly take judicial notice of its own records. (Evid. Code, § 452, subd. (e).)” (Garcia v. Sterling (1985) 176 Cal.App.3d 17, 21.)

 

Merits

 

            Defendant Shaoul Levy (“Levy”) demurs, pursuant to Code of Civil Procedure section 430.10, subdivisions (e), to the first and second causes of action for breach of a fiduciary duty and breach of contract in Plaintiff’s complaint, on the basis that Plaintiff fails to state facts sufficient to constitute causes of action.

 

Standing

 

            Levy argues that Plaintiff lacks standing to pursue claims on behalf of the entities involved as Plaintiff has not satisfied the procedural requirements to bring a derivative suit by failing to allege demand refusal or futility. (Demurrer, at pp. 20-21.)

 

            The court does not find Levy’s argument persuasive as Plaintiff alleges that “making a demand on Defendants to approve the filing of this claim on behalf of Nominal Defendants would have been futile as Defendants themselves are guilty of breaching fiduciary duties owed to Nominal Defendants. It would thus not be reasonable to expect Defendants to have consented to a suit against themselves.” (Complaint, ¶ 35.) As such, Plaintiff has sufficiently alleged a basis for standing to bring his claims against Defendants.

           

1st Cause of Action – Breach of Fiduciary Duty

 

            Levy argues that Plaintiff fails to state a cause of action for breach of fiduciary duty as Levy is only a member of the manager-managed entities. (Demurrer, at p. 15.) As such, Levy argues that he does not owe a fiduciary duty to the other members of the corporate entities under Corporations Code section 17704.09(f)(3). (Ibid.)

 

            In opposition, Plaintiff continues to argue that fiduciary duties arise from the control and influence a party has over a company imposing a duty on Levy who has a managerial role in one of the entities at issue. (Opp., at p. 6.)

 

            The complaint alleges that Levy is a principal and director of Defendant 7101 Sunset Managing Member Inc., a Delaware corporation. (Complaint, ¶ 4.) As such, “an officer who participates in management of the corporation, exercising some discretionary authority, is a fiduciary of the corporation as a matter of law.” (GAB Business Services, Inc. v. Lindsey & Newsom Claim Services, Inc. (2000) 83 Cal.App.4th 409, 420-21, disapproved on other grounds by Reeves v. Hanlon (2004) 33 Cal.4th 1140.) The court finds that Plaintiff sufficiently pleads that Levy owed a fiduciary duty. Moreover, as analyzed above, Plaintiff sufficiently pleads a cause of action for breach of fiduciary duty.

 

            The demurrer is overruled as to the first cause of action.

 

2nd Cause of Action – Breach of Contract

 

            Levy argues that as the complaint fails to attach the complete operating agreements nor the loan agreements that were allegedly breached, Plaintiff’s breach of contract cause of action fails. (Demurrer, at p. 16.) Moreover, Levy argues that Plaintiff does not allege facts stating that he performed his own contractual obligations. (Id., at pp. 16-17.) Lastly, Levy argues that Plaintiff fails to allege facts that would establish that Levy breached the contracts at issue. (Id., at p. 19.)

 

      The court finds that Plaintiff sufficiently pleads a cause of action for breach of contract against Levy.

 

Plaintiff sufficiently alleges the existence of both the operating agreements and loan agreements at issue. 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.) Here, Plaintiff attaches the operating agreements. (Complaint, Exhs. 1, 2.) In some circumstances, a plaintiff may also “plead the legal effect of the contract rather than its precise language.” (Construction Protective Services, Inc. v. TIG Specialty Ins. Co. (2002) 29 Cal.4th 189, 198-199.) Here, Plaintiff makes such allegations as to the loan agreements to support its breach of contract claim. (Complaint, ¶¶ 21-27.)

 

Additionally, as discussed above, Plaintiff sufficiently pleads his performance of all terms required by the contract or excused. (Id., ¶ 40.) Plaintiff also pleads Defendants breach, including Levy’s breach, of both alleged contracts at issue. (Id., ¶ 41.)

 

            The demurrer is overruled as to the second cause of action.

           

3.               Defendant Shaoul Levy’s Motion to Strike

 

Legal Standard

 

Pursuant to Code of Civil Procedure section 436, “the court may, upon a motion made pursuant to Section 435, or at any time in its discretion, and upon terms it deems proper: (a) Strike out any irrelevant, false, or improper matter inserted in any pleading. (b) Strike out all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court.” The grounds for a motion to strike must “appear on the face of the challenged pleading or from any matter of which the court is required to take judicial notice.” (Code Civ. Proc., § 437.)

 

Discussion 

 

Punitive Damages

 

            Levy moves the court to strike Plaintiff’s request for punitive damages.

 

            Punitive damages may be recovered upon a proper showing of malice, fraud, or oppression. (Civ. Code, § 3294(a).) “Malice” is defined as conduct intended to cause injury to a person or despicable conduct carried on with a willful and conscious disregard for the rights or safety of others. (Turman v. Turning Point of Cent. Cal., Inc. (2010) 191 Cal.App.4th 53, 63.) “Oppression” means despicable conduct subjecting a person to cruel and unjust hardship, in conscious disregard of the person’s rights. (Ibid.) “Fraud” is an intentional misrepresentation, deceit, or concealment of a material fact known by defendant, with intent to deprive a person of property, rights or otherwise cause injury. (Ibid.) Conclusory allegations, devoid of any factual assertions, are insufficient to support a conclusion that parties acted with oppression, fraud, or malice. (Smith v. Superior Court (1992) 10 Cal.App.4th 1033, 1042.)

 

“In order to survive a motion to strike an allegation of punitive damages, the ultimate facts showing an entitlement to such relief must be pled by a plaintiff.” (Clauson v. Superior Court (1998) 67 Cal.App.4th 1253, 1255.) “In passing on the correctness of a ruling on a motion to strike, judges read allegations of a pleading subject to a motion to strike as a whole, all parts in their context, and assume their truth.” (Ibid.) “In ruling on a motion to strike, courts do not read allegations in isolation.” (Ibid.) Conclusory allegations, devoid of any factual assertions, are insufficient to support a conclusion that parties acted with oppression, fraud or malice. (Smith v. Superior Court (1992) 10 Cal.App.4th 1033, 1042.)

            Levy argues that Plaintiff fails to allege facts demonstrating that Levy is guilty of oppression, fraud, or malice and instead makes conclusory allegations. (Motion to Strike, at p. 6.)

In opposition, Plaintiff argues that the complaint has sufficiently pled how Defendants acted with malice and oppression throughout the complaint. (Opp., at p. 2.)

The court finds that Plaintiff made sufficient allegations for his request of punitive damages as Plaintiff alleges that Defendants Daryoush Dayan and Levy made conscious efforts to frustrate the sale of their interest in the entities to Plaintiff. (Complaint, ¶¶ 28-31.)

The motion to strike is denied.

Attorney’s Fees

 

            Levy moves the court to strike Plaintiff’s request for attorney’s fees.

 

            Attorney’s fees are recoverable only when authorized by contract, statute, or law. (Code Civ. Proc. § 1033.5, subd. (a)(10).)

           

            Levy argues that Plaintiff does not identify any contractual or statutory basis under which Plaintiff could recover his attorney’s fees as none of the contract attached to the complaint contains an attorney’s fees provision. (Motion to Strike, at p. 7.)

            In opposition, Plaintiff argues that the operating agreements which were subject to the court’s judicial notice show an attorney’s fees provision in paragraphs 6.2. (Opp., at p. 3.) Additionally, Plaintiff argues that there are multiple statutory basis to recover attorney’s fees, including shareholder derivative actions. (Ibid.)

 

            After a review of the judicially noticed operating agreements in Levy’s request for judicial notice, the court finds that there is a provision that would entitle Plaintiff to recover attorney’s fees. (RJN, Exhs. A and E, ¶ 6.2)

 

The motion to strike is denied.

Conclusion

 

1.               Defendants Daryoush Dayan and 7101 Sunset Managing Member Inc.’s Demurrer to Plaintiff Kourosh Dayan’s Complaint is OVERRULED.

 

2.               Defendant Shaoul Levy’s Demurrer to Plaintiff Kourosh Dayan’s Complaint is OVERRULED.

 

3.               Defendant Shaoul Levy’s Motion to Strike Portions of Plaintiff Kourosh Dayan’s Complaint is DENIED.