Judge: Randy Rhodes, Case: 21CHCV00637, Date: 2022-12-21 Tentative Ruling

Case Number: 21CHCV00637    Hearing Date: December 21, 2022    Dept: F51

Dept. F-51  

Date: 12/21/22                                                                

Case #21CHCV00637

 

SUMMARY JUDGMENT

 

Motion filed on 8/19/22.   

 

MOVING PARTY: Defendant/Cross-Complainant Devonshire Reseda, LLC (“Defendant”)

RESPONDING PARTY: Plaintiff/Cross-Defendant Fitness International, LLC (“Plaintiff”)

NOTICE: ok 

 

RELIEF REQUESTED: An order granting summary judgment in favor of Defendant/Cross-Complainant Devonshire Reseda, LLC, and against Plaintiff/Cross-Defendant Fitness International LLC.

 

TENTATIVE RULING: Defendant’s motion for summary judgment is granted. 

  

REQUEST FOR JUDICIAL NOTICE

Defendant’s Request for Judicial Notice (RJN) is granted as to Exhibits 1–13. Defendant’s RJN is denied as to Exhibits 14–15.

 

Plaintiff’s RJN is granted as to Exhibits 1–42 and 47, and denied as to Exhibits 43–44 and 48–51. Defendant’s objections to Plaintiff’s RJN Exhibits 43–44 and 48–51are sustained. Defendant’s objection to Plaintiff’s RJN Exhibit 47 is overruled.

 

EVIDENTIARY OBJECTIONS

Plaintiff’s evidentiary objections, numbers 4–5, to the declaration of Brent Sherman are sustained.

Plaintiff’s evidentiary objections, numbers 27–28, to the declaration of Holly Tartaglino are sustained.

Defendant’s evidentiary objections, numbers 4–6 and 11, to the declaration of Greg Gill are sustained.

Defendant’s evidentiary objections, numbers 6–21, 26, 30, 32–33, and 37–40, to the declaration of Diann D. Alexander are sustained.

 

BACKGROUND

Plaintiff leases certain real property from Defendant for the operation of a fitness center located at 18679 Devonshire St., Northridge. On 3/12/20, Governor Newsom issued the “Safer at Home” order, thereby preventing the operation of businesses, such as Plaintiff, from allowing paying members to utilize the facilities. Notwithstanding a brief reopening period from 6/12/20 to 7/13/20, the facility was barred from allowing customers into the facility until 3/15/21, with limited entrance beginning on that date, until full access restoration on 6/15/21.

Plaintiff did not pay the rent due under its lease for the months of April, May, and June 2020, and on 6/12/20 the parties amended the lease to defer a portion of the rent due, on the condition that Plaintiff not commit any further monetary defaults. Plaintiff paid Defendant pursuant to the amended agreement. After the facility was closed again in July 2020, Plaintiff did not resume its payment of rent until reopening in March 2021. With this action, Plaintiff seeks to recover the rent it paid for the months that the facility was closed and declare those rent payments as excused given the impacts to operations due to the government shutdown orders. 

On 8/20/21, Plaintiff filed its complaint, alleging against Defendant the following causes of action: (1) Breach of Written Contract (Lease) – Force Majeure; (2) Breach of Written Contract (Lease) – Representations, Warranties & Covenants; (3) Common Count – Monies Had and Received; (4) Common Count – Monies Paid By Mistake; (5) Common Count – Monies Paid and Expended; (6) Declaratory Relief – Closure Period; and (7) Declaratory Relief – Ongoing Restrictions.

On 10/4/21, Defendant filed its cross-complaint against Plaintiff for Breach of Contract.

On 8/19/22, Defendant filed the instant motion for summary judgment (“MSJ”) and RJN. On 10/19/22, Plaintiff filed its opposition, evidentiary objections, and RJN. On 11/4/22, Defendant filed its reply and evidentiary objections.

 

LEGAL STANDARD FOR MOTIONS FOR SUMMARY JUDGMENT

The function of a motion for summary judgment or adjudication is to allow a determination as to whether an opposing party cannot show evidentiary support for a pleading or claim and to enable an order of summary dismissal without the need for trial. (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.) Code of Civil Procedure section 437c, subdivision (c) “requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to any material fact and that the moving party is entitled to judgment as a matter of law.”  (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.)  “The function of the pleadings in a motion for summary judgment is to delimit the scope of the issues; the function of the affidavits or declarations is to disclose whether there is any triable issue of fact within the issues delimited by the pleadings.”  (Juge v. County of Sacramento (1993) 12 Cal.App.4th 59, 65, citing FPI Development, Inc. v. Nakashima (1991) 231 Cal.App.3d 367, 381–382.)

As to each claim as framed by the complaint, the defendant moving for summary judgment must satisfy the initial burden of proof by presenting facts to negate an essential element, or to establish a defense. (Code Civ. Proc., § 437c, subd. (p)(2); Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1519–1520.)

Once the defendant has met that burden, the burden shifts to the plaintiff to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. 

To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v. Paetkau (1998) 68 Cal.App.4th 151, 163.) Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”  (Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389.)

 

ANALYSIS

I.                   Breach of Contract

Plaintiff’s first and second causes of action allege breach of contract. In a cause of action for breach of contract, a 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.)

Here, the parties entered the original lease agreement on 8/3/99. (Def.’s MSJ, 9:18–20.) As amended, the lease expires in 2032 with options to extend to 2042. (Id., 9:26–27.) The parties do not dispute that the 6/12/20 amended lease is valid and enforceable. Rather, the parties dispute whether Plaintiff’s nonpayment of rent was excused, and whether Defendant breached the lease agreement.

 

A.    Plaintiff’s Excuses for Nonperformance

Defendant argues that the pandemic restrictions on Plaintiff’s business operations never relieved Plaintiff of its obligation to pay rents or seek an abatement of rents. Defendant also cites to other actions where various California courts denied relief to Plaintiff on similar or duplicate arguments.

Plaintiff argues that rent was abated under the lease because the property was rendered untenantable. Plaintiff further argues that the government shutdown constitutes an excused event, thereby relieving Plaintiff of its rent payment obligation during the impacted period under the force majeure provision of the lease agreement. Plaintiff also reiterates its sought after relief on the basis of equitable doctrine—frustration of purpose, impossibility, and impracticability. Finally, Plaintiff argues that its performance obligations were excused under Civil Code 1511.

 

Abatement

Plaintiff argues that its obligation to pay rent was excused and abated under section 15.4 of the lease agreement. Section 15.4 states, in relevant part:

15.4 ABATEMENT OF RENT. If the Premises or any part thereof is rendered untenantable and neither party terminates this Lease pursuant to foregoing provisions of this Article XV, then Tenant's obligation for the payment of Minimum Rent and Additional Rent shall be abated from the date of the casualty in the ratio that the Floor Area of the portion of the Premises which is rendered untenantable bears to the total Floor Area of the Premises.

(Def.’s App. of Exhibits “AOE”, Ex. A [emphasis in original].)

Plaintiff argues that the shutdown restrictions rendered the premises “untenantable,” and thus rent is abated during the affected months. (Pl.’s Opp., 10:5–7.) However, as Defendant observes, Section 15.4 falls under Article XV of the lease agreement, entitled “Damage and Destruction.” (Def.’s Reply, 5:28–6:1; Ex. A to AOE, p. 30.) The condition of untenantability within the context of this Article is triggered by a “casualty” resulting in some sort of physical damage or destruction to the property which would necessitate repairs. (Ex. 1 to AOE, § 15.1.)

Here, Plaintiff does not argue that any such casualty has rendered the property “untenantable,” but instead argues that the government orders prohibited it from opening its doors for business. The Court rejects this interpretation of Section 15.4 of the lease, and finds that the government orders did not render the property “untenantable” under its intended meaning. Therefore, Section 15.4 is inapplicable in this action, and Plaintiff was not entitled to abatement of rent thereunder.

Accordingly, Defendant has met its initial burden to show that there is no triable issue of material fact as to abatement under Section 15.4 of the lease agreement. Plaintiff has not met its responsive burden to proffer evidence to show a triable issue.

 

Force Majeure

Generally, a party establishes the defense of force majeure where that party can demonstrate that “under the particular circumstances there was such an insuperable interference occurring without the parties’ intervention as could not have been prevented by prudence, diligence and care.” (Horsemen’s Benevolent & Protective Assn. v. Valley Racing Assn. (1992) 4 Cal.App.4th 1538, 1564.) “A force majeure clause is not intended to buffer a party against the normal risks of a contract … A force majeure clause interpreted to excuse the buyer from the risk he expressly assumed would nullify a central term of the contract.” (Id. at 1565.) Therefore, “where the ‘terms were specifically bargained for by both parties…the ‘doctrine’ of force majeure should not supersede the specific terms bargained for in the contract.” (Sun Pac. Mtkg. Coop. v. Dimare Fresh, Inc. (E.D. Cal. 2010) 2010 U.S. Dist. LEXIS 83176, citing Perlman v. Pioneer Limited Partnership (1990) 918 F.2d 1244, 1248.)

The force majeure provision of the lease agreement at issue reads, in pertinent part, as follows:

22.3 FORCE MAJEURE. If either party is delayed or hindered in or prevented from the performance of any act required hereunder because of strikes, lockouts, inability to procure labor or materials, failure of power, restrictive Laws, riots, insurrection, war, fire or other casualty or other reason of a similar or dissimilar nature beyond the reasonable control of the party delayed, financial inability excepted (any "Force Majeure Event"), performance of such act shall be excused for the period of the Force Majeure Event, and the period for the performance of such act shall be extended for an equivalent period. Delays or failures to perform resulting from lack of funds or which can be cured by the payment of money shall not be Force Majeure Events. The provisions of this Section 22.3 shall not

apply to Landlord or Tenant's obligations pursuant to the Work Letter attached hereto as Exhibit C and shall not extend the Rent Commencement Date or any date or occurrence based on which the Rent Commencement Date is calculated or determined.

(Ex. A to AOE [emphasis in original].)

Defendant argues that the shutdown orders causing the closure of the property did not constitute a force majeure event as defined under Section 22.3 because the orders did not affect Plaintiff’s ability to perform its obligation under the lease agreement, which was to pay rent. (Def.’s MSJ, 18:8–13.) The language of the lease unambiguously states that “[d]elays or failures to perform resulting from lack of funds or which can be cured by the payment of money shall not be Force Majeure Events.” (Ex. A to AOE.) Defendant also cites to several cases under California law which reject the application of the same force majeure provision to Plaintiff’s obligation to pay rent, of which the Court takes judicial notice. (Def.’s MSJ, 19:5–20:23.) In addition, it is undisputed by the parties that Plaintiff had the ability to pay rent at all times relevant to this action. Accordingly, Defendant met its initial burden to show that no triable issue of material fact exists as to the applicability of Section 22.3 to the instant action.

Plaintiff contends the government closure orders specifically barred Plaintiff from operating its business as intended—a health and fitness facility. (Pl.’s Opp., 12:1–3.) According to Plaintiff, said force majeure event prevented Plaintiff from receiving its benefit of the bargain, thereby rendering payment of the rent impossible and impractical and excusing Plaintiff’s non-payment. (Id., 15:3–5.) The payment of money would not cure the force majeure event in that Plaintiff cannot pay the State of California in order to resume health club operations. (Id., 13:9–10.)

Here, the Plaintiff appears to misunderstand its performance obligation under the “central” terms of the lease agreement, which is to pay rent in exchange for Defendant’s provision of the premises for Plaintiff’s possession, use, and quiet enjoyment without hindrance and interruption. (Horsemen, 4 Cal.App.4th at 1565; Ex. A to AOE.) As Defendant observes, it “had no obligation to ensure that [Plaintiff] would be free [from] acts of a third party, including from government closure orders.” (Def.’s Reply, 9:18–20.)

While a supervening government ordered banned the public from utilizing the facilities, for purposes of the subject motion only, the Court declines to find as a matter of law that the moratorium was a force majeure event. The force majeure clause requires a scenario actually impacting the fundamental elements of the contract itself—an event impacting the actual provision of the facilities rendering the premises unsafe or completely inaccessible due to fault in the facility itself. (Horsemen, 4 Cal.App.4th at 1565; Ex. A to AOE.) Such a scenario is not presented. The Court finds the plain language of the negotiated lease will not support this interpretation under governing California law.

A commercial tenant’s obligation to pay rent is independent from the landlord’s obligations under the lease. (Arnold v. Krigbaum (1915) 169 Cal. 143, 145–146.) Plaintiff’s inability to operate a fitness club due to restrictive COVID-19 laws and closure orders does not excuse its failure to pay rent. Nothing in the lease states that Plaintiff is excused from its obligation to pay rent if it is prevented from using the premises as a fitness club.

Even if the closure orders were considered a force majeure event, Plaintiff has not shown that its failure to pay rent was proximately caused by such orders or other causes as described in the agreement. (Exhibit A to AOE, § 22.3). Here, Plaintiff has not alleged that the government closure orders caused it not to pay rent or otherwise affected its ability to do so.

The Court finds that Section 22.3 of the lease agreement is inapplicable to the instant action, because the government closure orders did not affect Plaintiff’s ability to perform its essential obligation under the agreement, which was to pay rent. Accordingly, Plaintiff has not met its responsive burden of show a triable issue of material fact as to this issue.

 

Frustration of Purpose

Plaintiff alternatively argues that its nonpayment of rent was excused by the doctrine of frustration of purpose. “The elements of [the frustration of purpose] doctrine are as follows: Performance remains possible, but the fundamental reason of both parties for entering into the contract has been frustrated by an unanticipated supervening circumstance, thus destroying substantially the value of performance by the party standing on the contract.” (Cutter Laboratories, Inc. v. Twining (1963) 221 Cal.App.2d 302, 314–315.) “Even more clearly with respect to leases than in regard to ordinary contracts the applicability of the doctrine of frustration depends on the total or nearly total destruction of the purpose for which, in the contemplation of both parties, the transaction was entered into.” (Lloyd v. Murphy (1944) 25 Cal.2d 48, 53.) “With respect to frustration of purpose, the doctrine applies when performance is possible but a supervening, fortuitous event has virtually destroyed the value of the consideration to be rendered.” (Glendale Fed. Sav. & Loan Assn. v. Marina View Heights Dev. Co. (1977) 66 Cal.App.3d 101, 154.) “It is settled that if the parties have contracted with reference (to the frustrating event) or have contemplated the risks arising from it, they may not invoke the doctrine of frustration to escape their obligations.” (Glenn R. Sewell Sheet Metal, Inc. v. Loverde (1969) 70 Cal.2d 666, 676.)

Here, Defendant argues that the frustration of purpose doctrine should apply only where the entire value of the contract has been destroyed. (Def.’s MSJ, 21:1–3.) Defendant notes that here, a temporary shutdown order is insufficient to frustrate a multi-year lease ending in 2032. (Id., 21:9–12.) Plaintiff argues that temporary frustration of purpose is recognized under California law, which temporarily “suspends the obligor’s duty to perform while the frustration exists but does not discharge his duty.” (Pl.’s Opp. 16:1–6, quoting Maudlin v. Pac. Decision Sciences Corp. (2006) 137 Cal.App.4th 1001, 1017–1018.)

As Defendants observe, this action is distinguished from Maudlin because the Maudlin court applied the doctrine of temporary frustration of purpose to potentially suspend a corporation’s obligation to pay a retiree monies owed, on remand, due to the corporation’s lack of financial ability. (137 Cal.App.4th at 1017–1018.) Here, as previously mentioned, it is undisputed by the parties that Plaintiff had the ability to pay rent at all times relevant to this action. Therefore, the doctrine of temporary frustration of purpose is inapplicable to the instant case. Accordingly, Defendant has met its initial burden of showing no triable issue of material fact exists as to frustration of purpose excusing Plaintiff’s nonperformance under the lease agreement.

Plaintiff disputes the purpose of the lease agreement, and argues that it only entered into the agreement for the express purpose of operating a health and fitness facility, and made significant investments pursuant to its intended use of the premises. (Pl.’s Opp., 16:23–­17:8.) Contrary to Plaintiff’s contentions, the explicit purpose of the lease itself is for Plaintiff to pay rent in exchange for Defendant’s provision of defined space free from latent or patent defects, including local municipal fees, utility provisions, and other required operational items. (Ex. A to AOE, §§ 2.1–2.2.)

As Defendant observes, it made no guarantee to Plaintiff of its right to operate its business as a gym throughout the duration of the lease term. (Def.’s MSJ, 21:20–21.) In fact, the lease explicitly permits Plaintiff to use the premises “for any alternate lawful use” after the initial 10 years of the lease term. (Ex. A to AOE, § 8.2.) Moreover, the agreement specifically mentions that restrictive laws would not excuse the nonpayment of rent, as set forth in the above section discussing force majeure. (Id., § 22.3.)

The purpose of the lease agreement between the parties required Defendant to provide Plaintiff with the premises in exchange for the payment of rent. As such, the Court finds that this purpose was not frustrated by the government shutdown orders. Plaintiff has not met its responsive burden to show a triable issue of material fact exists as to its frustration of purpose defense.

 

Impossibility/Impracticability

“‘Impossibility’ is defined by section 454 of the Restatement of Contracts, not only as strict impossibility but as impracticability because of extreme and unreasonable difficulty, expense, injury, or loss involved. Temporary impossibility of the character which, if it should become permanent, would discharge a promisor's entire contractual duty, operates as a permanent discharge if performance after the impossibility ceases would impose a substantially greater burden upon the promisor; otherwise the duty is suspended while the impossibility exists. … The trial court's judgment indicates that the controversy was resolved upon the theory of temporary impossibility and suspension due to military service.” (Autry v. Republic Productions (1947) 30 Cal.2d 144, 148–149.) “A thing is impossible in legal contemplation when it is not practicable; and a thing is impracticable when it can only be done at an excessive and unreasonable cost.” (Mineral Park Land Co. v. Howard (1916) 172 Cal. 289, 293.)

As set forth above, Plaintiff’s performance obligation under the terms of the lease agreement was to pay rent in exchange for the lease of the premises. “The government closure orders did not render [Plaintiff’s] payment obligation impossible or impracticable.” (Def.’s MSJ, 23:7–8.) In fact, one of the orders explicitly stated that “nothing in this Order shall relieve a tenant of the obligation to pay rent.” (Ex. 1 to Def.’s RJN.) Furthermore, as previously mentioned, there is no dispute as to whether Plaintiff lacked the funds to pay the rent during the relevant time period.

While the restrictions certainly interfered with revenue generation, the obligations of the lease itself were not rendered impossible due to any changed obligations in the payment of the rent. The facilities were provided for full use, as required by the lease. (Ex. A to AOE, § 2.2.) The payment of rent is not dependent on the ability of the tenant to operate a business without extrinsic government restrictions. The lease provides the space for operation without consideration of the revenue source. Nothing otherwise prevented Plaintiff from paying the rent from other sources of revenue, as opposed to a business decision to decide on rent payment based on the operation of a single unit, rather than the portfolio of locations operated by Plaintiff. As such, Defendant has met its initial burden of showing that there is no triable issue of material fact as to Plaintiff’s impossibility and impracticability defenses to performance.

In opposition, Plaintiff proffers evidence to argue that “the entire purpose of the Lease was to operate a health club and fitness facility, which purpose was rendered illegal and impracticable by government orders.” (Pl.’s Opp., fn. 12.) As set forth above, the Court rejects Plaintiff’s interpretation of the objective purpose of the lease agreement, thus rendering this responsive showing irrelevant and insufficient to meet its responsive burden to show a triable issue of material fact.

 

Civil Code 1511

“The want of performance of an obligation, or of an offer of performance, in whole or in part, or any delay therein, is excused by the following causes, to the extent to which they operate: (1) When such performance or offer is prevented or delayed … by the operation of law, even though there may have been a stipulation that this shall not be an excuse; … (2) When it is prevented or delayed by an irresistible, superhuman cause, … unless the parties have expressly agreed to the contrary.” (Civ. Code § 1151.)

Pursuant to the above analyses regarding force majeure, frustration of purpose, and impossibility, the Court finds that the government restrictions did not impact Plaintiff’s ability to perform its obligation under the lease agreement, which was to pay rent in exchange for its possession and use of the property. The orders and pandemic may have made Plaintiff’s business less profitable and made it more difficult for Plaintiff to afford rent. However, “laws or other governmental acts that make performance unprofitable or more difficult or expensive do not excuse the duty to perform a contractual obligation.” (Aristocrat Highway Displays, Inc. v. Stricklen (1945) 68 Cal.App.2d 788, 790.)

Accordingly, the Court finds that Defendant has met its initial burden to negate the applicability of Civil Code section 1511, and Plaintiff has failed to meet its responsive burden to produce evidence showing a triable issue of material fact thereto.

 

B.     Defendant’s Breach

Defendant further argues that Plaintiff is unable to establish that Defendant breached its obligations to Plaintiff under the lease agreement. As discussed above, Plaintiff ceased its business operations due to the government orders, not any action by Defendant, nor does Plaintiff allege that Defendant is in any way responsible for the government acts. (Def.’s MSJ, 16:16–20.)

To the extent that Plaintiff alleges that Defendant breached the force majeure provisions in Section 22.3 of the lease agreement, its argument lacks merit as the Court has found the section inapplicable to the instant facts. To the extent that Plaintiff alleges that Defendant breached the warranty of quiet enjoyment in Section 22.1 of the lease agreement, its argument lacks merit as Plaintiff fails to attribute the alleged breach to any conduct by Defendant. (Id., 17:14–19.)

 

Consideration

Plaintiff asserts “failure of consideration” as a defense for its nonpayment of rent. “Failure of consideration is the failure to execute a promise, the performance of which has been exchanged for performance by the other party. The failure may arise from the wilful breach of the promise.” (Taliaferro v. Davis (1963) 216 Cal.App.2d 398, 410–411.)

As set forth above, the lease agreement requires Plaintiff to pay rent, and in exchange, Defendant is required to deliver Plaintiff defined space free from latent or patent defects, including local municipal fees, utility provisions, and other required operational items. (Ex. A to AOE, § 2.2.) Contrary to Plaintiff’s arguments, “the Lease does not create any ongoing obligation [on Defendant] to guarantee [Plaintiff’s] ability to legally operate as a fitness center throughout its term.” (Def.’s MSJ, 25:23–24.) Defendant essentially argues that because it provided Plaintiff possession of the property throughout the relevant time period, “any argument that it received no consideration in exchange for the payment of rent is factually inaccurate.” (Def.’s Reply, 13:18–19.) The Court finds that Defendant has met its initial burden of showing no triable issue of material fact with respect to Plaintiff’s failure of consideration argument.

Plaintiff argues in opposition that the government closure orders deprived Plaintiff of access to and occupancy of the property, thereby constituting a “total failure of consideration.” (Pl.’s Opp., 19:2–9.) The Court rejects Plaintiff’s argument, noting that notwithstanding the government orders, Plaintiff nevertheless decided to remain in possession of the property, and made no attempt to abandon it or return possession to Defendant. Defendant performed its obligations under the lease, including the provision of the premises for Plaintiff’s exclusive possession, maintenance of the common areas, and payment of property taxes.

Accordingly, the Court finds that Plaintiff has not made a sufficient responsive showing that a triable issue of material fact exists regarding this issue.

 

As set forth above, Defendant has met its initial burden of negating essential elements of (1) Plaintiff’s excused nonperformance and (2) Defendant’s breach in Plaintiff’s Breach of Contract causes of action. Plaintiff has not met its responsive burden to show a triable issue of material fact, and the Court therefore grants Defendant’s motion as to Plaintiff’s first and second causes of action.

 

II.                Common Count

Plaintiff’s third, fourth, and fifth causes of action are for Common Count. The elements of a common count claim are “(1) the statement of indebtedness in a certain sum, (2) the consideration, i.e., goods sold, work done, etc., and (3) nonpayment. A cause of action for money had and received is stated if it is alleged the defendant is indebted to the plaintiff in a certain sum for money had and received by the defendant for the use of the plaintiff.” (Farmers Insurance Exchange v. Zerin (1997) 53 Cal.App.4th 445, 460.)

Plaintiff’s Common Count causes of action seek the recovery of rent paid for the months during which the government closure orders were in effect. Because the Court finds that there exists no triable issue of material fact regarding Defendant’s alleged breach the lease agreement, as set forth above, Defendant is not indebted to Plaintiff. Accordingly, Defendant has met its initial burden of negating an essential element of Plaintiff’s Common Count causes of action. Plaintiff has made no responsive showing, and as such, the Court grants Defendant’s motion as to Plaintiff’s third, fourth, and fifth causes of action.

 

III.             Declaratory Relief

Plaintiff’s sixth and seventh causes of action are for Declaratory Relief pursuant to its arguments as discussed above. Because the Court finds that there is no triable issue of material fact as to any of the aforementioned causes of action, there is similarly no triable issue as to Plaintiff’s entitlement to declaratory relief. Defendant has met its initial burden of negating essential elements of Plaintiff’s above causes of action. Plaintiff has made no responsive showing as to the issue of declaratory relief, and as such, the Court grants Defendant’s motion as to Plaintiff’s sixth and seventh causes of action.