Judge: Ronald F. Frank, Case: 19STCV28087, Date: 2023-02-02 Tentative Ruling



Case Number: 19STCV28087    Hearing Date: February 2, 2023    Dept: 8

Tentative Ruling¿ 

¿¿ 

HEARING DATE:                 February 2, 2023¿¿ 

¿¿ 

CASE NUMBER:                  19STCV28087

¿¿ 

CASE NAME:                        Jessica Zazueta v. Wyndham Worldwide Corporation, et al

                                                            .¿¿¿ 

MOVING PARTY:                Defendants, LAX Hotel Investment Company, Inc. dba Wingate by Wyndham LAX

¿¿ 

RESPONDING PARTY:       Plaintiff, Jessica Zazueta

¿¿ 

TRIAL DATE:                        None set¿ 

¿¿ 

MOTION:¿                              (1) Demurrer¿ to First Amended Complaint

                                                (2) Motion to Strike

¿ 

Tentative Rulings:                  (1) Defendant’s Demurrer is OVERRULED in part and SUSTAINED in part.

                                                (2) Defendant’s Motion to Strike is GRANTED in part and DENIED in part.

¿¿ 

¿ 

I. BACKGROUND¿¿ 

¿¿ 

A. Factual¿¿ 

 

            On August 7, 2019, Plaintiff first filed a complaint in this case. On June 7, 2022, Plaintiff, Jessica Zazueta (“Plaintiff”) filed her First Amended Complaint (“FAC”) against Defendants, Wyndham Worldwide Corporation; Wyndham Destinations, Inc.; Wingate by Wyndham LAX; LAX Hotel Investment Company, Inc.; Linda Oh; Korey Small, and DOES 1 through 20 (collectively “Defendants”). On July 20, 2022, Plaintiff filed a First Amended Complaint (“FAC”) alleging a cause of action for: (1) Battery; (2) Negligence; (3) Intentional Infliction of Emotional Distress; (4) Fraudulent Concealment; (5) Private Nuisance; and (6) Public Nuisance.

¿ 

B. Procedural¿¿ 

¿ 

On August 9, 2022, Defendant, LAX Investment Company, Inc. dba Wingate by Wyndham LAX (“LAX”) filed a demurrer and motion to strike. On January 20, 2023, Plaintiff filed an opposition. On January 26, 2023, LAX filed a reply brief as to opposition to Motion to Strike, but no reply brief has been filed to the opposition to demurrer.

 

¿II. MOVING PARTY’S GROUNDS FOR THE DEMURRER¿& MOTION TO STRIKE¿ 

¿ 

¿¿Defendant demurs to Plaintiff’s FAC on the following grounds: (1) The First, Third, Fourth, Fifth, and Sixth causes of action fail to state facts sufficient to constitute a cause of action against Defendant LAX; (2) The Fourth Cause of action fails to meet the heightened specificity standard for maintaining a fraud cause of action; (3) The Court  does not have jurisdiction of the Fifth and Sixth Causes of action because Plaintiff does not have standing to bring them before this Court.

 

Defendant’s Motion to Strike is based on striking any language eluding to, or referencing punitive damages. Defendant further requests that this Court strike paragraphs 40 and 81 of the FAC because it argues that the allegations contained therein regarding other lawsuits allegedly filed against Wyndham hotels are uncertain and irrelevant.

¿¿ 

¿III. ANALYSIS¿¿ 

¿¿ 

A. Demurrer

¿¿ 

A demurrer can be used only to challenge defects that appear on the face of the pleading under attack or from matters outside the pleading that are judicially noticeable. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) “To survive a demurrer, the complaint need only allege facts sufficient to state a cause of action; each evidentiary fact that might eventually form part of the plaintiff’s proof need not be alleged.” (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 872.) For the purpose of testing the sufficiency of the cause of action, the demurrer admits the truth of all material facts properly pleaded. (Aubry v. Tri-City Hospital Dist. (1992) 2 Cal.4th 962, 966-967.) A demurrer “does not admit contentions, deductions or conclusions of fact or law.” (Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695, 713.)¿¿¿¿ 

¿¿¿ 

A pleading is uncertain if it is ambiguous or unintelligible. (Code Civ. Proc., § 430.10, subd. (f).) A demurrer for uncertainty may lie if the failure to label the parties and claims renders the complaint so confusing defendant cannot tell what he or she is supposed to respond to.¿ (Williams v. Beechnut Nutrition Corp. (1986) 185 Cal.App.3d 135, 139, fn. 2.) However, “[a] demurrer for uncertainty is strictly construed, even where a complaint is in some respects uncertain, because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly's of California, Inc. (1993) 14 Cal.App.4th 612, 616.)¿¿¿ 

 

Battery: Sustained with Leave to Amend

 

Defendant first demurs to the first cause of action for battery. The elements of civil battery are (1) defendant intentionally performed an act that resulted in a harmful or offensive contact with the plaintiff’s person; (2) plaintiff did not consent to the contact; and (3) the harmful or offensive contact caused injury, damage, loss or harm to plaintiff. (Brown v. Ransweiler (2009) 171 Cal.App.4th 516, 526.) 

 

Defendant argues that there are no material facts to allege that Defendant touched or caused Plaintiff to be touched, or that Defendant LAX intended to cause Plaintiff harm. While that is correct, a battery does not require a direct “touching” of the plaintiff by the defendant. For example, a battery may be committed by inducing the plaintiff to consume a poison. (U.S. v. Castleman (2014) 134 U.S. 1405, 1414-1415.) 

            Plaintiff argues in her opposition that “[i]t is well settled that an awareness of a condition that is known to cause harm in such a manner, absent any effort to stop such contact from occurring, constitutes battery.” Plaintiffs point to an appellate court case from the Seventh Circuit, Mathias v. Accor Econ. Lodging, Inc. (7th Cir. Ill. 2003) 347 F.3d 6721, which also involved allegations of a bedbug infestation at a hotel or motel.  The facts in that case were alleged which much greater detail and specificity than what is alleged here, where the traveler was relocated from a first room to a second room to a third one, and where it was alleged that the motel acknowledged that it had a “major problem with bed bugs” and that all that was being done about it was “chasing them from room to room.” As noted in Defendant’s Reply, the Opposition brief argues a number of purported facts that are not alleged in the First Amended Complaint.  To the extent that Plaintiff believes these additional allegations should be considered by the Court, the Court will allow leave to amend the battery cause of action. 

   

Accordingly, the demurrer to the first cause of action for battery is Sustained with 20 days leave to amend. 

           

Intentional Infliction of Emotional Distress: Sustained with leave to amend.

Defendant argues that Plaintiff has not stated sufficient facts for a claim of Intentional Infliction of Emotional Distress (“IIED”). “The elements of a prima facie case for the tort of intentional infliction of emotional distress are: (1) extreme and outrageous conduct by the defendant with the intention of causing, or reckless disregard of the probability of causing, emotional distress; (2) the plaintiff’s suffering severe or extreme emotional distress; and (3) actual and proximate causation of the emotional distress by the defendant’s outrageous conduct. Conduct to be outrageous must be so extreme as to exceed all bounds of that usually tolerated in a civilized community.” (Wilson v. Hynek (2012) 207 Cal.App.4th 999, 1009, citation and ellipses omitted.)

Here, Plaintiff’s FAC asserts that “[a]lthough Defendants, and DOES 1 through 20, had prior knowledge of bedbug infestations in their hotel, Defendants, and DOES 1 through 20, failed to eradicate such infestations, including an infestation in the room that Plaintiff were provided” and that “Defendants, and DOES 1 through 20, knew that their hotel had a prior bedbug infestation. Defendants, and DOES 1 through 20, deliberately and recklessly chose not to inspect or ensure that Plaintiff’s room was free of Cimex lectularius immediately prior to Plaintiff’s stay.” (FAC, ¶ 74.) The FAC also asserts that as a result, “Plaintiff suffered severe emotional distress that has caused Plaintiff to sustain sever, serious and permanent injuries to her person, all to Plaintiff’s damage in a sum to be shown according to proof and within the jurisdiction of the Superior Court. (FAC, ¶ 84.)

Plaintiff’s FAC does not allege extreme and/or outrageous conduct on behalf of Defendant LAX.  Given the number of defendants and the pleading requirements for an IIED cause of action, the Court finds that Plaintiff’s FAC fails to allege sufficient facts to support an IIED claim against the Demurring Defendant and thus the Demurrer is sustained.  The Court will grant 20 days leave to amend to include specific facts as against Defendant LAX if Plaintiff intends to pursue an IIED cause of action against the demurring defendant.   

Fraudulent Concealment: Sustained with leave to amend.

            Defendant argues that Plaintiff has not stated sufficient facts for a claim of Fraudulent Concealment. “The elements of a cause of action for fraudulent concealment are: (1) concealment of a material fact; (2) by a defendant with a duty to disclose; (3) the defendant intended to defraud by failing to disclose; (4) plaintiff was unaware of the fact and would not have acted as it did had it known the fact; and (5) damages.” (Butler America, LLC v. Aviation Assurance Company, LLC (2020) 55 Cal.App.5th 136, 144.) The facts constituting the alleged fraud must be alleged factually and specifically as to every element of fraud, as the policy of “liberal construction” of the pleadings will not ordinarily be invoked. (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) To properly allege fraud against a corporation, the plaintiffs must plead the names of the persons allegedly making the false representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written. (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)

            Here, Plaintiff’s FAC alleges that “[f]ront desk personnel intentionally did not disclose the material fact of the Cimex lectularius “bedbug” infestation, during check-in, a fact known to those employees and agents and which their employees and agents, knew Plaintiff would not discover on her own prior to renting the hotel room.” (FAC, ¶ 32.) Plaintiff claims that “[f]ront desk personnel intentionally did not disclose the material fact of the Cimex lectularius “bedbug” infestation, during check-in, a fact known to those employees and agents, and which their employees and agents, knew Plaintiff would not discover on her own prior to renting the hotel room.”  (FAC, ¶ 94.) Additionally, Plaintiff alleges that “Defendants, and DOES 1 through 20, and her employees and agents intentionally failed to disclose the material fact of the Cimex lectularius infestation” and “intended to deceive Plaintiff and take advantage of Plaintiff’s lack of knowledge of the infestation in order to turn a profit on a night’s stay at her hotel.” (FAC, ¶¶ 96, 98.) Plaintiff’s FAC alleges that as a result of Defendants breaches of duty, “Plaintiff was compelled to and did employ the services of hospitals, physicians and surgeons, nurses, and the like, to care for and treat Plaintiff’s injuries, and did incur hospital, medical, professional, and incidental expenses.” (FAC, ¶ 104.)

            Defendant’s demurrer argues that fraud must be plead with specificity and that Plaintiff has failed to state which representations she alleged were fraudulent; why and how these representations were fraudulent; and how these representations were the decisive motivating factor for Plaintiff to obtain services from defendants.

The Court notes that what this claim is dealing with is allegation of negligent concealment. Indeed, “[h]ow does one show ‘how’ and ‘by what means' something didn't happen, or ‘when’ it never happened, or ‘where it never happened?” (Alfaro v. Community Housing Improvement System & Planning Association (2009) 171 Cal.App.4th 1356, 1384.) A plaintiff asserting fraud on a concealment theory will “not be able to specify the time, place, and specific content of an omission as precisely as would a plaintiff in a false representation claim.” Such a claim “can succeed without the same level of specificity required by a normal fraud claim.” (Falk v. General Motors Corporation (N.D. Cal. 2007) 496 F.Supp.2d 1088, 1098-99.) It would be counterintuitive to require Plaintiff to name specific people who failed to say something. The specificity requirements for fraud are more strictly applicable to cases where affirmative fraudulent actions or representations are being alleged. On the contrary, what is at issue here are facts that were fraudulently never revealed. 

 

Moreover, the case Tarmann v. State Farm Mutual Automobile Insurance Company (1991) 2 Cal.App.4th 153 makes clear the longstanding California rule that the specificity requirement is relaxed when the allegations indicate that “the defendant necessarily possess full information concerning the facts of the controversy” or “where the facts lie more in the knowledge of the opposite party.” (Id. at p. 157; see, also Turner v. Milstein (1951) 103 Cal. App. 2d 651, 658 [“Even under the strict rules of common law pleading, one of the canons was that less particularity is required when the facts lie more in the knowledge of the opposite party than of the party pleading.”].) The facts regarding the knowledge and concealment of the bedbug infestation are arguably more within the knowledge of Defendant.  In light of the above authorities, the Court concludes that Plaintiffs cannot reasonable be required to comply with the specificity rule for pleading fraud in the strictest sense of the rule. 

 

Nevertheless, the Court does agree with Defendant that more specific facts could and should have been provided. Plaintiff should at least have been able to provide facts regarding what was said during check-in, whether Plaintiff inquired about the room’s condition, what the “front desk personnel” allegedly knew at check in time, what was said and who they interacted when Plaintiff first brought up the bedbug issue and checked out of her room, etc. The failure to do so subjects the fraudulent concealment cause of action to demurrer. 

 

Accordingly, Defendant’s demurrer to the fourth cause of action for fraudulent concealment is SUSTAINED, with 20 days leave to amend. 

 

Private Nuisance: Sustained without leave to amend

Defendant asserts that Plaintiff’s FAC fails to alleges facts sufficient to support a cause of action for Private Nuisance. To establish an action for private nuisance, (1) “the plaintiff must prove an interference with his use and enjoyment of his property”; (2) “the invasion of the plaintiff’s interest in the use and enjoyment of the land must be substantial, that is, that it causes the plaintiff to suffer substantial actual damage”; (3) “the interference with the protected interest must not only be substantial, but it must also be unreasonable, i.e., it must be of such a nature, duration, or amount as to constitute unreasonable interference with the use and enjoyment of the land.” (Mendez v. Rancho Valencia Resort Partners, LLC (2016) 3 Cal.App.5th 248, 262-263, citations, italics, brackets, and quotation marks omitted.)

            Plaintiff’s FAC alleges that “[t]he Cimex lectularius infestation that Defendants, and DOES 1 through 20, negligently and intentionally caused to exist in Plaintiff’s hotel, and specifically Plaintiff’s room, constitutes a nuisance within, but not limited to the meaning of Civil Code Section 3479 and California Health & Safety Code Section 17920.3, in that said infestation was injurious to the health and safety of Plaintiff, indecent and offensive to the senses of Plaintiff, and interfered substantially with Plaintiff’s comfortable enjoyment of their hotel room.” (FAC, ¶ 108.) Plaintiff’s FAC also alleges that the “nuisance has caused, and will continue to cause in the future, Plaintiff to suffer general and special damages.” (FAC, ¶ 109.)

            Defendant argues that Plaintiff fails to allege any interference with the use and enjoyment of her property or show that Defendant’s conduct was intentional or reckless or a result of an abnormally dangerous activity. Additionally, the Demurrer argues that the FAC fails to state any specific facts to show that this Defendant’s conduct is a substantial factor in causing Plaintiff’s alleged harm.

            Even though not raised by either party, this Court notes that a private nuisance claims requires a plaintiff to show inference with the use or enjoyment of a property interest. ‘‘[A]ny interest sufficient to be dignified as a property right’ will support an action based on a private nuisance…’” (Orange County Water Dist. v. Sabic Innovative Plastics US, LLC (2017) 14 Cal.App.5th 343, 416, citing Venuto v. Owens–Corning Fiberglas Corp. (1971) 22 Cal.App.3d 116, 125.)  However, “‘Guests in a hotel, boarders in a boarding house, and roomers or lodgers, so called, are generally mere licensees and not tenants. They have only a personal contract, and acquire no interest in the realty.’” (Sloan v. Court Hotel (1945) 72 Cal.App.2d 308, 314.)  A property right sufficient to bring a claim based on private nuisance “does not inure in favor of a licensee, lodger or employee.” (Venuto, supra, 22 Cal.App.3d at p. 125.) As such, Plaintiff, as a “lodger” has not alleged a sufficient property interest to bring a claim for private nuisance.

             Accordingly, the demurrer is SUSTAINED as to the fifth cause of action for private nuisance without leave to amend. 

 

Public Nuisance: Overruled.

A nuisance is statutorily defined as anything “injurious to health” or “indecent, or offensive to the senses, or an obstruction to the free use of property” that interferes “with the comfortable enjoyment of life or property…” (Civ. Code, § 3479.) “A public nuisance is one which affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal.” (Civ. Code, § 3480.)  “[P]ublic nuisances are offenses against, or interferences with, the exercise of rights common to the public.” (People ex rel. Gallo v. Acuna (1997) 14 Cal.4th 1090, 1103) “Of course, not every interference with collective social interests constitutes a public nuisance. To qualify, and thus be enjoinable [or abatable], the interference must be both substantial and unreasonable.” (Id. at p. 1105.) It is substantial if it causes significant harm and unreasonable if its social utility is outweighed by the gravity of the harm inflicted. (Ibid.) 

 

The elements “of a cause of action for public nuisance include the existence of a duty and causation.” (In re Firearm Cases (2005) 126 Cal.App.4th 959, 988.) Public nuisance liability “does not hinge on whether the defendant owns, possesses or controls the property, nor on whether he is in a position to abate the nuisance; the critical question is whether the defendant created or assisted in the creation of the nuisance.” (City of Modesto Redevelopment Agency v. Superior Court (2004) 119 Cal.App.4th 28, 38.) 

 

Defendant contends that Plaintiff cannot allege facts sufficient to support a public nuisance claim; specifically, Plaintiff only alleges that she was exposed to bedbugs during her stay and does not allege that the bedbug infestation affected any other people. Defendant contends that Plaintiffs cannot sustain an action for public nuisance because they have not alleged facts to demonstrate that the purported bedbugs in their room affected anyone beyond themselves.  

 

The elements of public nuisance are: (1) a nuisance that served as an obstruction of the free use of property so as to interfere with the comfortable enjoyment of life or property; (2) the nuisance affected a substantial number of people; (3) an ordinary person would be unreasonably annoyed or disturbed by the nuisance; (4) the seriousness of the harm occasioned by the nuisance outweighed its social utility; (5) plaintiffs did not consent to the nuisance; (6) plaintiffs suffered harm as a result of the nuisance that was different from the type of harm suffered by the general public; and (7) the nuisance was a substantial factor in causing the plaintiffs’ harm. (Department of Fish & Game v. Superior Court (2011) 17 Cal.App.4th 1323, 1352.) 

 

On a claim for public nuisance, the plaintiffs must “prove a substantial number of people were harmed and the plaintiffs suffered harm that was different from that suffered by the general public.” (Ibid.) 

 

            In opposition, Plaintiff argues that the community at large may be affected by bedbugs as they are likely to spread into the community amongst other hotel guests. (See Birke v. Oakwood Worldwide (2009) 169 Cal.App.4th 1540, 1548)(allegations were sufficient where it plaintiff alleged that “the condition impacts all guests of the apartment complex” in a secondhand tobacco smoke case.)   Paragraphs 115 and 116 of the FAC allege that the bedbug infestation affected the community at large and the general public.  Accordingly, the demurrer to the sixth cause of action for public nuisance is OVERRULED.  

¿¿¿ 

B. Motion to Strike¿¿ 

¿ 

The court may, upon a motion, or at any time in its discretion, and upon terms it deems proper, strike any irrelevant, false, or improper matter inserted in any pleading.¿ (Code Civ. Proc., § 436(a).)¿ The court may also strike 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.¿ (Id., § 436(b).)¿ The grounds for a motion to strike are that the pleading has irrelevant, false improper matter, or has not been drawn or filed in conformity with laws.¿ (Id., § 436.)¿ The grounds for moving to strike must appear on the face of the pleading or by way of judicial notice.¿ (Id., § 437.)¿ “When the defect which justifies striking a complaint is capable of cure, the court should allow leave to amend.”¿ (Vaccaro v. Kaiman (1998) 63 Cal.App.4th 761, 768.)¿     ¿ 

¿ 

Here, Defendant moves to strike the following in Plaintiff’s complaint:  

  

1.      Paragraph 40 of Plaintiffs F AC, on page 6, which states: "Multiple lawsuits have been filed against multiple Wyndham Worldwide Corporation and Wyndham Destinations, Inc. properties, showing a repetitive lack of care by Defendant, and DOES 1 through 20, in setting up adequate or proper policies and procedures for the elimination or control of bed bugs or bed bug infestations at their establishments."   GRANT.

2.      Paragraph 55 of Plaintiff's FAC, on page 9, which states: "Plaintiff is informed and believes, and thereon alleges, that the aforesaid conduct of Defendants, an DOES 1 through 20, was carried out with a willful and conscious disregard of Plaintiff's right to be free from such tortious behavior, such as to constitute oppression, fraud of malice pursuant to California Civil Code Section 3294, and that an officer, director, or managing agent of Defendants, and DOES 1 through 20, authorized or ratified the wrongful acts of the employees and Defendants, and DOES 1 through 20, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants, and DOES 1 through 20."  DENY.

 

3.      Paragraph 72 of Plaintiffs F AC, on page 14, which states: "Plaintiff is informed and believes, and thereon alleges, that the aforesaid conduct of Defendants, an DOES 1 through 20, was carried out with a willful and conscious disregard of Plaintiff's right to be free from such tortious behavior, such as to constitute oppression, fraud of malice pursuant to California Civil Code Section 3294, and that an officer, director, or managing agent of Defendants, and DOES 1 through 20, authorized or ratified the wrongful acts of the employees and Defendants, an DOES 1 through 20, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants, and DOES 1 through 20." DENY.

 

4.      Paragraph 81 of Plaintiff's FAC, on pages 15-16, which states: "Multiple lawsuits have been filed against multiple Wyndham Worldwide Corporation and Wyndham Destinations, Inc. properties, showing a repetitive lack of care by Defendant, and DOES 1 through 20, in setting up adequate or proper policies and procedures for the elimination or control of bed bugs or bed bug infestations at their establishments." GRANT.

 

5.      Paragraph 86 Plaintiff's FAC, on page 17, which states: "Plaintiff is informed and believes, and thereon alleges, that the aforesaid conduct of Defendants, an DOES 1 through 20, was carried out with a willful and conscious disregard of Plaintiff's right to be free from such tortious behavior, such as to constitute oppression, fraud of malice pursuant to California Civil Code Section 3294, and that an officer, director, or managing agent of Defendants, and DOES 1 through 20, authorized or ratified the wrongful acts of the employees and Defendants, and DOES 1 through 20, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants, and DOES 1 through 20."   DENY

 

6.      Paragraph 105 of Plaintiff's FAC, on pages 19-20, which states: "Plaintiff is informed and believes, and thereon alleges, that the aforesaid conduct of Defendants, an DOES 1 through 20, was carried out with a willful and conscious disregard of Plaintiff's right to be free from such tortious behavior, such as to constitute oppression, fraud of malice pursuant to California Civil Code Section 3294, and that an officer, director, or managing agent of Defendants, and DOES 1 through 20, authorized or ratified the wrongful acts of the employees and Defendants, and DOES 1 through 20, entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants, and DOES 1 through 20."  GRANT.

 

7.      Plaintiff’s Prayer for Relief on Page 21, where it states: “For punitive damages in an amount to be determined at trial.  DENY

 

 

Allegations of Prior Lawsuits

 

            Defendants request this Court strike paragraphs 40 and 81 of the FAC, which allege, tat multiple lawsuits have been filed against Wyndham hotels and that this allegedly shows that a repetitive lack of care by Defendants. The mere fact that a lawsuit has been filed is not an evidentiary fact which, if proven, bears of the allegations of entitlement to punitive damages.  Without any argument as to why Plaintiff has included the multiple lawsuits in its FAC, this Court GRANTS Defendant’s Motion to Strike as to the alleged lawsuits.

 

Punitive Damages

 

Civil Code section 3294, subdivision (a) authorizes punitive damages in non-contract cases “where the defendant has been guilty of oppression, fraud, or malice.” 

 

 “Malice [is defined as] conduct which is intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard for the rights and safety of others.” (Civ. Code, § 3294, subd. (c)(1).) “Oppression” means “despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person's rights.” (Civ. Code, § 3294, subd. (c)(2).) “Fraud” is “an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person of property or legal rights or otherwise causing injury.” (Civ. Code, § 3294, subd. (c)(3).) The Plaintiff has alleged sufficient facts which, if proven could entitle Plaintiff to establish the malice prong of Civil Code section 3294. 

 

For the foregoing reasons, the Court DENIES the motion to strike the allegation and prayer for punitive damages.