Judge: Ronald F. Frank, Case: 23TRCV04083, Date: 2024-04-02 Tentative Ruling

Case Number: 23TRCV04083    Hearing Date: April 2, 2024    Dept: 8

Tentative Ruling¿ 

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HEARING DATE:                 April 2, 2024¿ 

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CASE NUMBER:                   23TRCV04083

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CASE NAME:                        Natasha Campisi v. Searock PVE, LLC, et al.  

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MOVING PARTY:                (1) Defendant/Cross-Complainant, Searock PVE, LLC and Defendants, Pinky Khan, Ahmad Khan

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RESPONDING PARTY:       (1) Plaintiff/Cross-Defendant, Natasha Campisi

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TRIAL DATE:                       None set.  

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MOTION:¿                              (1) Defendants’ Demurrer 

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Tentative Rulings:                  (1) Defendants’ demurrer is SUSTAINED in part with 20 days leave to amend, and OVERRULED in part   

 

 

 

 

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I. BACKGROUND¿¿                                                                                

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A. Factual¿¿ 

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On December 6, 2023, Plaintiff, Natasha Campisi (“Plaintiff”) filed a Complaint against Defendants, Searock PVE, LLC, Pinky Khan, Ahmad Khan, Tiffany Kawata, Murat Mese, and DOES 1 through 100. The Complaint alleges causes of action for: (1) Intentional Misrepresentation; (2) Negligent Misrepresentation; (3) Fraudulent Concealment; (4) Private Nuisance; (5) Invasion of Privacy, Intrusion into Seclusion; (6) Intentional Infliction of Emotional Distress; (7) Breach of Implied Warranty of Habitability; and (8) Unlawful Self-Help by Landlord in Violation of Civil Code § 789.3.

 

Now, Defendants, Searock, Pinky Khan, and Ahmad Khan (collectively, “Demurring Defendants”), file a demurrer as to the First, Second, Third, Sixth, Seventh, and Eighth causes of action on the grounds that they argue Plaintiff  has failed to allege sufficient facts to allege these causes of action.

 

B. Procedural¿¿ 

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On February 5, 2024, Demurring Defendants filed their demurrer to Plaintiff’s Complaint. On March 19, 2024, Plaintiff filed an opposition brief. On March 25, 2024, Demurring Defendants filed a reply brief.  

 

II. REQUEST FOR JUDICIAL NOTICE

 

            Along with their moving papers, Demurring Defendants have filed a Request for Judicial Notice of the following Document:

 

1.     Attached as Exhibit C is a true and correct copy of Searocks Cross-Complaintfiled in this matter on February 5, 2024. Defendants request that the Court take judicial notice of this document, which is a public record, a record of the Court of this State, and part of this Courts record in the matter and incorporated by reference in the Demurrer to the Complaint.

 

The Court GRANTS this request and takes judicial notice of the above documents.

 

 

III. ANALYSIS¿ 

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A. Legal Standard

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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.)¿¿¿ 

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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.)¿¿ 

 

B. Discussion

 

Intentional Misrepresentation

Here, Demurring Defendants argue that Plaintiff’s cause of action for Intentional misrepresentation fails to state a cause of action. “The elements of a cause of action for intentional misrepresentation are (1) a misrepresentation, (2) with knowledge of its falsity, (3) with the intent to induce another’s reliance on the misrepresentation, (4) actual and justifiable reliance, and (5) resulting damage.” (Daniels v. Select Portfolio Servicing, Inc. (2016) 246 Cal.App.4th 1150, 1166.) 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.

Demurring Defendants contend that Plaintiff’s allegation that she discovered “through other neighbors” on the street that “Murat has been a known nuisance and a danger to the community for years” lacks specificity and is insufficient to withstand demurrer.  (Complaint, ¶ 26.) Demurring Defendants also contend that on that basis alone, Plaintiff alleges Defendants were “fully aware” and “willfully failed” to disclose Mr. Mese’s conduct. (Complaint, ¶ 26.) Demurring Defendants argue that Plaintiff imputes Plaintiff’s hearsay knowledge on Defendants without any basis from which to form the belief. They further argue that Plaintiff has not pled any allegations that they Defendants deceived Plaintiff about Defendant Mese such that they lied about the safety of the Property, but merely pled her independent discovery about Defendant Mese.  But when analyzing a demurrer, the Court may not weigh evidence of alleged hearsay. Instead, this Court is to determine whether, based on the face of the pleadings, Plaintiff has alleged sufficient facts to state a cause of action.

Parking Misrepresentation

As to the parking misrepresentation, Plaintiff asserts that she let it be known early in the process, she and her family had three vehicles, and that the property would need to accommodate three spaces. (Complaint, ¶ 20.) Plaintiff specifically alleges that Defendant Pinky verbally told Plaintiff multiple times before Plaintiff agreed to rent the property that there were three (3) parking spaces available, and that “she would have nothing to worry about” regarding ensuring parking spaces for all three vehicles. (Complaint,  ¶ 20.) Plaintiff further specifies that she was told, “two cars can be parked in the garage, and one can be parked in the driveway in front of the h use.” (Complaint, ¶ 20.) However, Plaintiff contends that what was not disclosed, was that her driveway was an easement, and that she would not be able to permanently park the third vehicle on the driveway. (Complaint, ¶ 20.) Further, Plaintiff contends that she was not told that the closest street parking is over one-third of a mile away. (Complaint, ¶ 20.) As such, the Complaint indicates the required specificities of an intentional misrepresentation cause of action.

However, in Demurring Defendant’s moving papers, they have requested this Court take Judicial Notice of the Cross-Complaint which has attached to it, the lease. The lease indicates in Paragraph 7A, that there is 2-Car garage, parking in the front of the home and side garage is in an easement, and that the easement can be utilized for temporary parking but needs to be readily accessible. (Demurring Defendants’ RFJN, Exhibit C.) Plaintiff’s opposition asserts that the fact that the lease says there is an easement does not explain why Pinky continued to “double down” on her misrepresentation by continuing to state that Plaintiff would be able to park the third vehicle in the driveway as the Complaint alleges.  But Plaintiff’s complaint does not contain allegations of continuing misrepresentation about the parking spot AFTER the signing of the lease. Here, although Plaintiff’s allegations note that oral representations were made prior to signing the lease, the lease clearly makes contrary representations and Plaintiff still signed the lease.  The Complaint does not allege any misrepresentations contained in the lease with respect to the parking spot. With respect to the assertion that the nearest street blocking was a considerable distance away, there is not allegation in the Complaint that any defendant promsed the street parking would be right in front of the home or that the street parking was available within a block or similar claim. 

As such, the Court does not believe that Plaintiff can maintain a cause of action for Intentional Misrepresentation with respect to the parking spot.

Electrical Issues

            As for the electrical issues, Plaintiff contends that Defendants Searock and Pinky represented that all of the electrical and appliances would be in good working order upon Plaintiff choosing to rent and subsequently moving into the Subject Property. (Complaint, ¶ 29.) Plaintiff also asserts that Searock knew about the faulty and incorrect wiring on the property for years, and certainly knew of this before they rented the property to Plaintiff and her family, exposing her to danger, as well as general and special damages. (Complaint, ¶ 22.) Plaintiff contends Defendants made these representations to Plaintiff in order to induce her into choosing to rent the Subject Property. (Complaint, ¶ 29.) Plaintiff asserts that these representations were made on July 1, 2023, when Plaintiff was touring the subject property. (Complaint, ¶ 29.) Plaintiff asserts that she reasonably relied on these false representations, as she chose to rent the subject property. (Complaint, ¶ 34.)

            Here, the Court finds that although Plaintiff has technically satisfied each of the elements in this cause of action as it relates to the electrical issues, Plaintiff’s allegations are far too conclusory. Plaintiff suggests that on July 1, 2023, representations were made to her regarding the electricity at the apartment and that such electricity and appliances were in good working order.  But Plaintiff will need to be plead more specific facts in order to state a cause of action for intentional misrepresentation, i.e., Did Plaintiff inquire as to the electrical and appliance? What questions were asked regarding the electrical and appliances, and what were the answers? These inquiries are necessary and required to be pleaded in order for Plaintiff to maintain this cause of action as it relates to the electrical and appliances.  

Harassing Neighbor

With the misrepresentation about the allegedly harassing neighbor, Plaintiff notes that before Plaintiff even agreed to rent the property from Searock through Pinky and Kawata brokering the transaction, she disclosed to both Pinky and to Kawata that Plaintiff and her family have been victims of abuse from Plaintiff’s prior spouse, and that her and her family were extremely sensitive to harassment, threats, and abuse, which is what she got and continues to get from Murat the neighbor since the day she moved in. (Complaint, ¶ 26.) Further, Plaintiff asserts that she was told by Kawata that she made Ahmad, Pinky, and Searock aware of Plaintiff’s history of abuse, and that Ahmad, Pinky, and Searock wanted to assure Plaintiff that she had nothing to worry about. (Complaint, ¶ 26.) Plaintiff further notes that when she asked about the neighbors and Murat specifically before agreeing to rent the Subject Property, Plaintiff was told by Pinky that “Murat is a really nice man,” “that me [Pinky] and my husband [Ahmad] have had tea with him before, and he’s great.” (Complaint, ¶ 27.) However, Plaintiff notes, that in her time living at the subject property, that other neighbors living on the same street have informed her that Murat is a known nuisance and a danger to the community for many years, has had numerous confrontations, some of which have escalated to physical violence. (Complaint, ¶ 26.) Plaintiff notes that Defendants were fully aware of these prior confrontations Murant had with the neighbors, and were fully aware of his nuisance and dangerous tendencies.

Pursuant to this First Cause of Action for Intentional Misrepresentation as it relates to the allegations against Demurring Defendant as to the harassing neighbor, this Court contends that Plaintiff has specifically alleged all elements of this cause of action. Thus, as it relates to the harassing neighbor misrepresentation, this Court notes that the demurrer is OVERRULED. However, as to the parking and electrical/appliances, the demurrer is SUSTAINED with twenty (20) days leave to amend.

 

Negligent Misrepresentation

Demurring Defendant also argues that Plaintiff has not sufficiently pled the cause of action for Negligent Misrepresentation. The elements of a cause of action for negligent misrepresentation include “[m]isrepresentation of a past or existing material fact, without reasonable ground for believing it to be true, and with intent to induce another’s reliance on the fact misrepresented; ignorance of the truth and justifiable reliance on the misrepresentation by the party to whom it was directed; and resulting damage.” (Hydro-Mill Co., Inc. v. Hayward, Tilton & Rolapp Ins. Associates, Inc. (2004) 115 Cal.App.4th 1145, 1154, quotation marks omitted.) 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 plaintiff 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.) “California courts have recognized a cause of action for negligent misrepresentation, i.e., a duty to communicate accurate information, in two circumstances. The first situation arises where providing false information poses a risk of and results in physical harm to person or property. The second situation arises where information is conveyed in a commercial setting for a business purpose.” (Friedman v. Merck & Co. (2003) 107 Cal.App.4th 454, 477.)

Here, this Court’s ruling as to this cause of action, and the first cause of action is the same, for the same reasons despite the slightly different elements. As such, as it relates to the harassing neighbor misrepresentation, this Court notes that the demurrer is OVERRULED. However, as to the parking and electrical/appliances, the demurrer is SUSTAINED with twenty (20) days leave to amend.

Fraudulent Concealment

Next, Demurring Defendants argue that Plaintiff has not stated sufficient facts to maintain a cause of action for 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.)

Based on the two above analysis on the First and Second causes of action, this Court’s analysis of the parking spot issue is the same. However, as far as the electrical issue is concerned, this Court notes a different analysis. Under this analysis, Defendants’ alleged knowledge of the electrical and appliance issues allegedly plaguing the subject property and failure to disclose these facts to Plaintiff are sufficient for the start of the fraudulent concealment issue. As noted above, Plaintiff meets the specificity requirements when it comes to baseline fraudulent causes of action as she has included facts speaking to the individuals, what they said, when they said, etc. However, what is missing from the Complaint is an allegation with respect to Demurring Defendants’ duty to disclose the material fact that was allegedly concealed. In fact, Plaintiff’s Complaint is devoid of any duty discussions. As such, this cause of action is SUSTAINED. Also, because of the failure to allege duty in Plaintiff’s Complaint in general, this cause of action for Fraudulent Concealment also fails as to the harassing neighbor issue. Plaintiff is granted twenty (20) days leave to file an amended Complaint.  

Intentional Infliction of Emotional Distress

Demurring Defendant argues that Plaintiff has not stated facts sufficient to maintain a cause of action for Intentional Infliction of Emotional Distress. “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.) Specifically, Demurring Defendants contend that Plaintiff’s Complaint lacks any allegations that Defendants knew of the neighbor’s conduct, or failed to disclose the easement, the oven, or the electricity, Plaintiff is unable to demonstrate that Demurring Defendants’ conduct was “extreme and outrageous.” Demurring Defendants also argue that Plaintiff cannot demonstrate any injuries or any injuries actually and proximately caused by Defendants because Plaintiff’s damages are speculative and based on conjecture. Instead, Demurring Defendants contend Plaintiff has admitted that Plaintiff’s damages stemmed from her neighbor, and with whom Defendants had no personal knowledge of his alleged tendencies.

Here, Plaintiff has certainly pled, at minimum, that Demurring Defendants had a reckless disregard of the probability of causing emotional distress. The Complaint alleges that Defendants, Searock, Pinky, Ahmad, and Kawata knew that Plaintiff was particularly vulnerable to emotional distress because during the time that Plaintiff was being shown the property, she let Pinky know that Plaintiff was a victim of prior physical abuse and because of this, she is more susceptible to emotional distress, especially stemming from the type of conduct committed by Murat against Plaintiff. (Complaint, ¶ 80.) Plaintiff further alleges that Defendants intended to cause harm, despite the probability that it would result in Plaintiff suffering severe emotional distress. (Complaint, ¶ 81.) Plaintiff contends that Defendants’ actions were a substantial factor in causing harm to Plaintiff, in the form of severe emotional distress. (Complaint, ¶ 82.) Plaintiff noted that Defendants knew about the neighbor’s violent tendencies, and despite, this, indicated that she would be safe. Here, the Court finds that such allegations would be not sufficient to allege a cause of action for Intentional Infliction of Emotional Distress.  These alleged facts may be sufficient to cause upset or anxiety to a reasonable person, but the allegations do not rise to the level of extreme nor outrageous misconduct as required by the standards for pleading an IIED cause of action.  The Demurrer is SUSTAINED with leave to amend.

Breach of Implied Warranty of Habitability

Demurring Defendant argues that Plaintiff’s Seventh Cause of Action fails to state sufficient facts for Breah of Warranty of Habitability. To establish a breach of the implied warranty of habitability, Plaintiffs must establish (1) “the existence of a material defective condition affecting the premises’ habitability,” (2) “notice to the landlord of the condition within a reasonable time after the tenant’s discovery of the condition,” (3) “the landlord was given a reasonable time to correct the deficiency, and” (4) “resulting damages.” (Erlach v. Sierra Asset Servicing, LLC (2014) 226 Cal.App.4th 1281, 1297.) Specifically, Demurring Defendants argues that Plaintiff failed to plead facts that an alleged 3-day electricity outage amounts to a breach. Demurring Defendant argues further that Plaintiff failed to plead how the alleged electrical outage or alleged exposed wiring were not in substantial compliance, or have materially affected her health and safety, or are the proximate cause of her damages. (Complaint, ¶¶ 21-22.)

Plaintiff’s Complaint alleges that Defendants Searock, Pinky, and Ahmad knowingly rented the Subject Property to Plaintiff without keeping the Subject Property in a habitable condition because the Subject Property fails to have electrical lighting and wiring and electrical equipment that complies with applicable law and building codes at the time of its installation, as well as the electrical system not being maintained in good working order. (Complaint, ¶ 88.) However, Plaintiff contends that the electrical system failure has been substantial and has existed the entirety of the time Plaintiff occupied the Subject Property. (Complaint, ¶ 88.) In fact, Plaintiff contends that the electricity went out in the subject property entirely from October 15, 2023 to October 19, 2023. (Complaint, ¶ 88.) Further, Plaintiff contends that she has done nothing in any way to contribute to the inhabitability of the Subject Property. (Complaint, ¶ 89.) Plaintiff had earlier in the Complaint, alleged that when she put Defendants on notice of the faulty wiring of the entire house, Plaintiff asserts that Pinky blamed her for the issues, knowing full and well that the electrical system was not wired correctly on the property. (Complaint, ¶ 22.) Plaintiff has alleged that the property has faulty electrical wiring that is not up to applicable building codes, and that the dangerous and exposed wires can be seen outside of the home, and the exposed wiring is in conspicuous locations throughout the outside of the house where children can be exposed to it and get electrocuted. (Complaint, ¶ 21.) Plaintiff has alleged that notice was provided to Searock, and that they waited a full three days to fix the issue, and that as of today, this issue is still not fixed as lights all over the property continue to flicker and periodically go out. (Complaint, ¶ 22.)

Here, the Court does not find that Plaintiff’s Complaint has pleaded sufficient facts to state a cause of action for Breach of the Implied Warranty of Habitability, but not for the reasons argued by Demurring Defendants. Here, the Complaint fails to allege how the electrical issue in this case is a breach of the implied warranty of habitability. For example, Plaintiff does not describe the consequence or effect of the habitability concerns.  Has Plaintiff been unable to keep food refrigerated? Has Plaintiff been unable to use cooking amenities? Has Plaintiff’s air conditioning or heating gone out? Without more, this Court notes that Plaintiff cannot maintain a cause of action for Breach of the Implied Warranty of Habitability. As such, the Demurrer as to this Cause of Action is SUSTAINED with twenty (20) days leave to amend.

Unlawful Self-Help by Landlord in Violation of Civil Code § 789.3.

 

Lastly, Demurring Defendants demur to Plaintiff’s Complaint on the grounds that they argue Plaintiff cannot maintain a cause of action for Violation of Civil Code § 789.3. Pursuant to Civil Code section 789.3, which provides at subdivision (a):  

 

“A landlord shall not, with intent to terminate the occupancy under any lease or other tenancy or estate at will, however created, of property used by a tenant as his residence willfully cause, directly or indirectly, the interruption or termination of any utility service furnished the tenant, including, but not limited to, water, heat, light, electricity, gas, telephone, elevator, or refrigeration, whether or not the utility service is under the control of the landlord.”  

 

In civil actions, the appellate courts have determined that a “landlord violates the statute only when he willfully interrupts a tenant's utility service with the intent to terminate occupancy.” (Kinney v. Vaccari (1980) 27 Cal.3d 348, 352 (Kinney).) A landlord found to have done so will be liable to her tenant for actual damages. (Civ. Code § 789 subd. (c).) 

 

Here, Demurring Defendants argue that no facts have been plead that give rise to Plaintiff’s belief that her internet was intentionally shut off at Defendants’ discretion. Demurring Defendants further argue that there are no allegations pled that Defendants misrepresented the use of the internet at the time that Plaintiff’s internet was allegedly disconnected. Defendant also argues that the Code section does not define “utilities” as including an internet connection.

 

First, this Court notes that Civil Code section 789.3 is not limited by the utilities listed in Public Utilities Code Section 216 and declines to sustain the Demurrer on this basis absent other legal authority. Next, this Court also notes that Plaintiff has alleged that Defendants cut off the internet at the Subject Property with the specific intent to force Plaintiff and her family to prematurely vacate the Subject Property. (Complaint, ¶ 95.) Such an allegation, paired with the fact that the internet is not excluded from the listed “utilities” under Civil Code section 789.3, this Court finds that Plaintiff has pled sufficient facts to allege a cause of action for Violation of Violation of Civil Code § 789.3.  As such, the Court OVERRULES the Demurrer as to this Cause of Action.