Judge: Salvatore Sirna, Case: 22PSCV00446, Date: 2023-08-14 Tentative Ruling

The Court may change tentative rulings at any time. Therefore, counsel are advised to check this website periodically to determine whether any changes or updates have been made to the tentative ruling. Counsel may submit on a tentative ruling by calling the clerk in Department G at (909) 802-1104 prior to 8:30 a.m. the morning of the hearing.


Case Number: 22PSCV00446    Hearing Date: February 5, 2024    Dept: G

Defendants Yanlin Li, Fiorano Motorsport LLC, Bianco Corsa Motorsport, Inc., and Yokohama Imports USA, LLC’s Demurrer to Plaintiffs’ Third Amended Complaint

 

Respondent: Plaintiffs M Capital Global California and Sokly Chen

 

Defendants Yanlin Li, Fiorano Motorsport LLC, Bianco Corsa Motorsport, Inc., and Yokohama Imports USA, LLC’s Motion to Strike Portions of Plaintiffs’ Third Amended Complaint

 

Respondent: NO OPPOSITION

 

TENTATIVE RULING

 

Defendants Yanlin Li, Fiorano Motorsport LLC, Bianco Corsa Motorsport, Inc., and Yokohama Imports USA, LLC’s Demurrer to Plaintiffs’ Third Amended Complaint is OVERRULED.  Defendants to file their Answer in ten (10) days.

 

Defendants Yanlin Li, Fiorano Motorsport LLC, Bianco Corsa Motorsport, Inc., and Yokohama Imports USA, LLC’s Motion to Strike Portions of Plaintiffs’ Third Amended Complaint is DENIED.

 

BACKGROUND

 

This is an action for breach of contract and fraud. In August 2021, Plaintiff Sokly Chen, a member of Plaintiff M Capital Global California (M Capital), met with Defendant Yanlin Li who invited Chen to invest in Li’s vehicle dealership business by purchasing a 50% ownership interest in Fiorano Motorsport LLC (Fiorano Motorsport) for $1,000,000. On September 22, Li prepared an operating agreement that established Li and M Capital would be members of Fiorano Motorsport. That same month, M Capital provided an additional $1,500,000 at Li’s request so Fiorano Motorsport could allegedly open a dealership. In total, M Capital invested a total of $6,683,000 in Fiorano Motorsport. However, Plaintiffs allege Li subsequently embezzled most of these funds through personal use or transferring the funds to other entities.

 

In February 2022, Fiorano Motorsport’s account had been drained of funds as Li had been allegedly transferring the money to Li’s personal accounts and pocketing revenue from purchases. When Li requested a $2,350,000 investment from M Capital to cover expenses, M Capital questioned why the sale revenue was insufficient. In response, Li claimed there was insufficient revenue and that Li had used personal money to purchase vehicles. Li then claimed the $2,350,000 was debt owed by M Capital and began attempting to collect this debt by allegedly threatening M Capital employees, attempting to break into M Capital’s office, falsely reporting Chen to law enforcement for vehicle theft, and stalking Chen.

 

On May 10, 2022, M Capital filed a complaint against Li, Fiorano Motorsport, Bianco Corsa Motorsport, and Does 1-50, alleging the following causes of action: (1) fraud, (2) breach of fiduciary duty, (3) breach of oral contract, (4) common counts, (5) conversion, and (6) accounting.

 

On September 12, 2022, Plaintiffs filed a First Amended Complaint (FAC) against Li, Fiorano Motorsport, Bianco Corsa Motorsport (Bianco Corsa), and Yokohama Imports USA, LLC (Yokohama, collectively Defendants) as well as Does 1-50, alleging the following causes of action: (1) fraud, (2) breach of fiduciary duty, (3) breach of contract, (4) breach of quasi contract, (5) involuntary dissolution under Corporations Code section 17707.03, (6) common counts, (7) conversion, (8) accounting, (9) offer and sale of unqualified, non-exempt securities in violation of Corporations Code section 25110, (10) misrepresentation and/ or omissions of material facts in violation of Corporations Code section 25401, (11) unlawful sale of securities under the Securities Act of 1933, section 5, (12) unlawful fraudulent scheme under the Securities Act of 1933, section 17, (13) unlawful business practices under Business & Professions Code section 17200, and (14) intentional infliction of emotional distress.

 

On April 11, 2023, the court sustained Defendants’ demurrer to Plaintiffs’ FAC in part and overruled it in part.

 

On May 11, 2023, Plaintiffs filed a Second Amended Complaint (SAC) against the same Defendants alleging the following causes of action: (1) fraudulent inducement, (2) fraud, (3) breach of fiduciary duty, (4) breach of contract, (5) breach of quasi contract, (6) involuntary dissolution pursuant to Corporations Code section 17707.03, (7) common counts, (8) conversion, (9) accounting, (10) sale of securities by unlicensed broker-dealer in violation of Corporations Code section 25501.5 et seq., (11) offer and sale of unqualified, non-exempt securities in violation of Corporations Code sections 25503, 25504, 25504.1, and 25110 et seq., (12) offer misrepresentations and/or omissions of material facts in violation of Corporations Code sections 25401, 25403, and 25404 et seq., (13) unlawful sale of securities pursuant to Securities Act, section five, (14) unlawful fraudulent scheme pursuant to the Securities Act, section 17, (15) unlawful business practices pursuant to Business and Professions Code section 17200, and (16) intentional infliction of emotional distress (IIED).

 

On October 18, 2023, the court sustained Defendants’ demurrer to Plaintiffs’ SAC in part and overruled it in part.

 

On November 6, 2023, Plaintiffs filed a Third Amended Complaint (TAC) against the same defendants alleging the same causes of action.

 

On January 5, 2024, Defendants filed the present demurrer and motion to strike. Prior to filing on December 22, 2023, Defendants’ counsel met and conferred telephonically with Plaintiffs’ counsel and was unable to reach a resolution. (Lee Decl., ¶ 18.)

 

A hearing on the demurrer and motion to strike is set for February 5, 2024, along with a case management conference.

 

REQUEST FOR JUDICIAL NOTICE


Defendants request the court take judicial notice of a membership interest purchase and sale agreement between Li and M Capital pursuant to Evidence Code sections 452, subdivision (h) and 453. Evidence Code section 452, subdivision (h) allows the court to take judicial notice of “[f]acts and propositions that are not reasonably subject to dispute and are capable of immediate and accurate determination by resort to sources of reasonably indisputable accuracy.” But “case law holds that ‘the existence of a contract between private parties cannot be established by judicial notice under Evidence Code section 452, subdivision (h).’” (Travelers Indemnity Company of Connecticut v. Navigators Specialty Insurance Company (2021) 70 Cal.App.5th 341, 354, quoting Gould v. Maryland Sound Industries, Inc. (1995) 31 Cal.App.4th 1137, 1145.) Thus, Defendants’ request is DENIED.

 

ANALYSIS


Demurrer


Defendants demur to Plaintiffs’ entire TAC on the grounds that (1) Plaintiffs lack standing to bring a derivative action and (2) Plaintiffs’ TAC fails to allege sufficient facts to state a claim as to each of the sixteen causes of action. For the following reasons, the court OVERRULES Defendants’ demurrer in its entirety.

 

Legal Standard

 

A party may demur to a complaint on the grounds that it “does not state facts sufficient to constitute a cause of action.” (Code Civ. Proc., § 430.10, subd. (e).) A demurrer tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747 (Hahn).) When considering demurrers, courts accept all well pleaded facts as true. (Fox v. JAMDAT Mobile, Inc. (2010) 185 Cal.App.4th 1068, 1078.) 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 pleadings alone and not the evidence or other extrinsic matters. Therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed.” (SKF Farms v. Superior Court (1984) 153 Cal.App.3d 902, 905.) “The only issue involved in a demurrer hearing is whether the complaint, as it stands, unconnected with extraneous matters, states a cause of action.” (Hahn, supra, at p. 747.)

 

Standing

 

Defendants argue Plaintiffs lack standing to bring a derivative action because they did not satisfy the procedural requirements for a derivative action. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 3.)

 

Fraud (First and Second Causes of Action)

 

Defendants contend M Capital’s first cause of action for fraudulent inducement and second cause of action for fraud against Li fail to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 4.) Accordingly, Defendants’ demurrer to these causes of action is OVERRULED.

 

Breach of Fiduciary Duty (Third Cause of Action)

 

Li maintains M Capital’s third cause of action for breach of fiduciary duty fails to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 5.) Accordingly, Defendants’ demurrer to this cause of action is OVERRULED.

 

Breach of Contract (Fourth and Fifth Causes of Action)

 

Defendants argue M Capital’s fourth cause of action for breach of contract and fifth cause of action for breach of quasi contract fail to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 6.) Accordingly, Defendants’ demurrer to these causes of action is OVERRULED.

 

Involuntary Dissolution (Sixth Cause of Action)

 

Fiorano Motorsport contends M Capital’s sixth cause of action for involuntary dissolution fails to plead sufficient facts to state a claim because the Corporations Code requires “specific events to occur” and M Capital has “failed to properly plead the necessary events.” In particular, Fiorano Motorsport contends Corporations Code section 17708.03, subdivision (b)(5) requires judicial dissolution of an LLC when “[t]hose in control of the limited liability company have been guilty of, or have knowingly countenanced, persistent and pervasive fraud, mismanagement, or abuse of authority.”

 

But in this case, the TAC has adequately pled such events as it has sufficiently alleged causes of action for fraud and conversion against Li. Accordingly, Defendants’ demurrer to this cause of action is OVERRULED.

 

Common Counts and Accounting (Seventh and Ninth Causes of Action)

 

Defendants maintain M Capital’s seventh cause of action for common counts and ninth cause of action for accounting fail to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 7.) Accordingly, Defendants’ demurrer to these causes of action is OVERRULED.

 

Conversion (Eighth Cause of Action)

 

Defendants argue M Capital’s eighth cause of action for conversion fails to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 7.) Accordingly, Defendants’ demurrer to this cause of action is OVERRULED.

 

Securities Law Violations (10th, 11th, 12th, 13th, and 14th Causes of Action)

 

Defendants contend M Capital’s tenth, eleventh, twelve, thirteenth, and fourteenth causes of action for securities law violations fail to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 8-10.) Accordingly, Defendants’ demurrer to these causes of action is OVERRULED.

 

Unlawful Business Practices (Fifteenth Cause of Action)

 

Defendants maintain M Capital’s fifteenth cause of action for unlawful business practices fails to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 10.) Accordingly, Defendants’ demurrer to this cause of action is OVERRULED.

 

IIED (Sixteenth Cause of Action)

 

Li argues Chen’s sixteenth cause of action for IIED fails to plead sufficient facts to state a claim. This argument fails for the same reasons noted in the court’s ruling on Defendants’ previous demurrer. (10/18/2023 Ruling, p. 10.) Accordingly, Defendants’ demurrer to this cause of action is OVERRULED.

 

Motion to Strike

 

Defendants move to strike punitive damages from Plaintiffs’ TAC as well assorted statements from Plaintiffs’ SAC. For the following reasons, the court DENIES Defendants’ motion.

 

Legal Standard

 

Motion to Strike


Upon a party’s motion or the court’s own motion, the court may strike any irrelevant, false, or improper matter inserted in any pleading. (Code Civ. Proc., § 436, subd. (a).) The court may also “[s]trike 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.” (Code Civ. Proc., § 436, subd. (b).) “The grounds for a motion to strike shall 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, subd. (a).)

 

An immaterial or irrelevant allegation includes “(1) An allegation that is not essential to the statement of a claim or defense,” “(2)¿An allegation that is neither pertinent to nor supported by an otherwise sufficient claim or defense,” or “(3)¿A demand for judgment requesting relief not supported by the allegations of the complaint or cross-complaint.” (Code Civ. Proc., § 431.10.)

 

Punitive Damages


Civil Code section 3294 allows punitive damages when a plaintiff establishes by clear and convincing evidence that a defendant is guilty of oppression, fraud, or malice. (Civ. Code, § 3294, subd. (a).) For the purposes of determining punitive damages, 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 of the rights or safety of others.” (Civ. Code, § 3294, subd. (c)(1).) Oppression is defined as “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).) Lastly, fraud is defined as “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).)

 

“In addition to the requirement that the operative complaint set forth the elements as stated in section 3294, it must include specific factual allegations showing that defendant's conduct was oppressive, fraudulent, or malicious to support a claim for punitive damages.” (Today’s IV, Inc. v. Los Angeles County Metropolitan Transportation Authority (2022) 83 Cal.App.5th 1137, 1193.) Furthermore, “[p]unitive damages may not be pleaded generally.” (Ibid.)

 

Discussion

 

In this case, as noted above, the TAC has adequately alleged causes of action for fraud. Thus, punitive damages allegations are not unsupported. To the extent Defendants also seek to strike paragraphs from the SAC, the court notes the SAC is no longer the operative complaint. And even if Defendants had properly cited to the correct operative complaint, Defendants also fail to develop their argument and explain in detail why each paragraph must be stricken.

 

Accordingly, Defendants’ motion is DENIED.

 

CONCLUSION


Based on the foregoing, Defendants’ demurrer to Plaintiffs’ TAC is OVERRULED in its entirety.

 

Furthermore, Defendants’ motion to strike portions of Plaintiffs’ TAC is DENIED.


Defendants to file an Answer in ten (10) days.