Judge: Serena R. Murillo, Case: 19STCV45161, Date: 2022-12-21 Tentative Ruling

Case Number: 19STCV45161     Hearing Date: December 21, 2022    Dept: 29

TENTATIVE

 

Plaintiff Brandon Joaquin Rodarte Ayala’s Motion for Leave of Court to File First Amended Complaint is DENIED.

 

Legal Standard

 

“The court may, in furtherance of justice, and on any terms as may be proper, allow a party to amend any pleading or proceeding by adding or striking out the name of any party, or by correcting a mistake in the name of a party, or a mistake in any other respect; and may, upon like terms, enlarge the time for answer or demurrer. The court may likewise, in its discretion, after notice to the adverse party, allow, upon any terms as may be just, an amendment to any pleading or proceeding in other particulars; and may upon like terms allow an answer to be made after the time limited by this code.” (C.C.P. § 473(a)(1).)

 

“Trial courts are vested with the discretion to allow amendments to pleadings ‘in furtherance of justice.’ That trial courts are to liberally permit such amendments, at any stage of the proceeding, has been established policy in this state since 1901.” (Hirsa v. Superior Court (1981) 118 Cal.App.3d 486, 488-489.)

 

California Rules of Court, uule 3.1321(a) requires that a motion to amend must: “[i]nclude a copy of the proposed… amended pleading… [and] state what allegations in the previous pleading are proposed to be [deleted and/or added], if any, and where, by page, paragraph, and line number, the [deleted and/or additional] allegations are located…”

 

Rules of Court, rule 3.1324(b) provides, as follows: “[a] separate declaration must accompany the motion and must specify: (1) The effect of the amendment; (2) Why the amendment is necessary and proper; (3) When the facts giving rise to the amended allegations were discovered; and (4) The reasons why the request for amendment was not made earlier.”

 

Discussion

 

The Court finds it proper to deny Plaintiff Brandon Joaquin Rodarte Ayala’s (“Plaintiff”) motion for leave to file a first amended complaint (“FAC”) for the following reasons.

 

First, as Defendant Xue Zhe Jin (“Defendant”) points out in his opposition, Plaintiff’s moving papers do not comply with California Rules of Court, rule 3.1321(a) and 3.1324(b) above. The motion fails to state where, by page, paragraph, and line number, the additional allegations are located. In addition, Plaintiff’s counsel’s declaration fails to explain why the request for amendment was not made earlier.

 

Second, and related to the point above, Plaintiff unduly delayed in bringing this motion. Plaintiff argues that he “recently discovered” facts that would cast doubt on Defendant’s insurer’s affidavit which declared that Defendant was not acting within the scope of his employment at the time of the automobile collision. However, Plaintiff’s counsel’s declaration shows Plaintiff already doubted that declaration even before he filed this lawsuit. Counsel testifies that months before Plaintiff filed this lawsuit (on December 23, 2019), Plaintiff received an affidavit from Defendant’s insurer on May 20, 2019 (the “Affidavit”), declaring that Defendant was not in the course of employment at the time of incident. (Motion, declaration of Christian Kim (“Kim Decl.”), ¶ 4.) In response to that Affidavit, Plaintiff’s counsel sent a letter to the insurer informing them that “Plaintiff is in possession of facts that indicate [Defendant] was in the course of employment at the time of the incident.” (Kim Decl., ¶ 4 [emphasis added].) After counsel threatened that Plaintiff will not release Defendant from liability until the insurer provides the contact information of Defendant’s employer, the insurer (on or around June 19, 2019) replied as follows: “It appears [Defendant] did pick up some supplies for the construction site just prior to the loss.” (Kim Decl., ¶ 6.) Therefore, months before Plaintiff even commenced this lawsuit, he was already “in possession of facts” that casted doubt of the insurer’s declaration in the Affidavit that Defendant was not acting within the scope of his employment at the time of the incident. The insurer’s response also suggested to Plaintiff that his suspicions were correct. Therefore, Plaintiff could have brought his proposed causes of action at the beginning of this lawsuit and, in fact, fails to explain why he did not seek discovery as to that issue until this year in 2022. Accordingly, Plaintiff cannot now claim that he “recently discovered” facts for which he now seeks leave to add.

 

Third, Defendant will be prejudiced by the amendment. Trial is only months away and this case is quickly approaching its 5-year mark. Defendant has pending motions based on the allegations in the Complaint, including a motion for summary judgment. Allowing the Plaintiff to amend his Complaint now will result in the Court moving the trial date as Defendant will need sufficient time to respond to the Complaint, conduct discovery on the new allegations, and file dispositive motions (if any).

 

For those reasons, Plaintiff’s motion to amend his Complaint is denied. 

 

Conclusion

 

Plaintiff Brandon Joaquin Rodarte Ayala’s Motion for Leave of Court to File First Amended Complaint is DENIED.

 

Moving party is ordered to give notice.  

 ***

TENTATIVE
Attorney James Y. Chu's motion to be relieved as counsel  for defendants James Ha and IPark, Inc. is GRANTED. 

               Counsel has filed the requisite forms pursuant to CRC Rule 3.1362.  Counsel has served the forms on Defendants and opposing counsel and confirmed Defendants’ addresses by Latest Statement of Information filed with the California Secretary of State by providing that defendant I Park, Inc.’s address, 1025 S. Alvarado St., Suite 100, Los Angeles, CA 90006 is listed as both the Principal and Mailing Address for I Park Inc, and Defendant James Ha is listed as the Chief Executive Officer, Secretary, Chief Financial Officer, and Registered Agent for Service of Process for I Park Inc. at the same address.

 

               Counsel declares that irreconcilable differences of opinion between Defendants and Counsel has led to a complete breakdown in the attorney-client relationship. 

 

As the Final Status Conference is set for March 13, 2023, and trial is set for March 27, 2023, Defendants will not suffer prejudice if Counsel is permitted to withdraw. 

Court sets an OSC re: Status of Defendant's Representation on March 1, 2023 at 10:00 a.m.

 

               Accordingly, the motion to be relieved as counsel is GRANTED.  Attorney Chu to give notice of this order, and the OSC date.  The order will become effective upon filing the proof of service with the court.