Judge: Wesley L. Hsu, Case: 21PSCV00615, Date: 2023-03-24 Tentative Ruling

Case Number: 21PSCV00615    Hearing Date: March 24, 2023    Dept: L

Background   

 

Plaintiff Ford Motor Credit Company LLC (“Plaintiff”) alleges as follows: On September 21, 2020, Defendants Erick Contreras (“Contreras”) and Maria Garcia (“Garcia”) (together, “Defendants”) entered into a Retail Installment Sales Contract with Performance Ford (“Dealership”), wherein Defendants purchased a new 2020 Ford F150, VIN #1 FTEW1 EPXLKE87751 from Dealership and agreed to make payments on same. Dealership subsequently assigned the Contract to Cab West LLC; Plaintiff is Cab West LLC’s servicing agent. Defendants defaulted under the terms and conditions of the contract by, inter alia, failing to make installment payments.

 

On July 29, 2021, Plaintiff filed a complaint, asserting causes of action against Contreras, Garcia and Does 1-100 for:

 

1.      Possession of Personal Property and Breach of Contract

2.      Possession of Personal Property and Breach of Contract

3.      Goods Sold and Delivered

4.      Book Account

5.      Account Stated

 

On December 16, 2021, Defendants’ defaults were entered.

 

On July 11, 2022, default judgment was filed.

 

On October 31, 2022, an abstract of judgment and a writ of execution were issued.

 

Discussion

 

Plaintiff/Judgment Creditor opposes the Claim of Exemption submitted by Garcia.

 

TIMELINESS: A claim of exemption may be made by the judgment debtor any time during the withholding period. (Code Civ. Proc., § 706.105, subd. (a).) An exemption may be claimed only once, however, unless there has been a “material change in circumstances” since the time of the last prior hearing on the earnings withholding order. (Id.)

 

A judgment creditor wishing to oppose a claim of exemption must file a notice of opposition with the levying officer within 10 days after the notice of claim of exemption was mailed. (Code Civ. Proc., § 706.105, subd. (d).) “(This 10–day period is not extended where the claim of exemption was served by mail; see CCP § 684.310 and Comment to CCP § 706.105.).” Ahart, CAL. PRAC. GUIDE: ENFORCING JUDGMENTS AND DEBTS (The Rutter Group 2021) ¶ 6:1192.

 

If a notice of opposition is timely filed, the judgment creditor is entitled to a hearing on the claim of exemption. (Code Civ. Proc., § 706.105, subd. (e).) If the judgment creditor desires a hearing, the judgment creditor must file a notice of motion for an order determining the claim of exemption with the court within 10 days after the date the levying officer mailed the notice of claim of exemption. (Id.) (This 10–day period is not extended where the claim of exemption was served by mail; see CCP § 684.310 and Comment to CCP § 706.105.).” Ahart, supra, at ¶ 6:1195. If the notice of opposition and notice of motion are timely filed, the court hearing on the claim of exemption must be held no more than 30 days after the notice of motion is filed (unless continued by the court for good cause). (Code Civ. Proc., § 706.105, subd. (e).)

 

The judgment creditor must give written notice of the hearing to the levying officer at least 16 court days prior to the hearing. (Code Civ. Proc., § 706.105, subd. (e); Code Civ. Proc., § 1005, subd. (b).) The judgment creditor must also serve a copy of the notice of opposition and notice of hearing at least 16 court days before the hearing on the judgment debtor at the address set forth in the claim of exemption. (Code Civ. Proc., § 706.105, subd. (e).)

 

The Notice of Filing Claim of Exemption states it was mailed on January 25, 2023. The Notice of Hearing on Claim of Exemption and the Notice of Opposition to Claim of Exemption were mail-served on Garcia on February 2, 2023 and filed with the court that day and stamped received by the levying officer on February 3, 2023. The hearing date was originally scheduled for March 15, 2023, but subsequently continued by the court to March 24, 2023.

 

It is unclear whether or not the parties are aware of the March 24, 2023 hearing date [see footnote]. The following ruling on the merits, then, is contingent upon the court being provided with proof that adequate notice of the March 24, 2023 hearing date was provided.

 

MERITS:

 

The maximum amount of disposable earnings of an individual judgment debtor for any workweek that is subject to levy under an earnings withholding order must not exceed the lesser of the following: (1) 25% of the individual's disposable earnings for that week or (2) 50% of the amount by which the individual's disposable earnings for that week exceed 40 times the state minimum hourly wage in effect at the time [i.e., $14.00 per hour for employers with 25 or fewer employees and $15.00 per hour for employers with 26 or more employees, as of January 1, 2022; see Lab. Code, § 1182.12.]. If the local minimum hourly wage is greater than the state minimum hourly wage, the local minimum hourly wage in effect at the time the earnings are payable is to be used for this calculation. (See Ahart, supra, at ¶ 6:1170; Code Civ. Proc., § 706.050, subd. (a).) For a biweekly pay period, the multiplier used to determine the maximum amount of disposable earnings subject to levy under an earnings withholding order that is proportional to the above calculation is as follows: multiply the applicable hourly minimum wage by 80 work hours. Code Civ. Proc., § 706.050, subd. (a).) “Disposable earnings” are those earnings remaining after deduction of any amounts required by law to be withheld. (Code Civ. Proc., § 706.011, subd. (a).)

 

In addition to the automatic exemption for nonsupport withholding orders, that portion of an employee's earnings necessary for the support of the judgment debtor or his or her family is exempt from nonsupport earnings withholding orders (Code Civ. Proc., § 706.051, subds. (a),(b)).

 

The exemption claimant has the burden of proof. (Code Civ. Proc., § 703.580, subd. (b).)

 

Garcia represents in her Claim of Exemption that all of her earnings are needed to support herself or her family; that she is paid every two weeks and that she is willing to have $100.00 withheld from her earnings each pay period during the withholding period; that her gross monthly pay is $3,000.00; that she owns the following property: $2,000.00 at U.S. Bank, $26,000.00 car and $64,000.00 jeep and that she has no spouse. Garcia, however, fails to provide any information as to her take-home pay or as to any other income sources.

 

Additionally, Garcia represents, in ¶ 4, subdivisions (a)-(m) of her Financial Statement, that she has $1,760.00 on monthly expenses, yet somehow concludes, in subdivision (n) (which asks for Garcia to add (a)-(m)) that her total monthly expenses are $3,110.00.

 

Garcia also represents, in ¶ 5 of her Financial Statement, that she owes $63,000.00, payable in monthly payments of $850.00, for the Jeep, but fails to identify any creditor. She represents that she owes $26,000.00, payable in monthly payments of $500.00, for a “can am,” but again fails to identify any creditor. These purported debts were not identified in ¶ 4, subdivision (j).

 

Plaintiff/Judgment Creditor, in turn, advises that it has not received the response to the earnings withholding order and is unaware of Garcia’s salary. Plaintiff/Judgment also points out that $1,550/month is, per Garcia’s representations, directed towards transportation, a new car note and a “can am,” which denotes an ability to pay towards the judgment. Plaintiff/Judgment Creditor further points out that Garcia is impermissibly attempting to self-prioritize debts.

 

Garcia has failed to carry her burden of establishing entitlement to an exemption.  The claim of exemption is denied.