Judge: William A. Crowfoot, Case: 23AHCV02759, Date: 2024-11-19 Tentative Ruling
Case Number: 23AHCV02759 Hearing Date: November 19, 2024 Dept: 3
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - NORTHEAST
DISTRICT
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Plaintiff(s), vs. Defendant(s). |
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[TENTATIVE]
ORDER RE: Dept.
3 8:30
a.m. |
I.
INTRODUCTION
Plaintiffs
Jennifer Haag and Anthony Giron (“Plaintiffs”) seek leave of court to file a
First Amended Complaint (“FAC”). Plaintiffs initiated this action against
defendant John Rodriguez (“Defendant”) on November 28, 2023, asserting causes
of action for breach of contract, breach of warranty of habitability, breach of
covenant of quiet enjoyment, negligence, and violation of Los Angeles Code of
Ordinances section 8.52.130, arising from their tenancy at 289 Hampden Terrace,
Alhambra, California 91801.
On August 14,
2024, Plaintiffs filed this motion to add claims under the Fair Housing Act
(“FHA”), 42 U.S.C. 3601, et seq., the Americans of Disabilities Act (“ADA”), 42
U.S.C. § 12101 et seq., and the California Disabled Persons Act (“DPA”),
California Civil Code sections 54-55.53
Defendant filed
an opposition brief on November 5, 2024.
No reply
brief is on file.
II.
LEGAL
STANDARD
The court may, in its discretion and
after notice to the adverse party, allow, upon any terms as may be just, an
amendment to any pleading, including adding or striking out the name of any
party, or correcting a mistake in the name of a party, or a mistake in any
other respect. (Code Civ. Proc., § 473, subd. (a)(1).) “Public policy dictates
that leave to amend be liberally granted.” (Centex
Homes v. St. Paul Fire & Marine Ins. Co. (2015) 237 Cal.App.4th 23,
32.) “Although courts are bound to apply a policy of great liberality in
permitting amendments to the complaint at any stage of the proceedings, up to
and including trial . . . this policy should be applied only ‘where no
prejudice is shown to the adverse party.’ [Citation]. A different result is
indicated ‘where inexcusable delay and probable prejudice to the opposing
party’ is shown. [Citation.]” (Magpali v.
Farmers Group, Inc. (1996) 47 Cal.App.4th 471, 487.)
A motion to amend a pleading must
include a copy of the proposed amendment or amended pleading which must be
serially numbered to differentiate it from previous pleadings or amendments and
must state what allegations in the previous pleading are proposed to be deleted
or added, if any, and where, by page, paragraph, and line number, the
allegations are located. (Cal. Rules of
Court, Rule 3.1324(a).) The motion shall also be accompanied by a declaration
attesting to the effect of the amendment, why the amendment is necessary and
proper, when the facts giving rise to the amended allegations were discovered,
and why the request for amendment was not made earlier. (Cal. Rules of Court,
Rule 1.324(b).)
III.
DISCUSSION
Plaintiffs seek leave to add claims
under the FHA, ADA, and CDA to “address newly discovered facts that support
these claims.” (Motion, p. 6.) Plaintiff’s counsel declares that the facts
giving rise to the amended allegations were “discovered during mediation in
this matter which took place in July 2024.” (Ibid.) Plaintiff’s counsel
states that during the mediation, it was revealed that the premises were not
compliant with ADA standards, contrary to the information previously available
to Plaintiffs. (Ibid.) Plaintiff’s counsel further avers that Plaintiffs
could not request leave to amend earlier because they “did not have access to
the critical information regarding ADA compliance.” (Ibid.)
Plaintiffs’ motion and accompanying
declaration are conclusory and Plaintiffs fail to specify what “new facts”
emerged which necessitate the amendment. Also, Plaintiffs do not explain how
any “new facts” about the premises could not have been discovered previously by
the Plaintiffs inasmuch as they occupied the premises. The proposed amendments
allege that plaintiff Jennifer Haag was denied accommodations for her
wheelchair during her tenancy. (Motion, Ex. A, ¶¶ 47, 50, 53.) Accordingly, Plaintiffs
fail to comply with CRC 3.1324 because they do not state the underlying facts
supporting the new claims and their inability to discover them earlier.
IV.
CONCLUSION
Based on the foregoing, Plaintiffs’
motion is DENIED.
Moving party to give notice.
Dated
this
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William A. Crowfoot Judge of the Superior Court |
Parties who intend to submit on this
tentative must send an email to the Court at ALHDEPT3@lacourt.org indicating
intention to submit on the tentative as directed by the instructions provided
on the court website at www.lacourt.org. Please be advised that if you submit
on the tentative and elect not to appear at the hearing, the opposing party may
nevertheless appear at the hearing and argue the matter. Unless you receive a
submission from all other parties in the matter, you should assume that others
might appear at the hearing to argue. If the Court does not receive emails from
the parties indicating submission on this tentative ruling and there are no
appearances at the hearing, the Court may, at its discretion, adopt the
tentative as the final order or place the motion off calendar.