Judge: William A. Crowfoot, Case: 23AHCV02879, Date: 2025-01-31 Tentative Ruling
Case Number: 23AHCV02879 Hearing Date: January 31, 2025 Dept: 3
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - NORTHEAST
DISTRICT
Plaintiff State Farm Fire &
Casualty Insurance Companies (“Plaintiff”) seeks a default judgment against
defendant JM Drywall Pro Inc. (“Defendant”) for $45,965.14, consisting of
$36,843.02 in unpaid premiums for a worker’s compensation insurance policy,
$8,354.52 in prejudgment interest, and $767 in costs.
Plaintiff’s evidence does not
sufficiently explain the amounts purportedly owed. Plaintiff’s representative,
Paul Ortiz, declares that he is the Underwriting Section Manager and authenticates
a Final Premium Audit Billing statement dated January 31, 2022, for $7,942 in
additional premiums following a policy audit for the policy term September 9, 2020,
to September 9, 2021. (Oritz Decl., Ex. B [pp. 52-53 of PDF].)
Another Final Premium Audit Billing statement
prepared October 18, 2022, reflects that $28,901.02 was owed for the policy
term of September 9, 2021, to April 1, 2022. This amount includes a $19,240
“audit noncompliance charge.” (Ex. B [pp. 56-57 of PDF].) The insurance policy
provides that an audit noncompliance charge may be applied if the insured fails
to allow the examination and audit of its records. The method of calculating
this charge is established in a schedule. (Ortiz Decl., Ex. A [p. 38 of PDF].)
The schedule states “$2,122.00” in the column labeled “Basis of Audit
noncompliance Charge” and “0.000” for “Maximum Audit Noncompliance Charge
Multiplier.” (Ibid.) Based on the language of this policy, it is unclear
how the charge of $19,240 was reached and where Defendant agreed to be liable
for that amount.
Additionally, even if the charge were
appropriate, the evidence submitted does not support a judgment of $36,843.02
because the October 18, 2022 premium due states that $28,901.02 is owed. Overall,
it is unclear how the documents submitted support the judgment requested.
The hearing on the default prove-up is
CONTINUED to _____________ at 8:30 a.m. in Department 3 of the Alhambra
Courthouse so that Plaintiff may submit additional explanatory briefing and, if
necessary, evidence supporting its application for default judgment. Any
revised or additional papers must be filed no later than 5 court days before
the date of the hearing.
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.