Judge: William A. Crowfoot, Case: 24AHCP00024, Date: 2024-10-03 Tentative Ruling
Case Number: 24AHCP00024 Hearing Date: October 3, 2024 Dept: 3
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - NORTHEAST
DISTRICT
I.
INTRODUCTION
National Default Servicing Corporation
(“NDSC”) commenced this special proceeding on January 17, 2024. This special
proceeding arises because from a trustee’s sale of real property which resulted
in a surplus of funds. The property that was encumbered by the deed of trust is
located at 540 N. Marengo Avenue, Apt. 3, Pasadena, CA 911011. The trustor on
the deed of trust was Robert G. May, who passed away on March 31, 2012.
A trustee’s sale was held on September
19, 2022. The total sale price of the property was $625,500. Surplus funds in
the amount of $232,364.85 were deposited with the Court and on June 3, 2024,
the Court set a hearing on all potential claims to the surplus funds for July
23, 2024. All potential claims were to be filed at least 15 days before the
hearing date.
II.
LEGAL
STANDARD
Civil Code section 2924j(c) permits a trustee
unable to determine the priority of claims to the surplus from a trustee's sale
to file a declaration of the unresolved claims and deposit the undistributed
proceeds with the clerk of the Superior Court in which the sale occurred. Upon
deposit of that portion of the sale proceeds that cannot be distributed by due
diligence, the trustee shall be discharged of further responsibility for the
disbursement of sale proceeds. Any amount deposited by the Trustee with the
clerk is deposited by the clerk with the County Treasurer subject to order of
the Superior Court upon the application of any interested party.
Civil Code section 2924k specifies the
following order of priority for distribution of the proceeds:
1) To the costs and expenses of
exercising the power of sale and of sale, including the payment of the
trustee's fees and attorney's fees.
2) To the payment of the obligations
secured by the deed of trust or mortgage which is the subject of the trustee's
sale.
3) To satisfy the outstanding balance
of obligations secured by any junior liens or encumbrances in the order of
their priority.
4) To the trustor or the trustor's
successor in interest. In the event the property is sold or transferred to
another, to the vested owner of record at the time of the trustee's sale.
The first and second priorities were
satisfied when the obligations secured by the deed of trust were paid and the
trustee's fees and expenses were paid. (Petition, ¶ 16(e)-(g).)
III.
DISCUSSION
On February 16, 2024, Marti Mackey
filed a response to NDSC’s petition arguing that the property is subject to an
existing probate case (Case No. 17STPB00634) and that she is filing a wrongful
foreclosure lawsuit.
On February 28, 2024, a claim was filed
by Malia M. Cohen, State Controller of California, for surplus proceeds in the
amount of $3,250.87. The State Controller has a lien on the property dated
April 25, 2007, which was recorded on May 14, 2007.
On March 19, 2024, NDSC filed a reply
to Mackey’s response stating that the hypothetical challenge to the foreclosure
sale should not impact its ability to deposit the surplus proceeds. NDSC also
addressed the various issues regarding notice raised by Mackey. Mackey filed a
reply purporting to rebut NDSC’s arguments and reiterating claims of a wrongful
foreclosure.
On March 28, 2024, the Court granted
NDSC’s petition to deposit the proceeds and the proceeds were subsequently
deposited with the clerk.
On July 9, 2024, Elizabeth M. Armstrong
filed correspondence requesting “due consideration in the distribution of any
surplus funds” in accordance with May’s will. Armstrong does not have a
recorded interest in the property and therefore is not entitled to a
distribution of funds through this special proceeding, which is intended to satisfy
the obligations secured by junior lienholders. (Cal-Western Reconveyance
Corp. v. Reed (2007) 152 Cal.App.4th 1308, 1318.)
On July 11, 2024, Mackey filed a
“response to hearing re: surplus funds” citing to the probate case as well as an
action for wrongful foreclosure, quiet title, and cancellation of documents
(Case No. 24NNCV02639), filed on July 1, 2024, and assigned to the Honorable
Ian C. Fusselman, Department T of the Alhambra Courthouse. This wrongful
foreclosure action is brought by Mackey as an individual and as the
administrator of the Estate of Robert G. May against NDSC, among others. Mackey
seeks declaratory relief and decrees cancelling the trustee’s sale as well as
other recorded instruments. Mackey also seeks compensatory, general, special,
and punitive damages.
According to the order of priority
established by Civil Code section 2924k, the surplus funds are to first be
distributed to the State Controller in the amount of $3,250.87, with the
remaining amount going to the Estate of Robert G. May. However, the Court
declines to distribute the surplus funds resulting from the trustee’s sale at
this time in light of Mackey’s pending action which seeks to invalidate that
sale. Instead, the Court continues the hearing on the distribution of surplus
funds to June 2, 2025, at 8:30 a.m. in Department 3 of the Alhambra Courthouse.
The Court also sets a non-appearance case review or April 2, 2025, to ascertain
the progress of Mackey’s wrongful foreclosure action.
IV.
CONCLUSION
The hearing on the distribution of
surplus funds is continued to June 2, 2025, at 8:30 a.m. in Department 3 of the
Alhambra Courthouse. A non-appearance case review is scheduled for April 2,
2025.
Dated
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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.