This case was last updated from Los Angeles County Superior Courts on 08/05/2021 at 21:45:09 (UTC).

CHIZUKO N. BERLINER, AS TRUSTEE FOR THE CHIZUKO N. BERLINER REVOCABLE FAMILY TRUST VS KEITH LA FOND, ET AL.

Case Summary

On 03/14/2019 CHIZUKO N BERLINER, AS TRUSTEE FOR THE CHIZUKO N BERLINER REVOCABLE FAMILY TRUST filed a Property - Other Real Property lawsuit against KEITH LA FOND. This case was filed in Los Angeles County Superior Courts, Stanley Mosk Courthouse located in Los Angeles, California. The Judge overseeing this case is ELAINE LU. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    *******8929

  • Filing Date:

    03/14/2019

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Property - Other Real Property

  • Courthouse:

    Stanley Mosk Courthouse

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judge

ELAINE LU

 

Party Details

Plaintiff

CHIZUKO N. BERLINER AS TRUSTEE FOR THE CHIZUKO N. BERLINER REVOCABLE FAMILY TRUST

Defendants and Cross Plaintiffs

LA FOND KEITH

IRVING BERLINER AS CO-TRUSTEE FOR THE ALLEN J. BERLINER REVOCABLE FAMILY TRUST

MYRON BERLINER. AS CO-TRUSTEE FOR THE ALLEN J. BERLINER REVOCABLE FAMILY TRUST

KEITH LA FOND AS CO-TRUSTEE OF THE KEITH LO FOND AND NORMA LA FOND REVOCABLE FAMILY TRUST

NORMA LA FOND AS CO-TRUSTEE FOR THE KEITH LA FOND AND NORMA LA FOND REVOCABLE FAMILY TRUST

KEITH LA FOND AS CO-TRUSTEE FOR THE ALLEN J. BERLINER REVOCABLE FAMILY TRUST

B-L PARTNERSHIP A CALIFORNIA GENERAL PARTNERSHIP

MCCORKELL ROBERTO ALLEN

HORIMOTO JESSE

ELWOOD 1404-1408 LLC A CALIFORNIA LIMITED LIABILITY COMPANY

MARTINEZ JOE D.

BARADARIAN DAVID

BRAVO CARMEN

CASTILLO HUMBERTO

HEGGNES HAROLD

BARRIENTO HENRY L.

BERLINER MYRON

MURAYAMA KIYOSHI

Cross Defendant

BERLINER KENJI JED

34 More Parties Available

Attorney/Law Firm Details

Defendant and Plaintiff Attorneys

OBERHOLTZER JAY

GREGORY KEITH MICHAEL

FERNALD BRANDON CLAUS

Defendant and Cross Plaintiff Attorneys

OBERHOLTZER JAY A

TAM JAMES

OBERHOLTZER JAY

Cross Defendant Attorney

LUKAS EDWARD W.

 

Court Documents

Notice of Ruling

5/24/2021: Notice of Ruling

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore - ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE ANGELA M. ALBAREZ, CSR #4344

5/7/2021: Order Appointing Court Approved Reporter as Official Reporter Pro Tempore - ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE ANGELA M. ALBAREZ, CSR #4344

Reply - REPLY TO THE OPPOSITION OF CHIZUKO BERLINER TO DEMURRER TO FOURTH AMENDED VERIFIED COMPLAINT

5/3/2021: Reply - REPLY TO THE OPPOSITION OF CHIZUKO BERLINER TO DEMURRER TO FOURTH AMENDED VERIFIED COMPLAINT

Proof of Service (not Summons and Complaint)

4/26/2021: Proof of Service (not Summons and Complaint)

Notice of Entry of Dismissal and Proof of Service

1/13/2021: Notice of Entry of Dismissal and Proof of Service

Amended Complaint - AMENDED COMPLAINT (3RD)

11/23/2020: Amended Complaint - AMENDED COMPLAINT (3RD)

Substitution of Attorney

9/21/2020: Substitution of Attorney

Declaration - DECLARATION DECLARATION OF KEITH M. GREGORY IN SUPPORT OF PLAINTIFFS MOTION FOR LEAVE TO FILE THIRD AMENDED COMPLAINT

2/25/2020: Declaration - DECLARATION DECLARATION OF KEITH M. GREGORY IN SUPPORT OF PLAINTIFFS MOTION FOR LEAVE TO FILE THIRD AMENDED COMPLAINT

Case Management Statement

2/7/2020: Case Management Statement

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore - ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE RE: ESTRELLA HERMAN CSR #13865

11/26/2019: Order Appointing Court Approved Reporter as Official Reporter Pro Tempore - ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE RE: ESTRELLA HERMAN CSR #13865

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (HEARING ON DEMURRER - WITHOUT MOTION TO STRIKE; CASE MANAGEME...) OF 11/26/2019

11/26/2019: Certificate of Mailing for - CERTIFICATE OF MAILING FOR (HEARING ON DEMURRER - WITHOUT MOTION TO STRIKE; CASE MANAGEME...) OF 11/26/2019

Declaration - DECLARATION AMENDED SUPPLEMENTAL PROOF OF SERVICE

11/4/2019: Declaration - DECLARATION AMENDED SUPPLEMENTAL PROOF OF SERVICE

Notice of Motion - NOTICE OF MOTION NOTICE OF HEARING OF DEMURRER

7/2/2019: Notice of Motion - NOTICE OF MOTION NOTICE OF HEARING OF DEMURRER

Cross-Complaint

5/23/2019: Cross-Complaint

Notice and Acknowledgment of Receipt

4/8/2019: Notice and Acknowledgment of Receipt

Proof of Service by Substituted Service

4/8/2019: Proof of Service by Substituted Service

Order to Show Cause Failure to File Proof of Service

4/19/2019: Order to Show Cause Failure to File Proof of Service

Summons - SUMMONS ON COMPLAINT

3/14/2019: Summons - SUMMONS ON COMPLAINT

164 More Documents Available

 

Docket Entries

  • 12/10/2021
  • Hearing12/10/2021 at 08:30 AM in Department 26 at 111 North Hill Street, Los Angeles, CA 90012; Hearing on Demurrer - with Motion to Strike (CCP 430.10)

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  • 11/09/2021
  • Hearing11/09/2021 at 08:30 AM in Department 26 at 111 North Hill Street, Los Angeles, CA 90012; Hearing on Demurrer - without Motion to Strike

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  • 11/09/2021
  • Hearing11/09/2021 at 08:30 AM in Department 26 at 111 North Hill Street, Los Angeles, CA 90012; Case Management Conference

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  • 07/21/2021
  • Docketat 08:30 AM in Department 26, Elaine Lu, Presiding; Hearing on Motion for Summary Adjudication - Not Held - Advanced and Vacated

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  • 07/16/2021
  • Docketat 11:00 AM in Department 26, Elaine Lu, Presiding; Informal Discovery Conference (IDC) - Not Held - Vacated by Court

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  • 07/16/2021
  • DocketMinute Order ( (Informal Discovery Conference (IDC))); Filed by Clerk

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  • 07/13/2021
  • DocketMotion to Strike (not initial pleading); Filed by Keith La Fond, as trustee for the Allen J. Berliner revocable family trust (Defendant); Keith LA Fond (Defendant); Keith La Fond, as trustee of the Keith La Fond and Norma La Fond revocable family trust (Defendant) et al.

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  • 07/13/2021
  • DocketDemurrer - with Motion to Strike (CCP 430.10); Filed by Keith La Fond, as trustee for the Allen J. Berliner revocable family trust (Defendant); Keith LA Fond (Defendant); Keith La Fond, as trustee of the Keith La Fond and Norma La Fond revocable family trust (Defendant) et al.

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  • 07/13/2021
  • DocketStipulation and Order (re: DISCOVERY); Filed by Keith LA Fond (Defendant)

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  • 07/13/2021
  • DocketRequest for Judicial Notice; Filed by Keith La Fond, as trustee for the Allen J. Berliner revocable family trust (Defendant); Keith LA Fond (Defendant); Keith La Fond, as trustee of the Keith La Fond and Norma La Fond revocable family trust (Defendant) et al.

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199 More Docket Entries
  • 03/20/2019
  • DocketNotice of Ruling; Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/20/2019
  • DocketOpposition (TO EX PARTE APPLICATION FOR LEAVE TO CONDUCT EARLY DEPOSITION DISCOVERY OF CHIZUKO N. BERLINER, TO SHORTEN TIME, AND TO EXTEND THE TIME LIMIT FOR DEPOSITION TESTIMONY); Filed by Keith La Fond, as co-trustee of the Keith Lo Fond and Norma La fond revocable family trust (Defendant)

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  • 03/19/2019
  • DocketDeclaration (Declaration of Chizuko N. Berliner in Support of Plaintiff Chizuko N. Berliner's as Trustee for the Chizuko N. Berliner Revocable Family Trust, Ex Parte Application for Leave to Conduct Early Deposition Discovery of Chizuko N. Berliner); Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/19/2019
  • DocketDeclaration (Declaration of Doctor IleanaSpizzirri in Support of Plaintiff Chizuko N. Berliner's as Trustee for the Chizuko N. Berliner Revocable Family Trust, Ex Parte Application for Leave to Conduct Early Deposition Discovery of Chizuko N. Berliner); Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/19/2019
  • DocketEx Parte Application (Plaintiff Chizuko N. Berliner's, as Trustee for the Chizuko N. Berliner Revocable Family Trust, Ex Parte Application for Leave to Conduct Early Deposition Discovery of Chizuko N. Berliner, to Shorten Time, and to Extend the Time Limit for Deposition Test); Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/19/2019
  • DocketDeclaration (Declaration of Attorney Daniel G. Seabolt in Support of Plaintiff's Ex Parte Application for Early Discovery); Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/14/2019
  • DocketSummons (on Complaint); Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/14/2019
  • DocketCivil Case Cover Sheet; Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/14/2019
  • DocketComplaint; Filed by Chizuko N. Berliner, as trustee for the Chizuko N. Berliner Revocable Family Trust (Plaintiff)

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  • 03/14/2019
  • DocketNotice of Case Assignment - Unlimited Civil Case; Filed by Clerk

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Tentative Rulings

Case Number: 19STCV08929    Hearing Date: May 7, 2021    Dept: 26

Superior Court of California

County of Los Angeles

Department 26

CHIZUKO BERLINER, et al.,

Plaintiffs,

v.

KEITH LAFOND, et al.,

Defendants.

Case No.: 19STCV08929

Hearing Date: May 7, 2021

[TENTATIVE] order RE:

defendants keith lafond, irving berliner, and myron berliner’s demurrer to the fourth amended complaint

Procedural Background

On March 14, 2019, Plaintiff Chizuko Berliner (“Plaintiff”) commenced the instant quiet title action. On April 18, 2019, Plaintiff filed a First Amended Complaint against Defendants Keith LaFond, Norma LaFond, Irving Berliner, Myron Berliner[1], B-L Partnership asserting causes of action for (1) quiet title, (2) fraud, (3) negligence, and (4) breach of fiduciary duty. The first and second causes of action were directed to all Defendants, while the third and fourth causes of action were directed solely at Keith LaFond.

On November 26, 2019, the Court sustained the demurrer brought by Defendants Keith LaFond, Myron Berliner, and Irving Berliner as trustees of the Allen J. Berliner Revocable Family Trust (collectively “Allen Trustees”) in its entirety with leave to amend.

On December 26, 2019, Plaintiff filed a Second Amended Complaint which named 47 defendants and asserted 22 causes of action, the vast majority of which involved completely different properties, different transactions, and different parties. On February 10, 2020, the Court on its own motion struck the entirety of Plaintiff’s Second Amended Complaint for violating and exceeding the court’s grant of leave to amend. (See Minute Order 2/10/20.) The Court ruled that Plaintiff could file a Third Amended Complaint that directly responded to the Court’s reasons for sustaining the demurrer to the FAC or request leave to amend.

On February 25, 2020, Plaintiff filed a motion requesting leave to file a Third Amended Complaint. After a substitution of counsel, on November 4, 2020 Plaintiff filed a notice of withdrawal of the motion for leave to amend. On November 23, 2020, Plaintiff filed the Third Amended Complaint responding to the November 26, 2019 order sustaining the demurrer. On December 14, 2020, Plaintiff filed a notice of errata as to the Third Amended Complaint.

On December 28, 2020, Moving Defendants filed the instant demurrer as to the Third Amended Complaint. On March 10, 2021, the Court granted the parties’ stipulation to recaption the Corrected Third Amended Complaint as the Fourth Amended Complaint (“4AC”) and file it promptly and for the demurrer to the Corrected Third Amended Complaint to be deemed a demurrer to the 4AC.

On April 26, 2021, Plaintiff filed the 4AC against Defendants Keith LaFond, Norma LaFond, Irving Berliner, Myron Berliner, B-L Partnership asserting causes of action for (1) quiet title, (2) fraud, (3) negligence, and (4) breach of fiduciary duty. The first and second causes of action are directed to all Defendants, while the third and fourth causes of action are directed solely at Keith LaFond.

On April 26, 2021, Plaintiff filed an opposition to the Allen Trustees’ demurrer. On May 3, 2021, the Allen Trustees filed a reply.

Untimely Reply

“All papers opposing a motion so noticed shall be filed with the court and a copy served on each party at least nine court days, and all reply papers at least five court days before the hearing.” (CCP § 1005(b).) This is calculated by counting backward from the hearing date and excluding holidays and weekends. (CCP §§ 12-12(c).) The court may refuse to consider a late-filed paper. (Cal. Rules of Court, Rule 3.1300(d).)

Here, the replies were filed on May 3, 2021 – only three court days before the instant hearing. Accordingly, the replies are untimely. However, the Court in its discretion will consider the untimely reply.

Factual Background

The 4AC alleges, in relevant part, that:

The instant action stems from a dispute concerning the ownership of several apartment buildings in Glendale, California. (4AC ¶ 11.)

Plaintiff was married to Allen Berliner (“Allen”) on March 6, 1965. (4AC ¶ 14.) While Plaintiff was married to Allen, on December 11, 1981 a California Superior Court confirmed the sale and conveyance of Lots 33 and 34, in Block 1 of Moore’s Resubdivision of the portion of Block 9 of the Glendale Boulevard Tract, in the City of Glendale, in the County of Los Angeles, State of California (“Canterbury Property”) to Allen and Plaintiff, jointly as to one-half interest, and to Keith LaFond and Norma LaFond, jointly, as to one-half interest. (4AC ¶¶ 11, 26.) On December 16, 1981, Keith LaFond and Norma LaFond transferred their interest in the Canterbury Property to Allen and Plaintiff via quitclaim deed. (4AC ¶ 28, Ex. 1.) This gave Plaintiff and Allen 100 percent interest in the Canterbury Property. (4AC ¶¶ 30-31.)

Plaintiff was never shown these deeds, and Allen “misrepresented to [Plaintiff] that the LaFonds were joint owners of the Property to prevent proper distribution of the Canterbury Property upon divorce.” (4AC ¶¶ 33-34.) On “February 8, 1982, without [Plaintiff]’s knowledge or authorization, Allen or Allen’s agent forged or caused to be forged [Plaintiff]’s signature to a Grant Deed (the ‘Forged Deed’), purporting to transfer a one-half undivided interest in the Canterbury Property to the LaFonds jointly.” (4AC ¶ 38, Ex. 3.) Plaintiff did not discover this forgery until January of 2019 through discovery in the instant action. (4AC ¶ 42.)

On September 5, 1983, Plaintiff and Allen physically separated, and the divorce decree finalizing the divorce was entered on April 24, 1986. (4AC ¶¶ 17, 45, Ex. 5.) Pursuant to the divorce decree, Plaintiff obtained Allen’s interest in the Canterbury Property. (4AC ¶ 45, Ex. 5.) On September 29, 1986, “Allen represented to [Plaintiff] that day that he would always keep his promise and take care of her and that he had one more document that he needed her to sign without explaining to her that the Fraudulent Deed would purportedly transfer Chizuko’s interest in Lot 33 of the Property to the LaFonds as joint tenant.” (4AC ¶ 49, Ex. 5.) Plaintiff signed the quitclaim deed believing that she was receiving property. (4AC ¶ 60.) Thus, the September 29, 1986 deed was the product of fraud in the inception. (4AC ¶¶ 58-59.)

In the time since Allen’s death in 2004 and the allegedly fraudulent deed transfers, Defendants Keith LaFond, Myron Berliner, and Irving Berliner allegedly sold the Allen Trust’s interest in the B-L Partnership to Defendant Keith LaFond, who transferred the Property to B-L Partnership. Plaintiff received notice of the petition of sale to B-L Partnership but was unaware that it included the sale of the Property. (4AC ¶¶ 61-72.)

“[Plaintiff] is informed and believes, and thereon alleges, that Keith, Myron, and Irving, as co-trustees of the Allen Family Trust, joined in the conspiracy by agreeing to keep Chizuko ignorant of the theft of the Canterbury Property.” (4AC ¶ 92.) The 4AC further alleges that, “Allen, Keith, Myron, Irving, and the Allen Trustees misrepresentations and concealments were a substantial cause of [Plaintiff]’s damages.” (4AC ¶ 119.)

Legal Standard

A demurrer can be used only to challenge defects that appear on the face of the pleading under attack; or from matters outside the pleading that are judicially noticeable. (Blank v. Kirwan (1985) 39 Cal 3d 311, 318.) No other extrinsic evidence can be considered (i.e., no “speaking demurrers”). (Ion Equipment Corp. v. Nelson (1980) 110 Cal.App.3d 868, 881.)

A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal. App. 4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context. (Taylor v. City of Los Angeles Dep’t of Water & Power (2006) 144 Cal. App. 4th 1216, 1228.) In a demurrer proceeding, the defects must be apparent on the face of the pleading or via proper judicial notice. (Donabedian v. Mercury Ins. Co. (2004) 116 Cal. App. 4th 968, 994.) “A demurrer tests the pleadings alone and not the evidence or other extrinsic matters. Therefore, it lies only where the defects appear on the face of the pleading or are judicially noticed.”  (SKF Farms v. Superior Ct. (1984) 153 Cal. App. 3d 902, 905.) “The only issue involved in a demurrer hearing is whether the complaint, as it stands, unconnected with extraneous matters, states a cause of action.”  (Hahn, supra, 147 Cal.App.4th at 747.) 

Meet and Confer

Code of Civil Procedure section 430.41, subdivision (a) requires that “[b]efore filing a demurrer pursuant to this chapter, the demurring party shall meet and confer¿in person or by telephone¿with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer.” The parties are to meet and confer at least five days before the date the responsive pleading is due and if they are unable to meet the demurring party shall be granted an automatic 30-day extension.  (CCP § 430.41(a)(2).)  The demurring party must also file and serve a declaration detailing the meet and confer efforts.  (Id.¿at (a)(3).)¿ If an amended pleading is filed, the parties must meet and confer again before a demurrer may be filed to the amended pleading.  (Id.¿at (a).)

The Court notes that the Allen Trustees have adequately met and conferred with Plaintiff. (Oberholtzer Decl. ¶ 2.)

Discussion

First Cause of Action: Quiet Title

Allen Trustees assert that the first cause of action for quiet title fails because it lacks the required specificity.

Pursuant to Code of Civil Procedure section 761.020, a complaint to quiet title must be verified and must include: (a) a description of the property including both its legal description and its street address or common designation; (b) plaintiff's title and the basis upon which it is asserted; (c) the adverse claims as against which a determination is sought; (d) the date as of which a determination is sought and, if other than the date the complaint is filed, a statement why the determination is sought as of that date; and (e) a prayer for determination of plaintiff's title against the adverse claims. (CCP § 761.020.) In addition, if the quiet title action is based on the defendant's fraud in obtaining record title, the plaintiff must plead the factual basis for the fraud specifically. (See Moss Estate Co. v. Adler (1953) 41 Cal.2d 581, 584; see also Strong v. Strong (1943) 22 Cal.2d 540, 545–546 [“the general rule that fraud must be specifically pleaded … applies particularly to quiet title actions.”].)

“Fraud allegations ‘involve a serious attack on character’ and therefore are pleaded with specificity. [Citation.] General and conclusory allegations are insufficient. [Citation.] The particularity requirement demands that a plaintiff plead facts which ‘‘‘show how, when, where, to whom, and by what means the representations were tendered.’’’ [Citation.]” (Cansino v. Bank of America (2014) 224 Cal.App.4th 1462, 1469.) Moreover, as a claim in fraud “each element must be pleaded with specificity. [Citations.]” (Daniels v. Select Portfolio Servicing, Inc. (2016) 246 Cal.App.4th 1150, 1166.)

Here, the 4AC alleges that Chizuko Family Trust has an interest in the Canterbury Property as a result of the December 16, 1981 quitclaim deed and the December divorce decree transferring all interest to Plaintiff, and the later deed transferring the interest from Plaintiff to the Chizuko Family Trust. (4AC ¶ 58.) The 4AC further alleges that the February 8, 1982 deed was forged and not signed by Plaintiff, and the September 29, 1986 deed was the product of fraud in the inception. (4AC ¶¶ 58-59.) As to the Allen Trustees, their alleged involvement is that they provided knowledge and assistance” in concealing the forgeries and acts of fraud. (4AC ¶¶ 22, 37.) However, there is no specific allegation as to what their acts of concealment and fraud were, or how Allen Trustees assisted in concealing the forgeries and acts of fraud. Nor is there any allegation as to how the Allen Trustee knew of Allen’s forgeries and acts of fraud. Moreover, Plaintiff’s allegations are based on information and belief without any allegation made to support a basis as to why Plaintiff would believe these allegations to be true. (See Doe v. City of Los Angeles (2007) 42 Cal.4th 531, 550; [A “[p]laintiff may allege on information and belief any matters that are not within his personal knowledge, if he has information leading him to believe that the allegations are true.”]; see also (Findley v. Garrett (1952) 109 Cal.App.2d 166, 177; [“‘[i]t is not sufficient to allege fraud or its elements upon information and belief unless the facts upon which the belief is founded are stated in the pleading.’”].)

As to the first cause of action, the most specific allegation is that “[o]n November 29, 2001, a quitclaim deed was executed purporting to transfer an interest in Lot 34 to the Chizuko Family Trust. This was less than three months after Allen’s stroke, and it is likely that Allen’s signature on said deed was a forgery caused by the Allen Trustees.” (4AC ¶ 66.) However, this alleged forgery is entirely irrelevant to Plaintiff’s claim to quiet title as Plaintiff does not assert an interest in the Canterbury Property from this deed.

Moreover, the 4AC fails to allege with any specificity that the Allen Trustees in their capacity as trustees of the Allen J. Berliner Revocable Family Trust have any adverse interest to Plaintiff in the Canterbury Property. (See Orcilla v. Big Sur, Inc. (2016) 244 Cal.App.4th 982, 1010, “ ‘An element of a cause of action for quiet title is ‘[t]he adverse claims to the title of the plaintiff against which a determination is sought.’ [Citations.]”].) Rather the complaint alleges that the property is purportedly owned by Lot 33 with 100 percent interest in B-L Partnership and Lot 34 split 50/50 in the LaFond Family Trust and the Chizuko Family Trust. (4AC ¶ 68.)

Accordingly, the first cause of action fails to allege the quiet title claim with the required specificity. Allen Trustees’ demurrer to the first cause of action for lack of specificity is SUSTAINED.

Second Cause of Action: Fraud

Allen Trustees assert that the second cause of action fails for lack of specificity.

“The elements of fraud are (a) a misrepresentation (false representation, concealment, or nondisclosure); (b) scienter or knowledge of its falsity; (c) intent to induce reliance; (d) justifiable reliance; and (e) resulting damage.” (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294.) As noted above, fraud must be alleged with specificity.

“A complaint for civil conspiracy states a cause of action only when it alleges the commission of a civil wrong that causes damage. Though conspiracy may render additional parties liable for the wrong, the conspiracy itself is not actionable without a wrong.” (Okun v. Superior Court (1981) 29 Cal.3d 442, 454.) Therefore, “Conspiracy, … is not an independent cause of action.” (Faunce v. Cate (2013) 222 Cal.App.4th 166, 172–173.) “Instead, it is ‘a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immediate tortfeasors a common plan or design in its perpetration. [Citation.] By participation in a civil conspiracy, a coconspirator effectively adopts as his or her own the torts of other coconspirators within the ambit of the conspiracy. [Citation.] In this way, a coconspirator incurs tort liability co-equal with the immediate tortfeasors.’ [Citation.] The elements of a civil conspiracy are (1) the formation of a group of two or more persons who agreed to a common plan or design to commit a tortious act; (2) a wrongful act committed pursuant to the agreement; and (3) resulting damages.” (City of Industry v. City of Fillmore (2011) 198 Cal.App.4th 191, 211–212.)

Here, the 4AC alleges that “[Plaintiff] is informed and believes, and thereon alleges, that Keith, Myron, and Irving, as co-trustees of the Allen Family Trust, joined in the conspiracy by agreeing to keep Chizuko ignorant of the theft of the Canterbury Property.” (4AC ¶ 92.) The 4AC further alleges that, “Allen, Keith, Myron, Irving, and the Allen Trustees misrepresentations and concealments were a substantial cause of [Plaintiff]’s damages.” (4AC ¶ 119.) Thus, the alleged wrongful acts appear to be affirmative acts of fraud or fraud by concealment.

As to the claims of fraud by concealment, there is no allegation as to why any of the alleged conspiracy defendants owed a duty to Plaintiff to disclose any concealed facts. (See Weiner v. Fleischman (1991) 54 Cal.3d 476, 483, [to show fraud by concealment, the plaintiff “had to establish the existence of some type of legal relationship giving rise to a duty to disclose. ‘Although material facts are known to one party and not to the other, failure to disclose them is ordinarily not actionable fraud unless there is some fiduciary relationship giving rise to a duty to disclose’ ”]; see e.g. Los Angeles Memorial Coliseum Com. v. Insomniac, Inc. (2015) 233 Cal.App.4th 803, 834, [Concluding that allegations that defendant event promoters conspired with plaintiff commission's event coordinator to conceal existence of consulting agreement requiring promoters to make payments directly to event coordinator, rather than to plaintiff, was sufficient to state cause of action that defendants were liable to plaintiff for fraudulent concealment under conspiracy theory of liability, because event coordinator's employment relationship with plaintiff was fiduciary in nature].) Thus, only allegations of affirmative fraudulent conduct can be actionable.

As to affirmative representations, the 4AC fails to allege with any specificity what was stated by Keith LaFond, Myron Berliner, Irving Berliner, and the Allen Trustees. For example, there is no allegations as to where the alleged misrepresentations were made, when the misrepresentations were made, the means of the misrepresentation or what the content of these misrepresentations are. Nor has Plaintiff alleged the misrepresentations by Allen with the required specificity. There are no allegations as to when the misrepresentations, the means of the affirmative misrepresentations or what the content of these misrepresentations are. Moreover, many of Plaintiff’s allegations are on information and belief with no facts to support this claim which as noted above is insufficient for fraud. (See e.g. 4AC ¶ 33, [“[Plaintiff] is informed and believes, and thereon alleges, that Allen knowingly misrepresented to [Plaintiff] that the LaFonds were joint owners of the Property to prevent proper distribution of the Canterbury Property upon divorce.) Further, the 4AC is vague as to how each of the alleged conspirator defendants was a part of the alleged conspiracy to keep Plaintiff ignorant of the theft of the Canterbury Property. (4AC ¶ 92.) Rather the complaint includes irrelevant extraneous allegations such as money laundering through unreported sales of prescription medication, (4AC ¶ 109), and Plaintiff being forced to buy back art objects (4AC ¶ 101-103.)

Accordingly, Allen Trustees’ demurrer is SUSTAINED as to the second cause of action.

Statute of Limitations

Finally, Allen Trustees argue that Plaintiff’s claims against the Allen Berliner’s estate are time-barred under Code of Civil Procedure section 366.2 because Allen Berliner died in 2004, and Plaintiff was thus required to bring the action against his estate within one year. Code of Civil Procedure section 366.2 states, in relevant part:

If a person against whom an action may be brought on a liability of the person, whether arising in contract, tort, or otherwise…dies before the expiration of the applicable limitations period, and the cause of action survives, an action may be commenced within one year after the date of the death, and the limitations period that would have been applicable does not apply.

(CCP§ 366.2(a).)

As previously noted, this section is inapplicable because if in an amended complaint Plaintiff alleges sufficient facts to state a claim based not on the personal liability of Allen Berliner but instead on conduct of Defendants as conspirators, Code of Civil Procedure section 366.2 would be inapplicable to the present action.

Leave to Amend

Leave to amend must be allowed where there is a reasonable possibility of successful amendment. (Goodman v. Kennedy (1976) 18 Cal.3d 335, 348.) The burden is on the plaintiff to show the court that a pleading can be amended successfully. (Goodman v. Kennedy, supra, 18 Cal.3d at p. 348; Lewis v. YouTube, LLC (2015) 244 Cal.App.4th 118, 226.)

Here, the Court finds that there may be a reasonable possibility of successful amendment. As to the first cause of action, Plaintiff must specify as to each Defendant, that particular Defendant’s adverse interest in the property and allege any fraudulent conduct with specificity. As to the second cause of action, it is unclear what fraud constitutes Plaintiff’s claims as the extraneous allegations make the 4AC unnecessarily confusing. Thus, Plaintiff must delineate exactly what each alleged fraudulent conduct is with specificity, the specific defendants involved in each fraudulent act, and the alleged harm from each specific fraud alleged. For claims of conspiracy, Plaintiff must identify the specific conspiracy, the Defendants involved in each specific conspiracy, the acts each defendant took in furtherance of the conspiracy, and the alleged harm suffered by Plaintiff. Finally, as to the allegations on “information and belief,” Plaintiff must specify the basis providing that information and belief.

Accordingly, Plaintiff has 15 days to amend the 4AC.

CONCLUSIONS AND ORDER

Based on the foregoing, the Demurrer brought by Defendants Keith LaFond, Myron Berliner, and Irving Berliner as trustees to the Allen J. Berliner Revocable Family Trust, and individually Myron Berliner, and Irving Berliner is SUSTAINED in full WITH LEAVE TO AMEND.

Plaintiff is to file an amended complaint within 15 days of notice of this order.

The case management conference is continued to June 1, 2021 at 8:30 am.

Moving Party is ordered to provide notice of this order and file proof of service of such.

DATED: May 7, 2021 ___________________________

Elaine Lu

Judge of the Superior Court


[1] The action is against Norma LaFond in her representative capacity as Trustee of the Keith LaFond and Norma LaFond Revocable Family Trust. The action is against Irving Berliner, and Myron Berliner in their representative capacities as Trustees of the Allen J. Berliner Revocable Family Trust. The action is against Keith LaFond individually and in his representative capacity as the trustee of both Keith LaFond and Norma LaFond Revocable Family Trust and the Allen J. Berliner Revocable Family Trust.

Case Number: 19STCV08929    Hearing Date: October 01, 2020    Dept: 26

The Court makes the following disclosure:

Judge Elaine Lu recently purchased a vacant duplex. After the close of escrow in August 2020, Judge Lu learned in September 2020 (1) that Sellers’ MLS listing contained misrepresentations regarding rent and (2) that Sellers had evicted the former tenant for one of the units as a result of which the rent for that unit is capped under rent control laws; the rent for that unit is capped at an amount lower than what Sellers had stated as rent in the MLS listing.  Sellers never disclosed the eviction of the former tenant or the rent cap. Judge Lu has not decided what legal action, if any, to pursue against the Sellers.

 

The Court makes this disclosure so that the parties are aware of all facts reasonably related to the issue of disqualification. The Court has no basis to recuse itself. The Court can remain fair and impartial to all parties.

The hearing on Plaintiff’s motion for leave to amend the complaint is CONTINUED to November 2, 2020 at 10:00 am in Department 26.

Any party that wishes to disqualify Judge Elaine Lu must file and serve a motion for disqualification no later than October 22, 2020. The failure to file and serve a motion for disqualification on or before October 22, 2020 will be deemed a waiver of any disqualification issues.

Court Clerk to give notice to all parties.

Case Number: 19STCV08929    Hearing Date: August 26, 2020    Dept: 26

IN ORDER TO IMPLEMENT PHYSICAL DISTANCING AND UNTIL FURTHER NOTICE, THE COURT STRONGLY ENCOURAGES ALL COUNSEL AND ALL PARTIES TO APPEAR REMOTELY FOR NON-TRIAL AND NON-EVIDENTIARY MATTERS, INCLUDING THIS MOTION

Superior Court of California

County of Los Angeles

Department 26

CHIZUKO BERLINER, et al.,

Plaintiffs,

v.

KEITH LAFOND, et al.,

Defendants.

Case No.: 19STCV08929

Hearing Date: August 26, 2020

[TENTATIVE] order RE:

PLaintiff Chizuko berliner’s motion to COMPEL defendant keith LaFond’s FUrTHER RESPONSES TO Special interrogatories, set one

Procedural Background

On March 14, 2019, Plaintiff Chizuko Berliner (“Plaintiff”) commenced the instant quiet title action. On April 18, 2019, Plaintiff filed the operative First Amended Complaint (“FAC”) against Defendants Keith LaFond, Norma LaFond, Irving Berliner, Myron Berliner, B-L Partnership, and Does 1-50 alleging causes of action for (1) quiet title, (2) fraud, (3) negligence, and (4) breach of fiduciary duty. The first and second causes of action were directed to all Defendants, while the third and fourth causes of action are directed solely at Keith LaFond.

On July 18, 2019, Plaintiff filed the instant motion to compel Defendant Keith LaFond’s (“Defendant’s”) further responses to special interrogatories set one.

On November 26, 2019, the Court sustained Defendants Demurrer in its entirety with leave to amend. On December 26, 2019, Plaintiff filed a Second Amended Complaint which named 47 defendants and asserted 22 causes of action, the vast majority of which involved completely different properties, different transactions, and different parties. On February 10, 2020, the Court on its own motion struck the entirety of Plaintiff’s Second Amended Complaint for violating and exceeding the court’s grant of leave to amend. (See Minute Order 2/10/20.) The court ruled that Plaintiff could file a Third Amended Complaint that directly responded to the Court’s reasons for sustaining the demurrer to the FAC or request leave to amend. On February 25, 2020, Plaintiff filed a motion requesting leave to file a Third Amended Complaint, which is set to be heard on October 1, 2020.

On April 1, 2020, Defendant filed an opposition to this instant motion to compel further responses. On April 7, 2020, Plaintiff filed a reply. Due to the COVID-19 pandemic, the court continued the hearing for the instant motion from April 14, 2020 to August 26, 2020 at 8:30 am. (Minute Orders 3/23/20, 4/21/20.) On April 24, 2020, Plaintiff filed proof of service indicating notice of the new hearing date. On August 18, 2020, Plaintiff filed a notice stating that no opposition to the instant motion had been filed. However, as stated above, the opposition was filed on April 1, 2020.

Factual Background

This action stems from a dispute concerning the ownership of several apartment buildings located in Glendale, California (“the Property”). Plaintiff is the ex-wife of Allen Berliner, who jointly acquired the Property in 1981 as to one half-interest shared with Keith LaFond and Norma LaFond. Allen Berliner passed away in 2004 and left his assets in a trust (“Allen Trust”), which includes his interest in the B-L Partnership. Keith LaFond, Myron Berliner, and Irving Berliner are the co-trustees of the Allen Trust.

The Property has been transferred by way of two deeds that are at issue in the present action: (1) a deed transferring one-half undivided interest in the Property to the LaFonds in 1982 (“1982 Deed”) and (2) a deed transferring Plaintiff’s entire interest in a lot on the Property to the LaFonds in 1986. (“1986 Deed”.)

The FAC alleges the following: As to the 1982 Deed, Allen Berliner forged Plaintiff’s signature for the transfer. As to the 1986 Deed, Allen Berliner presented the deed to Plaintiff, and Plaintiff signed the deed without knowing that it transferred her interest to the LaFonds. At the signing of the 1986 Deed, Plaintiff was suffering from medical problems and could not see clearly. Moreover, Defendant Keith LaFond was allegedly present at the signing.

The FAC further alleges that in the time since Allen’s death in 2004 and the fraudulent deed transfers, Defendants Keith LaFond, Myron Berliner, and Irving Berliner sold the Allen Trust’s interest in the B-L Partnership to Defendant Keith LaFond, which transferred the Property to the B-L Partnership. Plaintiff received notice of the petition of sale as to the B-L Partnership but was unaware that it included the sale of the Property.

Plaintiff has filed this action to recover her ownership interest in the Property that was transferred through the Subject Deeds. Plaintiff seeks to cancel all instruments flowing from the Subject Deeds.

Plaintiff’s Evidentiary Objections

There is no statutory basis for evidentiary objections for a motion to compel further responses. Moreover, Plaintiff’s objections are unnecessary because the Court, when reviewing the evidence is presumed to ignore material it knows it incompetent, irrelevant, or inadmissible.  (In re Marriage of Davenport (2011) 194 Cal. App. 4th 1507, 1526.)  Courts are presumed to know and apply the correct statutory and case law and to be able to distinguish admissible from inadmissible evidence, relevant from irrelevant facts, and to recognize those facts which properly may be considered in the judicial decision-making process.  (People v. Coddington (2000) 23 Cal.4th 529, 644.)  Accordingly, Plaintiff’s evidentiary objections are overruled.

Legal Standard

Code of Civil Procedure section 2030.300 provides that “[o]n receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: (1) An answer to a particular interrogatory is evasive or incomplete; [or] (2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate; [or] (3) An objection to an interrogatory is without merit or too general.” (CCP § 2030.300(a).)

Notice of the motion must be given within 45 days of service of the verified response, or upon a later date agreed to in writing. Otherwise, the propounding party waives any right to compel a further response. (CCP § 2031.310(c).) The motion must also be accompanied by a meet and confer declaration. (CCP § 2031.310(b)(2).)

The burden is on the responding part to justify any objection or failure fully to answer the interrogatories. (Fairmont Ins. Co. v. Superior Court (Stendell) (2000) 22 Cal. 4th 245, 255.)

Discussion

There are three Special Interrogatories at issue Special Interrogatories Nos. 23, 55, and 56.

Meet and Confer

“A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” (CCP § 2016.040.)

Here, Plaintiff has fulfilled this requirement by written meet and confer efforts and telephonic meet and confer efforts. (Seabolt Decl. ¶¶ 11-13, Ex. G-I.)

Special Interrogatory 23

Special Interrogatory 23 requests: “IDENTIFY all DOCUMENTS consisting of, related to, or referencing any and all COMMUNICATIONS between YOU and any DEFENDANT regarding the FORGED DEED.” (Special Interrogatory, No. 23.)

Defendant responded: “Objection, this discovery request violates § 2030.060 (d). Further, by its incorporation of the term ‘forged deed’ and its definition, the interrogatory is necessarily argumentative and requires responding party to adopt the assumption that the deed was ‘forged,’ which responding party rejects. Objection, this discovery request is so broad and unlimited as to time and scope as to be vague, ambiguous, overbroad, and unduly burdensome, and oppressive, particularly since it concerns events occurring more than 30 years ago. Objection, this discovery request is not reasonably tailored to lead to relevant evidence, in violation of § 2017.010.” (Response to Special Interrogatory, No. 23.)

Because Plaintiff has filed a motion to compel further responses, Defendant bears the burden to justify each of his objections.  (Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221.)

Objection That Question Was Not “Full and Complete in and of Itself”

Defendant contends that referring to the February 8, 1982 deed as the “Forged Deed” is improper as it would force Defendant to concede by responding to this interrogatory that the deed is forged. Defendant contends that this is argumentative and violates the rule that an interrogatory must be “full and complete in and of itself.” (See CCP § 2030.060(d).)

“Each interrogatory shall be full and complete in and of itself. No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17[.]” (CCP § 2030.060(d).) Though “argumentative” can be a proper objection to an oral question, the grounds for objecting to interrogatories are limited as there is less concern as to the form of questioning because the answering party will have the assistance of counsel in preparing responses. (See Greyhound Corp. v. Superior Court In and For Merced County (1961) 56 Cal.2d 355, 392 Fn. 16 [overruled by statute on other grounds].)

Defendant contends that by answering in any manner Defendant is forced to concede that the deed is forged. Defendant fails to reference any authority that use of leading and contentious terminology can justify a denial of discovery. Further, Defendant is not forced to admit any implication of the defined term, may dispute the implied contention that the deed is forged, and may make clear that Defendant is only applying Plaintiff’s definition of “forged deed” for purposes of responding to this special interrogatory.

Overbroad, Vague, Burdensome, and Irrelevant Objections

“[A]ny party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” (CCP § 2017.010.) “[A]n implicit waiver of a party's constitutional rights encompasses only discovery directly relevant to the plaintiff's claim and essential to the fair resolution of the lawsuit.” (Vinson v. Superior Court (1987) 43 Cal. 3d 833, 842.) However, discovery should not be denied if the information sought has any relevance to the subject matter. “These rules are applied liberally in favor of discovery, and (contrary to popular belief), fishing expeditions are permissible in some cases.” (Gonzalez v. Superior Court (1995) 33 Cal.App.4th 1539, 1546 [internal citation omitted].) Therefore, even if interrogatories are found to be “burdensome and oppressive,” the Court should not simply sustain the objection and thereby excuse any answer. Rather, the Court should limit the question to a reasonable scope. (Borse v. Superior Court (Southern Pac. Co.) (1970) 7 Cal. App. 3d 286, 289.)

Here the evidence in question is clearly relevant as it directly relates to Plaintiff’s claim that the February 8, 1982 deed was forged. Moreover, this question appears reasonably calculated to lead to the discovery of admissible evidence. Further, while Defendant states that this evidence is oppressive because it concerns events from 30 years ago, Defendant fails to present any evidence to show that responding to this interrogatory would be so burdensome that it is unjust. (West Pico Furniture Co. of Los Angeles v. Superior Court In and For Los Angeles County (1961) 56 Cal.2d 407, 417–418.)

Accordingly, Plaintiff’s request for a motion to compel further as to special interrogatory 23 is GRANTED.

Special Interrogatories 55

“IDENTIFY all properties where YOU and ALLEN were both INTEREST HOLDERS For purposes of this Interrogatory INTEREST HOLDERS means, in addition to its common meaning, any ownership interest, right to use the property, right to receive profits from the property, right to receive any other benefit from the property, and or right to encumber the property.” (Special Interrogatory, No. 55.)

“Objection, this discovery request violates § 2030.060 (d). Objection, this discovery request is vague, ambiguous, overbroad and unduly burdensome. Objection, this discovery request is not reasonably tailored to lead to relevant evidence, in violation of § 2017.010.” (Response to Interrogatory, No. 55.)

Defendant contends that this information is irrelevant as it does not deal solely with the property alleged in the complaint. However, “[w]here fraud is charged, evidence of other fraudulent representations of like character by the same parties at or near the same time is admissible to prove intent.” (Borse v. Superior Court (1970) 7 Cal.App.3d 286, 289.) Accordingly, here, evidence of other properties shared by Defendant and Allen may be relevant to show intent. However, as currently phrased, this interrogatory could include any type of property ownership as it does not specify the type of property interest. Thus, it should be limited to the relevant subject matter, namely shared real property interest.

Therefore, Plaintiff’s request is GRANTED with the limitation of real properties and not all properties.

Special Interrogatory 56

“IDENTIFY all properties where YOU and CHIZUKO were both INTEREST HOLDERS. For purposes of this Interrogatory INTEREST HOLDERS means, in addition to its common meaning, any ownership interest, right to use the property, right to receive profits from the property, right to receive any other benefit from the property, and/or right to encumber the property.” (Special Interrogatory, No. 56.)

“Objection, this discovery request violates § 2030.060 (d). Objection, this discovery request is vague, ambiguous, overbroad and unduly burdensome. Objection, this discovery request is not reasonably tailored to lead to relevant evidence, in violation of § 2017.010. Objection. The information sought in this discovery request is equally available to the Propounding party. (§2030.220 subd. (c); and Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App.2d 45.).” (Response to Special Interrogatory, No. 56.)

Similarly to interrogatory 55, here, this interrogatory is relevant to show intent as to Plaintiff’s claim of fraud. However, information on shared property interests between Defendant and Plaintiff is equally available to both parties. Plaintiff contends that this information is not equally available as she was not privy to her husband, Allen and Defendant’s property investments. (Motion p.16:11-18.) However, this argument addresses only Plaintiff’s knowledge of the property interests of her husband. Plaintiff’s motion and reply fail to address why information relating to property interests shared by Plaintiff and Defendant are not available to Plaintiff. Accordingly, Plaintiff’s motion to compel further responses as to special interrogatory number 56 is DENIED.

Sanctions

“[T]he court shall impose a monetary sanction … against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response to a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (CCP § 2031.310 (h) (emphasis added.))

Plaintiff requests sanctions under CCP § 2023.010 for misuse of discovery. In light of the mixed result and the needless use of a contentious interrogatory definition, the Court finds that imposition of sanctions would be unjust. As such, Plaintiff’s motion for sanctions is denied.

CONCLUSIONS AND ORDER

Based on the foregoing reasons above, Plaintiff Chizuko Berliner’s Motion to Compel Defendant Keith LaFond’s Further Responses to Special Interrogatories, Set One is GRANTED as to Special Interrogatories 23 and 55 with the above stated limitations as to Special Interrogatory 55. Plaintiff Chizuko Berliner’s motion to compel Defendant Keith LaFond’s further responses is DENIED as to Special Interrogatory 56.

Defendant Keith LaFond is ordered to provide within 15 days of notice of this order further responses to Special Interrogatories 23 and 55 that are code-compliant with the limitations stated above.

Plaintiff Chizuko Berliner’s request for sanctions is DENIED.

Moving Party is ordered to provide notice of this order and file proof of service of such.

DATED: August 26, 2020 ___________________________

Elaine Lu

Judge of the Superior Court

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