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1 EDWARD M. HIGGINBOTHAM, SBN 231636
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JEFFREY B. WORKMAN, SBN 287066
Attorneys at Law ELECTRONICALLY
3 885 Bryant Street, Second Floor F I L E D
San Francisco, CA 94103 Superior Court of California,
4 County of San Francisco
415.581.0885 Tel
5 415.581.0887 Fax 06/25/2020
Clerk of the Court
BY: RONNIE OTERO
6 Attorneys for Defendants Jose Ceron, Monica Medina and Judy Judkins Deputy Clerk
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8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
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SALLY LIU, an individual )
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Plaintiff, ) CASE NO. CGC-19-577432
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vs. ) DEFENDANTS’ REPLY TO
14 ) PLAINTIFF’S OPPOSITION TO
EDWARD M. HIGGINBOTHAM, an ) DEFENDANT JOSE CERON AND
15 individual, JOSE CERON, an individual, ) MONICA MEDINA’S SPECIAL MOTION
ESPETACION MONQIUE MEDINA, an ) TO STRIKE
16 )
individual, BRIAN RANGEL, an individual )
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and JUDY JUDKINS, an individual and Does ) Hearing Date: June 30, 2020
1-20 inclusive ) Dept.: 302
18 Time: 9:30 a.m.
Defendants.
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I. SUMMARY OF PLAINTIFF’S ARGUMENTS
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A. Plaintiff Claims she Did Not Receive Proper Notice
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B. Defendants Monica Medina and Jose Ceron Failed to Demonstrate that the
24 Activity in Question is Protected
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26 II. LEGAL ARGUMENT
27 A. Special Motion to Strike was Properly Noticed
28 As identified in the notice of this motion, the SLAPP motion before this Court is on
behalf of Jose Ceron and Monica Medina and seeks to strike the first, second, third and fifth
- Defendants’ Reply in Support of Special Motion to Strike
Liu v. Higginbotham et al.
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1 causes of action. Said notice was clear on its face, and provided the June 30 th hearing date. Co-
2 Defendants have filed separate motions and Brian Rangel was dismissed as he should have never
3 been included, so notice was proper, timely and abundantly clear.
4 B. Conversion is Not Exempt from a Special Motion to Strike
5 It is undisputed that Plaintiff Sally Liu received a meet & confer correspondence in
explaining that the first amended complaint was subject to a SLAPP motion. It is also
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undisputed that she never responded. Plaintiff claims that her conversion cause of action against
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these Defendants is immune from the special motion to strike before this Court. The citations to
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the penal code are completely irrelevant and need not be addressed. Communications with ‘some
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relation’ to judicial proceedings” are “absolutely immune from tort liability” by the litigation
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privilege. Rubin v. Green (1993) 4 Cal.4th 1187, 1193
11 Plaintiff does include case law to her support her position that a cause of action for
12 conversion is not proceed by the litigation privilege and relies heavily on Rusheen v. Cohen
13 (2006) 27 Cal. 4th 1048. A close read of Rusheen and said case does not exclude conversion
14 causes of action from the litigation privilege, to the contrary, Rusheen articulates that a
15 conversion cause of can be stricken pursuant to a special motion to strike. The Rusheen court
notes that the process of enforcing money judgments is subject to judicial supervision. After
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entry of judgment and on application of the judgment creditor, the court clerk issues a writ of
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execution directed to the levying office to any registered process server. The levying officer must
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serve a copy of the writ of execution and the notice of and a notice of levy on the judgment
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debtor and return the writ to the court with a report of the officer’s action and an accounting of
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amounts collected and costs incurred. These activities are communicative and were the actions
21 taken in the underlying action. Plaintiff is not alleging fraudulent or false information on the
22 judgment, writ or subsequent levies or liens as did Mr. Cohen in the Rusheen litigation. Given
23 this factor, all of Defendants’ conduct was communicative and therefore the litigation privilege
24 protects the process that each of them engaged in to execute the writ and the acts carrying out
25 said execution. As stated in the Court’ s findings
“Accordingly, we conclude that if the gravamen of the action is
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communicative, the litigation privilege extends to noncommunicative acts that are
27 necessarily related to the communicative conduct, which in this case included acts
necessary to enforce the judgment and carry out the directive of the writ. (See
28 Rubin, supra, 4 Cal.4th at p. 1195 [fact that defendants' communications
"necessarily involved related acts" does not destroy privilege]; Brown, supra, 94
- Defendants’ Reply in Support of Special Motion to Strike
Liu v. Higginbotham et al.
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1 Cal.App.4th at p. 50; O'Keefe, supra, 84 Cal.App.4th at p. 134.) Stated another
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way, unless it is demonstrated that an independent, noncommunicative, wrongful
act was the gravamen of the action, the litigation privilege applies.”
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Plaintiff does not make such claim in her first amended complaint and fails to articulate
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how Defendants Jose Ceron and Monica Medina conduct was non communicative. According to
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the Rusheen court, the following acts have been deemed noncommunicative and thus
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unprivileged: prelitigation illegal recording of confidential telephone conversations (Kimmel v.
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Goland (1990) 51 Cal.3d 202, 211); eavesdropping on a telephone conversation (Ribas v. Clark,
8 (1985) 38 Cal.3d 355, 364-365); physician’s negligent examination of patient causing physical
9 injury. Mero v. Sadoff (1995) 31 Cal.App.4th 1466, 1479-1480.The “[p]leadings and process in a
10 case are generally viewed as privileged communications.” (Navellier v. Sletten (2003) 106
11 Cal.App.4th 763, 770.) Plaintiff asserts no facts in her first amended complaint or her opposition
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that allege Defendants’ conduct to be non-communicative and/or unprivileged.
Plaintiff also relies on Mancini & Associates v. Schwetz (2019) 39 Cal. App. 5th 656
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which is perplexing. There was no SLAPP motion ins Mancini and the crux of the issue is
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whether the Plaintiff’s direct settlement discussions with the defendant were privileged and could
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be shielded from Plaintiff’s attorney. There is no rhyme or reason why this case should be cited
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in Plaintiff’s opposition. Defendants Jose Ceron and Monica Medina successfully shifted the
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burden to Plaintiff and her opposition fails as to the cause of action for conversion and therefore
18 said cause of action should be stricken.
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C. Plaintiff’s Breach of Contract Complaint
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21 Plaintiff fails to deal with the heart of the issue, that being that there was no contract
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between these Defendants and Plaintiff. Plaintiff cites Wong v. Wong, (2019) 43 Cal. App. 5th
358 as the basis for why the litigation privilege does not apply and should not be applied in this
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Court’s analysis of Plaintiff’s breach of a third-party contract. Plaintiff’s reliance on Wong is
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misplaced. In Wong and husband and wife were deceased one estate(Tang) sued the other
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estate(Wong) for indemnification pursuant to a divorce decry that involved a specific parcel or
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property. If either party was sued pursuant to the ownership interest in said property, the party
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that was sued to no fault of their own was to be indemnified. The Tang Estate was forced to pay
28 off a note pursuant to a loan Wong had obtained to cure a notice of default. After paying off said
- Defendants’ Reply in Support of Special Motion to Strike
Liu v. Higginbotham et al.
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1 loan the Tang Estate sought reimbursement from the Wong Estate. Despite having no protected
2 activity, the Wong Estate filed a SLAPP motion that was denied by the trial court and soundly
3 rebuked by the Court of Appeal. There is not a single issue or fact that remotely relates to the
4 matter before this Court.
5 As far as the attack on the merits, Plaintiff fails to cite any authority that allows her to
proceed as a third-party beneficiary on an alleged contract between Defendants’ counsel and an
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escrow company. Plaintiff does not assert at anytime that Jose Ceron and Monica Medina
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entered into any contract with her or anyone else. The lack of a substantive opposition to the
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SLAPP motion on the breach of contract claim requires that Plaintiff’s second cause of action for
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breach of contract be stricken.
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D. Common Counts Cause of Action
11 Plaintiff again cites cases that have no bearing on the matter at hand. Beginning with
12 Personal Court Reporters, Inc. v. Rand (2012) 205 Cal.App.4th 182 and states at page 14, Lines
13 10-11 that, “there is no principled distinction between nonpayment of overdue invoices, and the
14 over-collection of a debt.” Plaintiff continues to treat defendants as vendors, and they are tenants,
15 not vendors and not in a business relationship. In Personal Court Reporters, Inc. defendants did
not pay an invoice after services were tendered. Here, Plaintiff refused, thwarted and avoided
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paying a jury verdict against her for mismanaging her building. Plaintiff was the debtor who
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avoided paying her debt and Plaintiff’s position is closer to Defendants Rand & Rand than it is to
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the court reporter that rendered considerable court reporting services without being paid.
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Plaintiff then relies on Drell v. Cohen (2014) 232 Cal. App 4th 24 which is less on point
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than Personal Court Reporters, Inc. Drell is a fee and lien dispute. A quick read and it is clear
21 this case does not relate to the matter at hand, and Defendants are precluded from a detailed
22 articulation as to why since they are close to their page limit on reply briefs. Plaintiff has also
23 failed to make a showing or submit any evidence that Defendants Jose Ceron and Monica
24 Medina received funds that they should not have and therefore the cause of action for common
25 counts should be stricken.
E. Failure to File a Satisfaction of Judgment
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As a threshold matter, defense counsel misquotes Judge Ulmer’s December 22, 2016
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Order on Plaintiff’s citing on page 17 at Lines 6-7, stating, “The motion was denied ‘without
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prejudice and Sally Liu’s right to bring an action rather than a motion is secure by CCP724.050.
- Defendants’ Reply in Support of Special Motion to Strike
Liu v. Higginbotham et al.
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1 The actual Order reads quite different and essentially defeats Plaintiff’s fifth cause of
2 action in her first amended complaint. Said Order reads as follows:
3 DEFENDANT SALLY LIU'S Motion For Order Directing Filing Of Satisfaction Of
Judgment And Return Of Over-Collected Amounts is DENIED WITHOUT
4 PREJUDICE. Defendant Liu has already been given a written acknowledgement of
satisfaction of judgment. Plaintiffs were not required to file that document, as CCP
5 724.010(b) applies and CCP 724.030 does not, because the judgment was satisfied by
writ. As to the claim that amounts were over-collected, Mr. Higginbotham's October 4,
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2016 e-mail and plaintiffs' opposition provide explanations, to which Defendant Liu has
7 not responded coherently.
8 Plaintiff attempts to misconstrue said order as an invitation for her to refile her
9 motion(See Plaintiff’s Opposition at page 17, Lines 15-16). Said Order contained no
10 ambiguity and found that the satisfaction of judgment was provided to Plaintiff Sally Liu
and did not need to be filed. Assuming arguendo, Plaintiff did not refile her motion but
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instead waited three years to bring the present action.
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Clearly, this cause of action falls within the scope of the litigation privilege and
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given Judge Ulmer’s December 22, 2016 Order, the lack of facts in the first amended
14
complaint and the failure to address this issue in the opposition, Plaintiff cannot prevail
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on this cause of action, and said cause of action must be stricken.
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17 III. CONCLUSION
18 Plaintiff’s incoherent opposition offers much case law that is not on point, including
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some cases that are not even remotely relevant to the case before this Court( Wong, Personal
Court Reporters, Inc., Drell and Mancini & Associates), confuses facts and attempts to distort
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this Court’s prior ruling from December 22, 2016. The allegation that notice was not proper is
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defeated by a ten second review of the notice of motion for Defendants Monica Medina and Jose
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Ceron. Plaintiff’s first amended complaint contains a breach of contract action where there is no
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contract, a common counts cause of action when there is no vendor relationship or even an
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allegation of any such relationship and a cause of action for failure to file a satisfaction when this
25 specific issue was decided by this Court over three years ago. Plaintiff’s opposition fails meet its
26 burden which was shifted to her with the present motion, accordingly Defendants Monica
27 Medina and Jose Ceron special motion to strike should be granted in its entirety.
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- Defendants’ Reply in Support of Special Motion to Strike
Liu v. Higginbotham et al.
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1 Dated: June 24, 2020
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3 Respectfully Submitted,
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5 __//Jeff B. Workman//______________________________
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Jeff Workman
Attorney for Plaintiffs Ceron et al.
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- Defendants’ Reply in Support of Special Motion to Strike
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Preview
1 EDWARD M. HIGGINBOTHAM, SBN 231636 2 JEFFREY B. WORKMAN, SBN 287066 Attorneys at Law ELECTRONICALLY 3 885 Bryant Street, Second Floor F I L E D San Francisco, CA 94103 Superior Court of California, 4 County of San Francisco 415.581.0885 Tel 5 415.581.0887 Fax 06/25/2020 Clerk of the Court BY: RONNIE OTERO 6 Attorneys for Defendants Jose Ceron, Monica Medina and Judy Judkins Deputy Clerk 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 11 SALLY LIU, an individual ) 12 ) Plaintiff, ) CASE NO. CGC-19-577432 13 ) vs. ) DEFENDANTS’ REPLY TO 14 ) PLAINTIFF’S OPPOSITION TO EDWARD M. HIGGINBOTHAM, an ) DEFENDANT JOSE CERON AND 15 individual, JOSE CERON, an individual, ) MONICA MEDINA’S SPECIAL MOTION ESPETACION MONQIUE MEDINA, an ) TO STRIKE 16 ) individual, BRIAN RANGEL, an individual ) 17 and JUDY JUDKINS, an individual and Does ) Hearing Date: June 30, 2020 1-20 inclusive ) Dept.: 302 18 Time: 9:30 a.m. Defendants. 19 20 21 I. SUMMARY OF PLAINTIFF’S ARGUMENTS 22 A. Plaintiff Claims she Did Not Receive Proper Notice 23 B. Defendants Monica Medina and Jose Ceron Failed to Demonstrate that the 24 Activity in Question is Protected 25 26 II. LEGAL ARGUMENT 27 A. Special Motion to Strike was Properly Noticed 28 As identified in the notice of this motion, the SLAPP motion before this Court is on behalf of Jose Ceron and Monica Medina and seeks to strike the first, second, third and fifth - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 1- 1 causes of action. Said notice was clear on its face, and provided the June 30 th hearing date. Co- 2 Defendants have filed separate motions and Brian Rangel was dismissed as he should have never 3 been included, so notice was proper, timely and abundantly clear. 4 B. Conversion is Not Exempt from a Special Motion to Strike 5 It is undisputed that Plaintiff Sally Liu received a meet & confer correspondence in explaining that the first amended complaint was subject to a SLAPP motion. It is also 6 undisputed that she never responded. Plaintiff claims that her conversion cause of action against 7 these Defendants is immune from the special motion to strike before this Court. The citations to 8 the penal code are completely irrelevant and need not be addressed. Communications with ‘some 9 relation’ to judicial proceedings” are “absolutely immune from tort liability” by the litigation 10 privilege. Rubin v. Green (1993) 4 Cal.4th 1187, 1193 11 Plaintiff does include case law to her support her position that a cause of action for 12 conversion is not proceed by the litigation privilege and relies heavily on Rusheen v. Cohen 13 (2006) 27 Cal. 4th 1048. A close read of Rusheen and said case does not exclude conversion 14 causes of action from the litigation privilege, to the contrary, Rusheen articulates that a 15 conversion cause of can be stricken pursuant to a special motion to strike. The Rusheen court notes that the process of enforcing money judgments is subject to judicial supervision. After 16 entry of judgment and on application of the judgment creditor, the court clerk issues a writ of 17 execution directed to the levying office to any registered process server. The levying officer must 18 serve a copy of the writ of execution and the notice of and a notice of levy on the judgment 19 debtor and return the writ to the court with a report of the officer’s action and an accounting of 20 amounts collected and costs incurred. These activities are communicative and were the actions 21 taken in the underlying action. Plaintiff is not alleging fraudulent or false information on the 22 judgment, writ or subsequent levies or liens as did Mr. Cohen in the Rusheen litigation. Given 23 this factor, all of Defendants’ conduct was communicative and therefore the litigation privilege 24 protects the process that each of them engaged in to execute the writ and the acts carrying out 25 said execution. As stated in the Court’ s findings “Accordingly, we conclude that if the gravamen of the action is 26 communicative, the litigation privilege extends to noncommunicative acts that are 27 necessarily related to the communicative conduct, which in this case included acts necessary to enforce the judgment and carry out the directive of the writ. (See 28 Rubin, supra, 4 Cal.4th at p. 1195 [fact that defendants' communications "necessarily involved related acts" does not destroy privilege]; Brown, supra, 94 - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 2- 1 Cal.App.4th at p. 50; O'Keefe, supra, 84 Cal.App.4th at p. 134.) Stated another 2 way, unless it is demonstrated that an independent, noncommunicative, wrongful act was the gravamen of the action, the litigation privilege applies.” 3 Plaintiff does not make such claim in her first amended complaint and fails to articulate 4 how Defendants Jose Ceron and Monica Medina conduct was non communicative. According to 5 the Rusheen court, the following acts have been deemed noncommunicative and thus 6 unprivileged: prelitigation illegal recording of confidential telephone conversations (Kimmel v. 7 Goland (1990) 51 Cal.3d 202, 211); eavesdropping on a telephone conversation (Ribas v. Clark, 8 (1985) 38 Cal.3d 355, 364-365); physician’s negligent examination of patient causing physical 9 injury. Mero v. Sadoff (1995) 31 Cal.App.4th 1466, 1479-1480.The “[p]leadings and process in a 10 case are generally viewed as privileged communications.” (Navellier v. Sletten (2003) 106 11 Cal.App.4th 763, 770.) Plaintiff asserts no facts in her first amended complaint or her opposition 12 that allege Defendants’ conduct to be non-communicative and/or unprivileged. Plaintiff also relies on Mancini & Associates v. Schwetz (2019) 39 Cal. App. 5th 656 13 which is perplexing. There was no SLAPP motion ins Mancini and the crux of the issue is 14 whether the Plaintiff’s direct settlement discussions with the defendant were privileged and could 15 be shielded from Plaintiff’s attorney. There is no rhyme or reason why this case should be cited 16 in Plaintiff’s opposition. Defendants Jose Ceron and Monica Medina successfully shifted the 17 burden to Plaintiff and her opposition fails as to the cause of action for conversion and therefore 18 said cause of action should be stricken. 19 C. Plaintiff’s Breach of Contract Complaint 20 21 Plaintiff fails to deal with the heart of the issue, that being that there was no contract 22 between these Defendants and Plaintiff. Plaintiff cites Wong v. Wong, (2019) 43 Cal. App. 5th 358 as the basis for why the litigation privilege does not apply and should not be applied in this 23 Court’s analysis of Plaintiff’s breach of a third-party contract. Plaintiff’s reliance on Wong is 24 misplaced. In Wong and husband and wife were deceased one estate(Tang) sued the other 25 estate(Wong) for indemnification pursuant to a divorce decry that involved a specific parcel or 26 property. If either party was sued pursuant to the ownership interest in said property, the party 27 that was sued to no fault of their own was to be indemnified. The Tang Estate was forced to pay 28 off a note pursuant to a loan Wong had obtained to cure a notice of default. After paying off said - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 3- 1 loan the Tang Estate sought reimbursement from the Wong Estate. Despite having no protected 2 activity, the Wong Estate filed a SLAPP motion that was denied by the trial court and soundly 3 rebuked by the Court of Appeal. There is not a single issue or fact that remotely relates to the 4 matter before this Court. 5 As far as the attack on the merits, Plaintiff fails to cite any authority that allows her to proceed as a third-party beneficiary on an alleged contract between Defendants’ counsel and an 6 escrow company. Plaintiff does not assert at anytime that Jose Ceron and Monica Medina 7 entered into any contract with her or anyone else. The lack of a substantive opposition to the 8 SLAPP motion on the breach of contract claim requires that Plaintiff’s second cause of action for 9 breach of contract be stricken. 10 D. Common Counts Cause of Action 11 Plaintiff again cites cases that have no bearing on the matter at hand. Beginning with 12 Personal Court Reporters, Inc. v. Rand (2012) 205 Cal.App.4th 182 and states at page 14, Lines 13 10-11 that, “there is no principled distinction between nonpayment of overdue invoices, and the 14 over-collection of a debt.” Plaintiff continues to treat defendants as vendors, and they are tenants, 15 not vendors and not in a business relationship. In Personal Court Reporters, Inc. defendants did not pay an invoice after services were tendered. Here, Plaintiff refused, thwarted and avoided 16 paying a jury verdict against her for mismanaging her building. Plaintiff was the debtor who 17 avoided paying her debt and Plaintiff’s position is closer to Defendants Rand & Rand than it is to 18 the court reporter that rendered considerable court reporting services without being paid. 19 Plaintiff then relies on Drell v. Cohen (2014) 232 Cal. App 4th 24 which is less on point 20 than Personal Court Reporters, Inc. Drell is a fee and lien dispute. A quick read and it is clear 21 this case does not relate to the matter at hand, and Defendants are precluded from a detailed 22 articulation as to why since they are close to their page limit on reply briefs. Plaintiff has also 23 failed to make a showing or submit any evidence that Defendants Jose Ceron and Monica 24 Medina received funds that they should not have and therefore the cause of action for common 25 counts should be stricken. E. Failure to File a Satisfaction of Judgment 26 As a threshold matter, defense counsel misquotes Judge Ulmer’s December 22, 2016 27 Order on Plaintiff’s citing on page 17 at Lines 6-7, stating, “The motion was denied ‘without 28 prejudice and Sally Liu’s right to bring an action rather than a motion is secure by CCP724.050. - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 4- 1 The actual Order reads quite different and essentially defeats Plaintiff’s fifth cause of 2 action in her first amended complaint. Said Order reads as follows: 3 DEFENDANT SALLY LIU'S Motion For Order Directing Filing Of Satisfaction Of Judgment And Return Of Over-Collected Amounts is DENIED WITHOUT 4 PREJUDICE. Defendant Liu has already been given a written acknowledgement of satisfaction of judgment. Plaintiffs were not required to file that document, as CCP 5 724.010(b) applies and CCP 724.030 does not, because the judgment was satisfied by writ. As to the claim that amounts were over-collected, Mr. Higginbotham's October 4, 6 2016 e-mail and plaintiffs' opposition provide explanations, to which Defendant Liu has 7 not responded coherently. 8 Plaintiff attempts to misconstrue said order as an invitation for her to refile her 9 motion(See Plaintiff’s Opposition at page 17, Lines 15-16). Said Order contained no 10 ambiguity and found that the satisfaction of judgment was provided to Plaintiff Sally Liu and did not need to be filed. Assuming arguendo, Plaintiff did not refile her motion but 11 instead waited three years to bring the present action. 12 Clearly, this cause of action falls within the scope of the litigation privilege and 13 given Judge Ulmer’s December 22, 2016 Order, the lack of facts in the first amended 14 complaint and the failure to address this issue in the opposition, Plaintiff cannot prevail 15 on this cause of action, and said cause of action must be stricken. 16 17 III. CONCLUSION 18 Plaintiff’s incoherent opposition offers much case law that is not on point, including 19 some cases that are not even remotely relevant to the case before this Court( Wong, Personal Court Reporters, Inc., Drell and Mancini & Associates), confuses facts and attempts to distort 20 this Court’s prior ruling from December 22, 2016. The allegation that notice was not proper is 21 defeated by a ten second review of the notice of motion for Defendants Monica Medina and Jose 22 Ceron. Plaintiff’s first amended complaint contains a breach of contract action where there is no 23 contract, a common counts cause of action when there is no vendor relationship or even an 24 allegation of any such relationship and a cause of action for failure to file a satisfaction when this 25 specific issue was decided by this Court over three years ago. Plaintiff’s opposition fails meet its 26 burden which was shifted to her with the present motion, accordingly Defendants Monica 27 Medina and Jose Ceron special motion to strike should be granted in its entirety. 28 - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 5- 1 Dated: June 24, 2020 2 3 Respectfully Submitted, 4 5 __//Jeff B. Workman//______________________________ 6 Jeff Workman Attorney for Plaintiffs Ceron et al. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - Defendants’ Reply in Support of Special Motion to Strike Liu v. Higginbotham et al. 6-