Motion to Stay Proceedings in COLLEEN CUDD vs TIFFANY LI| Trellis.Law

On March 16, 2018 a Motion-Secondary was filed involving a dispute between Cudd, Colleen Kay, Green, Vivienne Li, O'Brien, Eileen, and Adella, Olivier, Bayat, Kaveh, Does 1 Through 10, Inclusive, Li, Tiffany, for Complex Civil Unlimited in the District Court of San Mateo County.

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Jason E. Fellner - 245364
JFellner@mpbf.com
- 287894
FILEE'

Caitlin T. DiMaggio SAN MATEO (‘QUNTY ’1
CDiMaggio@mpbf.com
.Tarah G. Powell—Chen - 316359 MAY f“
'
1 2018
' ‘

TPowell-Chen@rnpbf.com _

iMURPHY, PEARSON, BRADLEY & FEENEY desk 5241”
5,» the}
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88 Keamy Street, 10th Floor y
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San Francisco, CA 94108-5530
Telephone: (415) 788-1900
>
Facsimile: (415) 393-8087

Attorneys for Defendant
. ,
TIFFANY LI

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN MATEO

; COLLEEN KAY CUDD, individually and as Case Not: ‘18—CIV ~01‘355
f
representative of the Estate of Keith Cameron
; Green; VIVIENNE LI GREEN, through Court-
j.Appointed Guardian EILEEN O'BRIEN; and REPLY IN SUPPORT OF DEFENDANT
'
NIA LI GREEN, through Court—Appointed TIFFANY LI‘S MOTION TO STAY CIVIL
Guardian EILEEN O'BRIEN, PROCEEDINGS

Plaintiff, Date: May 8, 2018
Time: 9:90 am
v. Dept: Law & Motion

TIFFANY LI, an individual; KAVEH BAYAT, Action Filed: March 16, 2018
. an individual; OLIVIER ADELLA, an Trial Date: Not yet set
.
individual; and DOES 1 through

Defendants.
10, inclusive,
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Memorandum 01Points and Authorities in Rap!
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-1-
REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROr EEDINGS
H TABLEOFCONTENTS
Page

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II. IJEChAI,AdiCﬂltTTT."uuu.”nnnn."u“as-“sm“.nuu.uhaunuun."nun. .......... .“nﬁsh ...... ."4

A. Defendant Li’s Fifth Amendment Rights Are Heavily lmplicated ....... ,,,,, 4

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B. The Five Keating Factors Favor a Stay ........................ a... ...... ........6

l. Plaintiffs Do Not Face Substantial Prejudice By a Stay ..... 6

2 The Burden on Defendant Li is Signiﬁcant ..... ...... ............ 7

3. The Efﬁcient Use of Judicial Resources Weighs in Favor of a Stay ... ......
8

4 The Interests of Persons Not Parties to the Civil Litigation Weigh In
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5. The Interest of the Public Further Favors a Stay...~..-.;..-........ ......... 1,; ......
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-2-
REPLY IN SUPPORT OF DEFENDANT TIFFANY LI‘S MOTION TO STAY CIVIL PROCEEDINGS
TABLE OF AUTHORITIES

Page
gusto

CASES

Campbell 12. Eastland
(5th Cir. 1962) 307 F.2d 478 ........................................................... ....................................... ,. ............... 7
,

Douglas v. United States
No. C 03-04518 JW, 2006 WL 2038375, at *6 ................................ 9
.................

Fed. Sav. & Loan Ins. Corp. v.Molinaro
\OOO\]O\
(9th Cir. . ~.
............ .................. '4
1989) 889 F.2d 899-..,...,.....- ........................... ............................ .

Fuller v. Superior Court
(2001) 87 Ca1.App.4th 299 ............ 4
‘

10 Gordon v.Fed. Deposit Ins. Corp.
(DC. Cir. 1970) 427 F.2d 578 ............. ...7
11

‘13
Jones v.
(N .D.

Keating v.
Conte
Cal. Apr. 19,2005) No.

Oﬂice of the
C-‘04—5312

Thrift Supervision
SI, 2005 WL 1287017, at *2".. ‘

....... 8, 9

45 F.3d 322 (9th Cir. 1995)............ ............. .............. . ............. ..... '.
,
*

...........
, 4, 6,7, 8, 9
14
Neman Fin, L.P. v. Citigroup Global Mkts., Inc.
(CD. Cal. Apr. 17, 2015) No. CV 14-02499-BRO (PLAX), 2015 WL 12837640, at *4...-...., ............ 5

17
Pacers v.
(1984)

Roberts v.
Superior Court
162 Ca1.App.3d 686

Brown
................................ . .....
, ..4 5

18 (CD. Cal. July 14, 2014) No. 2:13—CV-07461 ODW (JCX) 2014 WL 3503094, a1 *2.. .................. 4

19 Securities & Exchange Commission v.Dresser Industries, Inc.
(DC. Cir. 1980) 628 F.2d 1368 ........
A
4
20
STATUTES
21
Code of Civil Procedure
22 § 37 ....... .m."an"...“my.uuwa..-...........; ............... ,.....w..........................., ...................................................... .7

_3 _

REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
I. INTRODUCTION
A stay of this civil case is necessary to prevent substantial prejudice to Defendant Tiffany Li’s
U.)
ability to defend herself in this action. “Tjhe strongest case for deferring civil proceedings until after

completion of criminal proceedings is where a party under indictment for a serious offense is required.

to defend a civil or administrative action involving the same matter.” (Securities & Exchange

Commission v.Dresser Industries, Inc. (DC. Cir. 1980) 628 F.2d 1368, 1375-1376.) Where, as here,
\OOO\lO\UI-I>

the facts underlying the civil and criminal proceedings are duplicative, a stay is necessary to preserve an

individual’s Fifth Amendment Rights. Although Plaintiffs have an interest in the civil case proceeding,

which it will, there is no prejudice to Plaintiffs by imposing a reasonable stay based on the upcoming

10 criminal trial. Co'ntrasted with the substantial prejudice to Defendant Tiffany Li if she is forced to choose

11 between exercising her Fifth Amendment rights and providing testimony in her defense in the civil case,

12 the factors weigh heavily in favor of a stay. In these circumstances, a stay is necessary to preserve

13 Defendant Li’s Constitutional rights. The court may stay civil proceedings when the interests ofjustice

14, so require, which is warranted in this case. (Keating v. Office of the Thrift Supervision, 45 F.3d 322, 324

15 II(9th Cir. 1995).

16 II. LEGAL ARGUMENT
17 A. Defendant Li’s Fifth Amendment Rights Are Heavily Implicated

18 As identiﬁed in Defendant Li’s moving papers, the ﬁrst step for the court to assess is “the extent
I!

19 to which the defendant’s Fifth Amendment rights are implicated.” (Keating at 324.) Courts have found

20 II that
“there is a strong casein favor of g stav after a grand jury returns a criminal indictment and Where

'21 there is a large degree of overlap between the facts involved in bet ” civil and criminal cases. (Roberts

. "v. Brown, (CD. Cal. July 14, 2014) No. 2:13—CV-07461 ODW (JCX) 2014 WL 3503094, at *2 [listing

23 cases].) However, “the case for staying civil proceedings is a far weaker one where no indictment has

24 I returned, and no Fifth Amendment privilege is threatened.” (Fed. Sav. & Loan Ins. Corp. v.Molinaro,

25 (9th Cir. 1989) 889 F.2d 899, 903.) Plaintiff Cudd’s opposition fails to account for this important

26 idistinction, relying on cases in support of denying the stay where the criminal prosecution was merely

27 threatened. (See e.g. Plaintiff Cudd’s Opposition at p. 928-10224, citing to Fuller v. Superior Court

28 (2001) 87 Cal.App.4th 299; Pacers v. Superior Court (1984) 162 Cal.App.3d 686). In contrast here, the

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REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
II
reasons supporting a stay of the criminal proceedings as identiﬁed in Pacers are even more compelling

here, as the criminal proceedings against Tiffany Li are pending with a set trial date of September 17,

2018. (Pacers v.Superior Court ( 1984) 162 Cal.App.3d 686, 689.) Plaintiff Cudd’s opposition further
confuses the issue of how Defendant Li’s Fifth Amendment rights are implicated by arguing the motion
is premature because she has not yet invoked her right to silence in the civil proceedings. (See Plaintiff
Cudd’s Opposition at p. 10:21-22: “She is not being forced to choose between her right to silence and

her right to defend the civil action because there is no civil trial pending”)
\OOO\10\

Plaintiff Cudd’s Opposition misses the point, and indeed, on balance, provides further support

for a stay of the civil action. Where there is substantial overlap to the subject matter of both the civil—

10 and criminal cases, a stay of the civil case is necessary to protect the defendant’s constitutional rights:

11 “it has been consistently held that when both civil and criminal proceedings arise out of the same or

12 related transactions, an objecting party is generally entitled to a stay of discovery in the civil action until
13 disposition of the criminal matter.” (Pacers, Inc. v. Sup. Ct. (1984) 162 Cal.App.3d 686, 690.) The

.14 rationale is based on Fifth Amendment principles as well as the inherent unfairness of compelling
15 disclosure of a criminal defendant’s evidence and defenses before the criminal trial. (Id) When criminal
16 and civil proceedings overlap signiﬁcantly, the civil case implicates Fifth Amendment rights. (See

17 Neman Fin, L.P. v. Citigroup Global Mitts, Inc. (CD. Cal. Apr. 17, 2015) No. CV l4—02499-BRO

18 (PLAX), 2015 WL 12837640, at *4 [“That this case involves factual circumstances related to those

19 underlying the criminal charges suggests that Plaintiffs[’] Fifth Amendment rights may be adversely

20 affected if this matter proceeds.”].) Thus, if the civil case moves forward, Defendant Li would have to
21 choose between exercising her Fifth Amendment rights and testifying on her behalf in the civil case.

22 The civil case here and the pending criminal proceedings both arise from the same

23 circumstances: the death of Keith Green. The nearly duplicative overlap of the subject matter at issue

24 in both this civil case and the pending criminal action (The People of the State of California v. Olivier
25 Adella, Kaveh Bayat, Tifany Li, Superior Court of California, County of San Mateo, Case No. 0730964,
26 Docket No. 16-SF-005932-C) is highlighted by the nearly seven pages devoted to “background” in
27 Plaintiff Cudd’s Opposition brief which refers to the criminal proceedings’ preliminary hearing.

28 However, the only undisputed fact relevant to the court’s inquiry of the motion to stay is that there is a

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REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
related criminal case pending in the Superior Court, County of San Mateo, arising from the same

circumstances as this civil case. Plaintiff Cudd’s references to the preliminary hearing transcript in her

Opposition, and the accompanying declaration of her counsel Alison Cordova are objectionable. (See

Objection to Declaration of Alison Cordova, ﬁled concurrently with Defendant Tiffany Li’s Reply In

Support of Motion to Stay),

The correlation of this civil action to the criminal proceeding makes it impossible for Defendant
Li to defend herself against Plaintiffs allegations without waiving her Constitutional rights. Plaintiff‘s

Opposition attempts to identify discovery requests which will not implicate Defendant Li’s rights,

pointing to the damages sought pursuant to the wrongful death claim and the fraud claim and related

10 discovery of the custody dispute between Keith Green and Tiffany Li. (See Plaintiff Cudd’s Opposition

ll at p. 10:26 — 11:27). Yet, both of these topics could have an impact on the criminal proceedings and

1 {\J may be legitimately interpreted as potentially incriminating to Defendant Li, flu'ther evidencing the need

13 for a stay of the civil action. While Defendant Li is not the only witness whose testimony would be

14 required, as the person with the most direct knowledge of the prior custody dispute and ﬁnancial support
15 her daughters received from the deceased Keith Green, her testimony would be indispensable to

16 disposition of the civil action. What’ 5 more, discovery sought in the civil case could be improperly used

17 in the criminal case or used by Plaintiff or her counsel to taint the jury pool by sending information to

18 the media. A stay is warranted to ensure the civil case is not substantially interfered by the pending

19 criminal proceedings.

20 B. The Five Keating Factors Favor a Stay
2.1 As set forth in Defendant Li’s moving papers, an analysis of the additional Keating factors favors

issuance of a stay:
23 1. Plaintiffs Do Not Face Substantial Prejudice By a Stay

24 The ﬁrst Keating factor requires the court to consider “the interest of the plaintiffs in proceeding

25 expeditiously with this litigation or any particular aspect of it, and the potential prejudice to plaintiffs of

26 a delay.” (Keating v. Oﬁice of Thrift Supervision, (9th Cir. 1995) 45 F.3d 322, 325.) Plaintiff CuddI

argues, without any speciﬁc evidence identiﬁed, that “[t]o delay [ ] discovery would delay expeditious

28 resolution of this case and prejudice Plaintiffs’ ability to obtain material discovery as to years have

_ 6 _

REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
already passed and witnesses’ memories fade.” (Plaintiff Cudd’s Opposition, p.12t4-6). Plaintiff Cudd

also argues Plaintiffs’ are prejudiced based on the entirely speculative assumption the civil trial willbe

set for preference‘. Plaintiff Cudd’s unsupported arguments do not identify how a delay in the
ADJ

proceedings would cause undue prejudice. While it is undeniable that Plaintiffs have a valid interest in
the prompt resolution of their claims, where Defendant Li’s Fifth Amendment rights are heavily

implicated and the potential impact on the criminal proceedings substantial, Plaintiffs’ interests do not

outweigh the necessity of a stay, as is the case here, especially when the duration of the requested stay
\OOO\]O\

is short in length.

2. The Burden on Defendant Li is Signiﬁcant
10 Under the second Keating factor; the Court analyzes the “burden which any particular aspect of

ll the proceedings may impose on defendants.” (Keating, 45 F.3d at 325.) As set forth in detail in

Defendant Li’s moving papers, she faces substantial prejudice if compelled to proceed with this civil

13 case while the criminal proceedings are pending, given the signiﬁcant overlap between the facts of this
14 action and the criminal case, and Defendant Li’s status as a critical witness to defend herself in the civil

15 case.

16 Plaintiff Cudd’s Opposition suggests Defendant Li should be forced 'to invoke her Fifth

17 Amendment rights at each step of the civil discovery sought, but this cuts against the principles which

18 support a stay. “The court must not only be concerned with the general consideration of whether the
19 real purpose of the civil discovery is to obtain information that is unavailable directly in a criminal

20 proceeding, but with the further question Whether to permit any discovery of the type that requires the

21 criminal defendant to testify, for this obviously involves aspects of the privilege against self—

22 incrimination.” (Gordon v. Fed. Deposit Ins. Corp. (DC. Cir. 1970) 427 F.2d 578, 580, citing Campbell

23 v. Eastland (5th Cir. 1962) 307 F.2d 478, 487 [holding that in handling motions for a stay of a civil suit

24 until the disposition of a criminal prosecution on related matters and in ruling on motions under the civil

25 discovery procedures, a judge should be sensitive to the difference in the rules of discovery in civil and

26 1
Plaintiff Cudd argues the civil case is entitled to statutory preference under C.C.P. § 37, with the
improper and completely unsupported assumption of Defendant Li’s guilt: “Once Defendant gets
27 convicted, this case will have statutory preference for tria .” (Plaintiff Cudd’s Opposition, p. 14:3).
Nothing could be further from this falsehood as Defendant Li isinnocent and is innocent until proven
28 otherwise.

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REPLY 3N SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
criminal cases].) Given the potential signiﬁcance of the civil discovery to the ongoing criminal

proceedings, which will necessarily bear heavily on Defendant Li’s Fifth Amendment rights, permitting

the civil case to proceed would cause undue prejudice.
m-PWNH

3. The Efﬁcient Use of Judicial Resources Weighs in Favor of 3 Stay
The third Keating factor, not addressed by Plaintiff Cudd’s Opposition, permits the court to

determine whether a stay will impact “the convenience of the court in the management of its cases, and
—-v

the efﬁcient use ofjudicial resources.” (Keating, supra, 45 F.3d at 324-325 .) This factor strongly favors
w
\DOO\)O\

a full stay. There is nothing to be gained by moving forward now — and permitting discovery even on

the few narrow issues which arguably would not implicate Defendant Li’s Fifth Amendment rights

10 would lead to an inefﬁcient outcome. (See Jones v.Conte (ND. Cal. Apr. 19, 2005) No. C 04-5312 SI,

11 2005 WL 1287017, at *2 [“Staying the case makes efﬁcient use of judicial resources by insuring that

12 common issues of fact will be resolved and subsequent civil discovery will proceed unobstructed by

13 concerns regarding self-incrimination.”].) The majority of anticipated questions related to the causes of

14 action Plaintiff Cudd argues are separate and distinct from those completely overlapping with the

15 criminal proceedings are still arguably intertwined, which would lead to Defendant Li invoking her Fifth

16 Amendment privilege. The result is likely to cause a number of otherwise avoidable disputes related to

17 discovery, procedure, and timing. Furthermore, it is likely the outcome of the criminal proceeding will

18 streamline the civil issues and questions presented for the court. Therefore, the interests of judicial

19 efﬁciency strongly weight in favor of a stay.

20 4. The Interests of Persons Not Parties to the Civil Litigation Weigh In Favor of a
Stay
21
The fourth [fearing factor requires a court to assess “the interests of persons not parties to the.
22
civil litigation.” (Keating, supra, 45 F.3d at 325.) As identiﬁed in Defendant Li’s moving papers,

Defendant Li is unaware of any third parties adversely affected by a stay, and Plaintiff Cudd’ s Opposition
24
fails to identify any third parties negatively impacted by a stay. Instead, as discussed in Defendant Li’s
25
moving papers, the interests of third party Jihong Li, as a Non—Party and Court-Appointed Co—Guardian
2t)
of Li’s children, are beneﬁtted by a stay, as Plaintiff Cudd’s actions in the pending civil suit effect Ii hon g
27
Li’s legitimate interest as a co-guardian of her grandchildren.
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REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
5. The Interest of the Public Further Favors a Stay
The ﬁnal Keating factor directs the court to analyze “the interest of the public in the pending civil

and criminal litigation.” (Keating, supra, 45 F.3d at 325.) The public has an interest in “ensuring that

the criminal process is not subverted by ongoing civil cases.” (Douglas v. United States, No. C ()3-

04518 JW, 2006 WL 2038375, .at*6 (ND. Cal. July 17, 2006). Moreover, “the public interest is

furthered by a stay because ‘the public’s interest in the integrity of the criminal case is entitled to
\OOOQONUi-b

precedence over the civil litigant.” (Jones v. Comte, No. C 04-5312 SI, 2005 WL 1287017, at *2 (N .D.

Cal. Apr. 19, 2005).) Where, as here, the civil litigation has just commenced and there is signiﬁcant

media attention given to both proceedings, the public interest is best served by ensuring the integrity of

the criminal process and strict adherence to the rule of law. As the Ninth Circuit recognized in Keating,

“in such high visibility situations, it is especially necessary to guard the rights of defendants, and

concern for the public deterrence value of an enforcement proceeding must not he allowed to

override the individual defendant’s due process rights.” (Keating, supra, 45 F.3d at 326.)

Accordingly, this factor too weighs in favor of a stay.

III. CONCLUSION
‘
On balance, the particular circumstances and competing interests in this case warrant a stay: the

substantial implication of Defendant Li’s Fifth Amendment rights together with the minimal prejudice

II toPlaintiffs; the numerous evidentiary disputes which will likely arise if the stay is not granted; the

{likelihood that the outcome of the criminal proceedings will resolve a number of key issues in the civil

case; and the potential for abuse to the integrity of the civil and criminal proceedings without a stay. For

I these reasons, a stay of this civil action is necessary until the criminal proceedings against Defendant Li

and the other named civil defendants in this case have been resolved.

DATED: May 1,2018
MURPHY, PEARSON, BRADLEY & FEENEY
H

r By CL
Jason @ﬂlner
Caitlin’l DiMaggio
Tarah Powell- Chen
,
Attorneys for Defendant TIFFANY LI
CTD.324.473 l.docx

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REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO STAY CIVIL PROCEEDINGS
CERTIFICATE OF SERVICE

I, Krysia Flores, declare:

AWN I am a citizefn of the United States, am over the age of eighteen years, and am not a party to or

interested in the within entitled cause. My business address is 88 Kearny Street, 10th Floor, San

[J1
Francisco, CaliforniJa 94108.
1

On May 1, 2018, I served the following document(s) on the parties in the Within action:

REPLY IN SUPPORT OF DEFENDANT TIFFANY LI'S MOTION TO S AY CIVIL
1‘
\DOO\)O\

I
PROCEEDINGS
l

VIA OVERNIGHT SERVICE: The above—described document(s) will be delivered by
X overnight service, to the addresses listed below.
10 1'

11 Alison E. Cordova Attorney For Plaintiffs
Cotchett, Pitre & McCarthy, LLP COLLEN KAY CUDD; VIVIENNE LI
San Francisco Airport Ofﬁce Center GREEN; AND NIA LI GREEN
840 Malcolm Road, Suite 200
13 Burlingame, CA 94010
E-mail: acordova:@cpmlegal com
14
KeVin B. Jacksoni Attorney For JIHONG LI
15 Aaron, Riecher, Carpol & Rifﬂe, APC
Melissa Karlsten }

1-6
900 Veterans Blvd, Ste. 600
Redwood City, CA 94063
17 E-mail: karlsten@arcr. com
18 |

I declare milder penalty of perjury under the laws of the State of California that the foregoing is
19
a true and correct sltatement and that this Certiﬁcate was executed on May 1, 2018.
20

21
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22

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_ 10 -
REPLY IN SUPPORT OF DEFENDANT TIFFANY LI‘ S MOTION TO STAY CIVIL PROCEEDINGS
|

Case Info

Judge

Chou, Danny Y. Track Judge’s New Case

Case No.

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Document Filed Date

May 01, 2018

Case Filing Date

March 16, 2018

County

Parties

ADELLA, OLIVIER Defendant
BAYAT, KAVEH Defendant
CORDOVA, ALISON E Attorney for the Plaintiff
CUDD, COLLEEN KAY Plaintiff
DOES 1 THROUGH 10, INCLUSIVE Defendant
GREEN, VIVIENNE LI Plaintiff
LI, TIFFANY Defendant
O'BRIEN, EILEEN Plaintiff
PITRE, FRANK M. Attorney for the Plaintiff
Jason Fellner Attorneys for Defendants
Donald Magilligan Attorney
Nabilah Hossain Attorneys for Plaintiffs
Dek Ketchum Attorneys for Defendants
Tarah Powell-Chen Attorneys for Defendants
John Girarde Attorneys for Defendants
David Shapiro Attorney
David Millstein Attorney
Colleen Chikahisa Attorney
Caitlin DiMaggio Attorney
Beverly Narayan Attorneys for Defendants
Dana Fox Attorneys for Defendants
Stevan Luzaich Attorney
Andrea Nguyen Attorney
Melissa Karlsten Attorney
Kevin Jackson Attorney
Robert Bruening Attorneys for Plaintiffs
Samantha Wu Attorney
Alison Erca Attorney
David Anderson Attorney
Hallie Hoffman Attorney
Daniel Pastor Attorney
John Burke Attorney
David Beach Attorneys for Defendants
John Beiers Attorney
Tara Heumann Attorney
Joseph Lee Attorneys for Defendants
James Thompson Attorney
John Ma Attorney
Anne Freeman Attorney
Lorie Nachlis Attorney
Joel Shawn Attorney

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Motion-Secondary: COLLEEN CUDD vs TIFFANY LI

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