110 - reply re default judgment

7/29/2019 110 - Reply Re Default Judgment

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REPLY IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT

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GINGRAS

LAWO

FFICE,PLLC

3941E.CHAN

DLERBLVD.,#106-243

PHOENIX,AZ85048

David S. Gingras, #021097Gingras Law Office, PLLC3941 E. Chandler Blvd., #106-243Phoenix, AZ 85048Tel.: (480) 668-3623Fax: (480) 248-3196

[email protected]

Attorney for Plaintiff Xcentric Ventures, LLC

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

XCENTRIC VENTURES, LLC, anArizona limited liability company,

Plaintiff,v.

LISA JEAN BORODKIN et al.,

Defendants.

Case No.: 11-CV-1426-GMS

PLAINTIFFS REPLY TO

DEFENDANT LISA BORODKINS

OPPOSITION TO PLAINTIFFS

MOTION FOR DEFAULT

JUDGMENT AS TO DEFENDANTS

DANIEL BLACKERT AND ASIA

ECONOMIC INSTITUTE, LLC

Plaintiff XCENTRIC VENTURES, LLC (Plaintiff or Xcentric) respectfully

submits the following Reply to Defendant (Defendant or Ms. Borodkin) Response

(Opposition; Doc. #106) to Xcentrics Motion for Default Judgment As To Defendants

Daniel Blackert and Asia Economic Institute, LLC (Doc. #99).

I. ARGUMENTa. A Default Judgment Against Blackert Is Proper Because He Defaulted

PriorTo Xcentrics Amended Complaint

Because Xcentric was ordered to amend its Complaint based on Ms. Borodkins

first Motion for More Definite Statement, she now argues that Xcentric is not entitled to a

default judgment against Mr. Blackert even though he defaulted before the Amended

Complaint was filed. This argument is without merit.

As reflected by the docket in this matter, Mr. Blackert was served with the origina

Complaint on November 11, 2011 and after he failed to plead or defend, Xcentric sought

entry of default against him on December 15, 2011. See Doc. #49. The clerk entered Mr

Case 2:11-cv-01426-GMS Document 110 Filed 08/15/12 Page 1 of 12


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Blackerts default on December 16, 2011. See Doc. #50. Eventually, on July 20, 2012

Xcentric moved for the entry of a default judgment against Mr. Blackert. See Doc. #99.

Of course, between the date on which the clerk entered Mr. Blackerts default and

the date Xcentric moved for a default judgment against him, the Court granted, in part,Ms. Borodkins Motion for More Definite Statement. The Courts order (Doc. #52) was

issued on March 1, 2012, and as a result, Xcentric filed its First Amended Complaint on

March 16, 2012 (Doc. #55).

Based on the timing of these events, Ms. Borodkin argues that Xcentric cannot

obtain a default judgment against Mr. Blackert because the Amended Complaint

supersedes the original Complaint, and thus even though Mr. Blackert failed to timely

answer the original Complaint and even though the clerk entered his default several

months before Xcentric was ordered to amend its Complaint, he somehow is entitled to a

new opportunity to respond to the First Amended Complaint. This argument is specious.

When a party fails to timely appear and defend, they have no further right to

participate in the proceeding nor do they have a right to further notice of the plaintiffs

efforts to obtain a default judgment. See Wilson v. Moore & Assoc., Inc., 564 F.2d 366

368 (9th

Cir. 1997) (noting, No party in default is entitled to 55(b)(2) notice unless he

has appeared in the action.) While it is certainly true that an amended pleading may

supersede an existing Complaint, it is also true that an amended pleading relates back to

the date of the original pleading, see Fed. R. Civ. P. 15(c), and Ms. Borodkin cites no

authority for her premise that a defendant whose default has already been entered is

somehow entitled to a renewed right to answer a post-default Amended Complaint in

this context.

This case is therefore not identical to those in Best Western Intl, Inc. v

Melbourne Hotel Investors, LLC, 2007 U.S. Dist. LEXIS 78920 (D.Ariz. 2007). In that

case, the plaintiffs original Complaint requested an award of $130,000 in damages plus

attorneys fees. After the defendant defaulted, the plaintiff amended its pleading to

increase the damages sought from $130,000 to more than $343,000.



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Based on this voluntary amendment, the court denied the plaintiffs request for a

default judgment based on its original Complaint. This decision was based on the fac

that the original Complaint was superseded by the subsequent Amended Complaint

which requested substantially greater relief thus rendering the plaintiffs original defaultmotion moot. This practical result was consistent with the general rule that a defaul

judgment must not differ in kind from, or exceed in amount, what is demanded in the

pleadings.Enterprise Bank & Trust v. Vintage Ranch, Inv., LLC, 2012 WL 1267988*2 (D.Ariz. 2012).

Here, Xcentric did not voluntarily amend its pleading, nor did the relief requested

as to Mr. Blackert change in either amount or kind. Rather, afterMr. Blackert defaulted

Ms. Borodkin prevailed in forcing Xcentric to make minor technical revisions to its

Complaint in order to provide a more definite statement of its claims against her. Of

course, Mr. Blackert never joined in this request, nor could he have done so given that he

had already defaulted. Thus, the minor technical changes in Xcentrics First Amended

Complaint had no impact whatsoever on the relief sought as to Mr. Blackert and this

amendment did not revive his right to participate in the case and should not preclude the

entry of a default judgment as to Mr. Blackert.

b. Ms. Borodkins Appearance Does Not Preclude A Default JudgmentAgainst AEI or Blackert

Although the entry of a judgment against fewer than all defendants is expressly

permitted by Fed. R. Civ. P. 54(b), Ms. Borodkin argues that based on the U.S. Supreme

Courts 140 year-old decision inFrow v. De La Vega, 82 U.S. 552, 21 L.Ed. 60 (1872), a

default judgment would be improper because Xcentric alleges joint and several liability

among the defendants who have defaulted (AEI and Mr. Blackert) and those who have

not (Ms. Borodkin). This argument has no merit.

The rule described in Frow and its progeny is extremely simpleto prevent the

troubling possibility of directly conflicting judgments in the same case, courts will



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generally refrain from entering a default judgment against fewer than all defendants in a

multi-party action where the liability of one defendant is necessarily dependent on the

liability of all defendants; Frow stands for the proposition that when one of several

defendants who is alleged to be jointly liable defaults, judgment should not be enteredagainst that defendant until the matter has been adjudicated with regard to all defendants,

or all defendants have defaulted. Shanghai Automation Instrument Co. Ltd. v. Kuei

194 F.Supp.2d 995, 1006 (N.D.Cal. 2001) (quoting CHARLES ALAN WRIGHT,ARTHURR

MILER & MARY KAY KANE, FEDERAL PRACTICE AND PROCEDURE: CIVIL 3D 2690

(2001) (WRIGHT &MILLER)).

This rule is inapplicable, however, when the facts of the case logically permit one

defendant to be found liable without necessarily requiring the same result as to the

remaining defendants; theFrowprinciple is designed to apply only when it is necessary

that the relief against the defendants be consistent. If that is not the case, then a defaul

against one defendant may stand, even though the remaining defendants are found not

liable. WRIGHT &MILLER2690 (emphasis added); see also In re Uranium Antitrust

Litigation, 617 F.2d 1248, 1258 (7th

Cir. 1980) (noting We think it most unlikely that

Frow retains any force subsequent to the adoption of Rule 54(b) ... and concluding

Frow does not preclude the entry of default judgment against a group of nine defaulters

prior to adjudication on the merits as to the remaining defendants, where liability is joint

and several.) (quotingInternational Controls Corp. v. Vesco, 535 F.2d 742, 74647 n.4

(2nd Cir. 1976));Kuei, 194 F.Supp.2d at 1008 (explaining Frows applicability turns not

on labels such as joint liability or joint and several liability, but rather on the key

question of whether under the theory of the complaint, liability of all the defendants must

be uniform.) (emphasis added).

Measured by this simple standard, it is clear thatFrow does not preclude the entry

of a default judgment against AEI or Mr. Blackert even though Ms. Borodkin has not

defaulted. This is so because Xcentrics claims do not require the liability of all

defendants in order to forany one defendant to face liability.



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Although Xcentrics second and third causes of action (wrongful continuation of

civil proceedings and aiding/abetting) allege that all defendants acted together in a

manner sufficient to create joint and several liability, Xcentrics first cause of action

(wrongful commencementof civil proceedings) is not asserted against Ms. Borodkin anddoes not implicate or require her liability in any way. The first cause of action arises

from a different eventwrongfully commencing the prior California actionand is

asserted against different partiesMr. Blackert and his former clientssuch that there is

nothing necessarily inconsistent about a judgment in favor of Xcentric and against

AEI/Mr. Blackert as to the first cause of action and a judgment in favor of Ms. Borodkin

as to the second and third causes of action.

In other words, it is logically possible for AEI and Mr. Blackert to be found liable

for wrongfully commencing the prior case while Ms. Borodkin is subsequently found not

liable on the second and third causes of action for her conduct after the case began. Even

though Xcentric believes this result is unlikely because the evidence of wrongful conduct

on the part ofalldefendants is overwhelming, it is not mandatory for Ms. Borodkin to be

found liable as a prerequisite for AEI and Mr. Blackert to be liable; a fortiori, the concern

at issue inFrow is simply not present here; when different results as to different parties

are not logically inconsistent or contradictory, the rationale for the Frow rule is lacking

Such is this case involving joint and several liability. In re Uranium Antitrust

Litigation, 617 F.2d at 125758.

c. Defendants Cannot Relitigate Facts From The Prior ActionOn pages 610 of her brief, Ms. Borodkin engages in a lengthy analysis and

discussion of her interpretation of Xcentrics business operations and other issues,

apparently for the purpose of further disparaging Xcentric while simultaneously seeking

to re-litigate the merits of the prior California action in an effort to show probable cause

for her actions. These arguments are perplexing and are largely based on false assertions

which were already raised and rejected in the prior California action. To the extent any

response from Xcentric is required, only a few brief comments are warranted.



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First, Ms. Borodkin does not represent Mr. Blackert or AEI in this matter, so her

arguments defending and advocating their actions are inappropriate. Of course, Ms

Borodkin is certainly free to present any legitimate factual/legal arguments in her own

defense, but Xcentric is not seeking a default judgment against her so these arguments arepremature.

Second, it is clear from reviewing her brief that Ms. Borodkin refuses to accept the

California District Courts determination that her prior allegations, theories and

arguments were groundless, but this is beside the point. Ms. Borodkin cannot relitigate

the merits of the prior California case in this action; When ... the proceedings are civil,

the decision of a competent tribunal is a final adjudication of all matters in dispute.

Therefore, the person who unsuccessfully initiates civil proceedings can not relitigate the

validity of his claim in an action brought for their wrongful initiation. RESTATEMENT

(SECOND) OF TORTS 674.

Third, as explained in Xcentrics separately-filed Response (Doc. #107) to her

Motion to Dismiss, virtually all of the arguments presented by Ms. Borodkin are simply

irrelevant/immaterial because even if true, they do not establish that the claims asserted

against Xcentric in the prior California action were meritorious. For instance, on page 8

of her brief, Ms. Borodkin quotes a lengthy passage fromLevitt v. Yelp! which observed

that certain types of false advertising claims may not be protected under the

Communications Decency Act. Next, Ms. Borodkin argues These claims -- which the

Levittcourt held were not immunized [by the CDA] -- were exactly the ones that were

asserted by the plaintiffs [AEI and Mobrez/Llaneras] in the California Action following

the dismissal of the RICO claim predicated on a pattern of attempted extortion. Resp. at

8:1820. Thus, because the Levittcourt suggested that the CDA might not apply to all

such claims, Ms. Borodkin implies that her decision to prosecute such claims was

arguably supported by probable cause.

This argument is a non sequiturfor one obvious reasonjust because a particular

legal theory might be viable under appropriate facts does not mean that any such facts



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actually existed in the prior California case. Indeed, even assuming arguendo that the

CDA does not bar unfair business practices/unfair competition claims under California

law as Ms. Borodkin now suggests,1 such claims nevertheless require proof that the

plaintiff actually suffered an injury in fact andlost money or property as the result ofthe alleged unlawful conduct. The California court found that Ms. Borodkins clients

failed to offer proof as to both of these mandatory elements:

As an additional ground, Plaintiffs lack standing to sue under the UCL. Tohave standing under Californias UCL, as amended by CaliforniasProposition 64, plaintiffs must establish that they (1) suffered an injury infact and (2) lost money or property as a result of the unfair competition.Plaintiffs have not met their burden in establishing either prerequisite.

Here, any harm suffered stemmed from the reports, which are shielded bythe CDA, not from any of Defendants independent acts. Plaintiffs also failto establish the requisite injury based on Defendants allegedly falsemarketing of themselves as consumer advocates or based onmisrepresentations about the CAP program. Plaintiffs never relied onDefendants statements. They did not become CAP members and had norelationship with any CAP members. As such, Plaintiffs lack standing tosue pursuant to the UCL.

Asia Economic Institute, LLC v. Xcentric Ventures, LLC, 2011 WL 2469822, *8

(C.D.Cal. 2011) (empahsis added) (quoting Birdsong v. Apple, Inc., 590 F.3d 955, 959(9

thCir. 2009)).

During his deposition on May 7, 2010 (which Ms. Borodkin and Mr. Blackert

personally attended) Mr. Mobrez testified that AEI had $0 in revenues and $0 in profits

during nine years in operation. As such, Ms. Borodkin and Mr. Blackert knewwith

absolute certainlythat their clients could not possibly show that they suffered an injury

in fact and lost money or property as the result of the alleged unlawful conduct on the

part of Xcentric as required to establish liability under California law. Despite this, Ms

1 The California District Court rejected this argument and expressly held that the CDAbarred AEI/Mobrez claims under Californias unfair business practices law, Cal. Bus. &Prof. Code 17200; To the degree that Plaintiffs allegations under the UCL stem fromthe posted reports allegedly defaming them, Defendants remain shielded from liability bythe CDA.Asia Economic Institute, LLC v. Xcentric Ventures, LLC, 2011 WL 2469822*8 (C.D.Cal. 2011).



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Borodkin and Mr. Blackert continued prosecuting the RICO and UCL claims for as long

as they possibly could despite knowing they were factually groundless.

As she did throughout the prior California action, Ms. Borodkin continues to

ignore this crucial and dispositive point; she literally pretends the defect does not existUnconcerned about or unwilling to accept the true facts, Ms. Borodkin continues

discussing otherirrelevant issues which eventually result in her mistaken conclusion that

Xcentrics only theory for why the California Action was without probable cause is that

Mobrez and Llaneras were allegedly caught lying about oral conversations with

Magedson. Resp. at 10:35.

This position is simply astonishing given that both Xcentric and the California

District Court have repeatedly explained to Ms. Borodkin that all claims in the prior

action were groundless on multiple levels and for a variety of different reasons. Yes, it

is accurate that the RICO/extortion claims were groundless because Mr. Mobrez and Ms.

Llaneras lied about being extorted, but this was hardly the only flaw in that claim or in

the remainder of the case. The RICO/extortion and RICO/wire fraud claims were also

groundless because such claims require proof of actual injury to the plaintiffs business

or property; to satisfy the damages requirement of a civil RICO claim, a plaintiff must

show that the defendant caused injury to his business or property. Firemans Fund

Ins. Co. v. Stites, 258 F.3d 1016, 1021 (9th Cir. 2001). In the absence of such proof, a

plaintiff has no standing to sue under RICO; Without a harm to a specific business or

property interesta categorical inquiry typically determined by reference to state law

there is no injury to business or property within the meaning of RICO. JM Martinac

Shipbuilding Corp. v. Washington, 2010 WL 325950 (9th Cir. 2010) (citing 18 U.S.C.

1964(c)) (quotingDiaz v. Gates, 420 F.3d 897, 900 (9th

Cir. 2005)).

Again, each defendant in this knew, with absolute certainty, that Xcentric did not

harm AEIs business or property because AEI never conducted any business of any kind

As a result, even if Mr. Mobrez and Ms. Llaneras had not lied about being extorted, their

RICO claims were still completely groundless; [a] defendant who violates [18 U.S.C.]



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section 1962 is not liable for treble damages to everyone he might have injured by other

conduct, nor is the defendant liable to those who have not been injured. Sedima,

S.P.R.L. v. Imrex Company, Inc., 473 U.S. 479, 49697, 105 S.Ct. 3275, 3285 (1985)

(emphasis added) (quotingHaroco, Inc. v. American Natl Bank & Trust Co. of Chicago747 F.2d 384, 398 (7th Cir. 1984), aff'd, 473 U.S. 606, 105 S.Ct. 3291).

Because AEI was never harmed by Xcentrics alleged unfair business practices,

it did not have probable cause to sue Xcentric for numerous/multiple claims which

required proof of actual injury. Thus, Ms. Borodkins gratuitous personal attacks and

grandiose references to patterns of attempted extortion are of no moment; even if her

arguments were correct, they cannot and do not establish merit in the claims which were

already resolved in favor of Xcentric in the prior action. As such, there is no basis to

deny the entry of judgment against the defaulting defendants based on this argument.

d. Comments re: Reasonableness of Attorneys FeesOn pages 1012 of her brief, Ms. Borodkin takes issue with some of the legal fees

which Xcentric seeks to recover. Based on this, Ms. Borodkin argues that a hearing

should be held to to determine which of Xcentrics legal bills were proximately caused

by [the] Defaulting Defendants. Resp. at 12:1415.

Again, Xcentric objects to Ms. Borodkins efforts to represent the interests of

either Mr. Blackert or AEI. Ms. Borodkin is not counsel to these defendants in this

matter, and her efforts to advocate on their behalf is inappropriate. Of course, Ms

Borodkin remains free to raise these arguments to the extent they relate to the amount of

her liability if and when Xcentric finally prevails against her, but now is not the

appropriate time to make those arguments.

As for Ms. Borodkins assertion that some of the fees involved were not

proximately caused by the actions of AEI or Mr. Blackert or that some of the fees were

incurred prior to May 7, 2010 (the date of Mr. Mobrez deposition after which Mr

Blackert would have known his client had lied about the extortion claim), this argument

fails to recognize that it is not Xcentrics burden to apportion damages between any of



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the defendants; the burden of proving such an apportionment must rest with the party

whose malicious conduct created the problem. To place the burden on the injured party

rather than upon the wrongdoer would, in effect, clothe the transgressor with immunity

when, because of the interrelationship of the defense and cross-action, the injured partycould not apportion his damages. Bertero v. National General Corp., 13 Cal.3d 43, 60

529 P.2d 608, 620, 69 Cal.Rptr.3d 561 (Cal. 1974). Of course, because Mr. Blackert and

AEI have defaulted, they have no further right to participate in this action and thus cannot

argue that the Court should apportion damages in the manner suggested by Ms. Borodkin

Finally, Ms. Borodkin objects to two time entries from July 27, 2011 totaling less

than $200 which related to Xcentrics efforts to file a perjury complaint against Mr.

Mobrez and Ms. Llaneras with various federal law enforcement agencies. Ms. Borodkin

apparently disagrees that this cost is recoverable here as it represents time spent afterthe

final judgment was entered in the California action and the work involved was thus not

directly related to the defense of the prior case.

This argument overlooks the relatively broad categories of damages available in a

malicious prosecution case which are notstrictly limited to the legal fees incurred by the

victim; the measure of compensatory damages for the malicious prosecution of a civil

action includes attorney fees and court costs for defending the prior action and

compensation for emotional distress, mental suffering and impairment to reputation

proximately caused by the initiation and prosecution of the action. Bertero, 529 P.3d at

620;see also Davis v. Local Union No. 11 Internat. etc. of Elec. Workers, 16 Cal.App.3d

686, 69596, 94 Cal.Rptr. 562, 568 (Cal. App. 2nd Dist 1971) (noting broad measure of

damages available in malicious prosecution actions; damages may be recovered for loss

of time, deprivation of liberty, * * * injury to fame, reputation, character, * * * * mental

suffering, general impairment of social and mercantile standing, injury to credit, * * *

and all losses sustained to plaintiffs business as the direct and natural result of the

proceedings complained of.)



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While a such de minimus amount does not justify extensive argument or briefing

Xcentrics position is that the costs it incurred in reporting these events to the FBI and

U.S. Attorneys Office were reasonably related to Xcentrics efforts to mitigate the harm

caused to its reputation by the false testimony of Mr. Mobrez and Ms. Llaneras. As suchthese fees are properly recoverable here.

II. CONCLUSIONFor the foregoing reasons, Xcentrics Motion for Default Judgment (Doc. #99)

against Defendants Blackert and AEI should be granted.

DATED August 15, 2012.

GINGRAS LAW OFFICE, PLLC

/S/ David S. GingrasDavid S. GingrasAttorneys for Plaintiff



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CERTIFICATE OF SERVICE

I hereby certify that on August 15, 2012 I electronically transmitted the attached

document to the Clerks Office using the CM/ECF System for filing, and for transmittalof a Notice of Electronic Filing to the following:

John S. Craiger, Esq.David E. Funkhouser III, Esq.

Krystal M. Aspey, Esq.Quarles & Brady LLP

One Renaissance SquareTwo North Central Avenue

Phoenix, Arizona 85004-2391

Attorney for Defendant Lisa J. Borodkin

Raymond MobrezIliana LlanerasPO BOX 3663

Santa Monica, CA 90408DefendantsPro Se

And a courtesy copy of the foregoing delivered to:HONORABLE G. MURRAY SNOW

United States District CourtSandra Day OConnor U.S. Courthouse, Suite 622

401 West Washington Street, SPC 80Phoenix, AZ 85003-215

/s/David S. Gingras


110 - reply re default judgment

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