Motion to Claim Exemption in U.S. BANK NATIONAL ASSOCIATION vs I.G. DIEGO ENGINE & TRANSMISSION REBUILDERS| Trellis.Law

On March 01, 2020 a Complaint,Petition was filed involving a dispute between U.S. Bank National Association, and I.G. Diego Engine & Transmission Rebuilders, Leonardo Diego, for Unlimited Civil Other Contract in the District Court of Riverside County.

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1 Sarah A. Cuellar, Esq. (SBN 320908)
Goldfein & Associates, P.C.
2 2447 Pacific Coast Hwy, Suite 200
Hermosa Beach, CA,90254
3 Sarah.Cuellar@goldfeinclaims.com
TEL.: (470) 610-0886
4
Attorney for Plaintiff
5

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF RIVERSIDE
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10
Hermosa Beach, CA, 90254

11 U.S. BANK NATIONAL ASSOCIATION, a Case No.:
Delaware Corporation,
12 COMPLAINT FOR:
vs.
13 (1) CLAIM AND DELIVERY
I.G. DIEGO ENGINE & TRANSMISSION (2) VIOLATION OF CIVIL CODE §3068
14 REBUILDERS, a corporation; LEONARDO (3) VIOLATION OF VEH. CODE §10652.5
DIEGO, individually; Does 1-10, inclusive (4) VIOLATION OF CIVIL CODE §3071
15 (5) CONVERSION
Defendants. (6) VIOLATION OF VEH. CODE §22651.07
16
DEMAND AMOUNT: $37,000
17

20 NOW COMES, Plaintiff, U.S. BANK NATIONAL ASSOCIATION (“US Bank” or

21 “Plaintiff”) and complains and alleges as follows:

22 I. THE PARTIES

23 1. Plaintiff is, and at all times herein mentioned, was authorized to do business in the State of

24 California.

25 2. Plaintiff is informed and believes upon such information and belief alleges that Defendant

26 I.G. Diego Engine & Transmission Rebuilders (“IG Diego”), is a corporation, incorporated in

27 California, and that the Defendant maintains an office in Riverside County.

28 3. Plaintiff is informed and believes upon such information and belief alleges that Defendant
1
COMPLAINT
1 Leonardo Diego (hereinafter “Diego”) is a natural person and the C.E.O of I.G. Diego

2 4. The true identities and capacities of Defendant Does 1 through 10, inclusive, are unknown to

3 Plaintiff. Plaintiff will seek leave to amend this Complaint when the same has been ascertained.

4 II. ALTAR EGO ALLEGATIONS

5 5. At all relevant times, as alleged more fully herein, each Defendant acted as an agent, servant,

6 employee, co-conspirator, alter-ego and/or joint venturer of the other Defendants, and in doing the

7 things alleged herein acted within the course and scope of such agency, employment, alter-ego and/or

8 in furtherance of the joint venture. Each of the Defendant’s acts alleged herein was done with the

9 permission and consent of each of the other Defendants.
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 6. At all times relevant thereto, Defendant IG Diego was not only influenced
Hermosa Beach, CA, 90254

11 and governed by Defendant Leonardo Diego, but there was such a unity of interest and ownership that

12 the individuality, or separateness, of Defendant Leonardo Diego and Defendant IG Diego has ceased,

13 and that the facts are such that an adherence to the fiction of the separate existence of these entities

14 would, under the particular circumstances promote injustice.

15 7. Specifically, at all times relevant hereto, Defendant Leonardo Diego (1) controlled the

16 business and affairs of Defendant IG Digo, including any and all of their affiliates; (2) comingled the

17 funds and assets of the corporate entities, and diverted corporate funds and assets for his own personal

18 use (3)disregarded legal formalities and failed to maintain arm’s length relationships among the

19 corporate entities; (4) inadequately capitalized IG Diego; (5) used the same office or business location

20 and employed the same employees for all the corporate entities; (6) held herself out as personally

21 liable for the debts of the corporate entities; (7) used the corporate entities as mere shells,

22 instrumentalities or conduits for himself and/or his individual business; (8) used the corporate entities

23 to procure labor, services or merchandise for another person or entities; (9) manipulated the assets

24 liabilities between the corporate entities so as to concentrate the assets in one and the liabilities in

25 another; (10) used corporate entitles to conceal their ownership, management and financial interests

26 and/or personal business activities; and/or (11) used the corporate entities to shield against personal

27 obligations, and in particular the obligations as alleged in this Complaint.

28 8. Plaintiff is informed and believes and, upon such information and belief, alleges that each of
2
COMPLAINT
1 the Defendants named herein as Does 1 through 10, inclusive, were and are in some manner

2 responsible for the actions, acts and omissions herein alleged, and for the damage caused by the

3 Defendants, and are, therefore, jointly and severally liable for the damages caused to Plaintiff.

4 II. JURISDICTION AND VENUE

5 9. Jurisdiction and venue are proper in Riverside County because Defendant IG Diego

6 has its place of business at 5850 Griffith Street, Riverside, CA, 92504.

7 10. Plaintiff is informed and believes and thereon alleges that the vehicle which is the subject of

8 this action is currently stored at the aforementioned location.

9 III. GENERAL ALLEGATIONS
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 11. This action involves the alleged repair and storage of a 2014 Chevrolet Corvette with VIN No.
Hermosa Beach, CA, 90254

11 1G1YM3D76E5122641 (“Vehicle”) which Defendants are attempting to sell via lien sale.

12 12. At all relevant times, Plaintiff was listed on title as the legal owner of the Vehicle.

13 13. Two alleged lienholders have attempted to sell the Vehicle since 2020. The basis of this

14 lawsuit involves the second attempted lien sale initiated by Defendant IG Diego.

15 A. First Lien Sale

16 14. On or about July 1, 2020, a lien sale was initiated by an individual lien holder named Derrick

17 Lee Hinton (“Mr. Hinton”). Mr. Hinton thereafter notified Plaintiff of the lien sale through his lien

18 sale agent, Noustar Lien Sale Services. Exhibit “1”

19 15. Plaintiff, through counsel, contacted Mr. Hinton and negotiated a settlement to recover the

20 Vehicle.

21 16. Mr. Hinton informed Plaintiff, however, that the Vehicle was located at Plaintiff’s repair

22 facility located at 5850 Griffith Street, Riverside, CA, 92504.

23 17. At the time Mr. Hinton informed Plaintiff of the Vehicle’s location, it was unaware that the

24 Vehicle was located at 5850 Griffith Street, Riverside, CA, 92504.

25 B. Second Lien Sale

26 18. After Mr. Hinton informed Plaintiff of the Vehicle’s most recent location, Plaintiff attempted

27 to secure the Vehicle from Defendant’s repair facility. However, Defendants informed Plaintiff that

28 the Vehicle would not be released unless Plaintiff paid $15,703.55. Exhibit “2”
3
COMPLAINT
1 19. Defendants demanded payment be made “By Direct Deposit Only to Business Bank Account”

2 Exhibit “2”

3 20. Plaintiff is informed and believes and, upon such information and belief, alleges that

4 Defendants came into possession of the Vehicle on or about October 2020.

5 21. Plaintiff is informed and believes and, upon such information and belief, alleges that

6 Defendants completed the alleged repair work on February 16, 2021

7 22. Plaintiff is informed and believes and, upon such information and belief, alleges that

8 Defendants began a second lien sale application in October 2021, 8 months after having allegedly

9 completed the repair work on the Vehicle.
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 23. Defendants allege that the registered owner was provided “numerous months” to recover
Hermosa Beach, CA, 90254

11 the Vehicle, but failed to do so. Exhibit “2”

12 24. At the time of filing this complaint, it is unknown if Defendants mailed any notice to Plaintiff

13 according to statute.

14 25. On October 15, 2021, Plaintiff, through counsel, explicitly cited CA Civil Code §3068 via

15 email and informed Defendants of the statutory maximums. Exhibit “3”

16 26. In good faith, Plaintiff, through counsel, offered $2,525 to Defendants to release the Vehicle.

17 However, Defendants rejected Plaintiff’s good faith offer.

18 27. Plaintiff is informed and believes and thereon alleges that the vehicle has a rough trade

19 in value of approximately $31,500 according to a National Automobile Dealers Association

20 (“NADA”) evaluation. Exhibit “4”

21 II. FIRST CAUSE OF ACTION
22 (Claim and Delivery against All Defendants)
23 28. Plaintiff incorporates by reference the prior paragraphs and allegations as though
24 fully set forth herein.
25 29. Plaintiff is informed and believes, and thereon alleges that Defendant came into possession of
26 the vehicle in October 2020.
27 30. As the legal owner, Plaintiff is entitled to immediate possession of the Vehicle; however, the
28
4
COMPLAINT
1 Vehicle is still in Defendant’s control and it is believed the Defendant is in possession of the Vehicle.

2 31. Plaintiff is informed and believes and thereon alleges that Defendant seeks storage fees in

3 excess of the statutory maximums outlined in Civil Code section 3068 and continues refusing

4 Plaintiff’s demand to release the Vehicle. As a result, Defendant is not entitled to protections provided

5 under Civil Code section 3068.

6 32. Plaintiff is informed and believes and thereon alleges that Defendant violated Veh. Code

7 10652.5 and thus, any potential lien is void in accordance with Civ. Code §3071(l).

8 33. Prior to commencement of this action, Plaintiff demanded that Defendant return the Vehicle to

9 Plaintiff. However, Defendant refused, and continues to refuse to return the Vehicle. Plaintiff is
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 entitled to immediate possession of the vehicle.
Hermosa Beach, CA, 90254

11 34. Defendants’ behavior demonstrates a clear disregard of California Civil Code §3068 as

12 well as in addition, the stated remedy found in Civil Code §3068(d).

13 35. Based on Defendants behavior, Plaintiff has been deprived ownership of the Vehicle and

14 has been harmed by Defendants’ conduct.

15 36. Plaintiff brings this action seeking to gain recovery of no less than $31,500 if possession

16 of the Vehicle cannot be had.

17 37. Plaintiff seeks attorney’s fees in the amount of $1,750 in accordance with Civil

18 Code§3068(d).

19 III. SECOND CAUSE OF ACTION

20 (Violations of Civil Code §3068 Against All Defendants)

21 38. Plaintiff incorporates by reference the prior paragraphs and allegations as though

22 fully set forth herein.

23 39. Civil Code §3068(b)(1) further provides “Any lien under this section that arises because

24 work or services have been performed on a vehicle with the consent of the registered owner shall be

25 extinguished and no lien sale shall be conducted unless either of the following occurs:

26 (A) The lienholder applies for an authorization to conduct a lien sale within 30 days after the lien has

27 arisen.

28 (B)An action in court is filed within 30 days after the lien has arisen.
5
COMPLAINT
1 40. According to Civil Code §3068, Defendants’ lien arose at the time a written statement of

2 charges for completed work or services is presented to the registered owner OR 15 days after the work

3 or services are completed, whichever occurs first.

4 41. Defendants allege that it provided the registered owner with “numerous months” to pay and

5 recover the Vehicle. However, the registered owner failed to secure the Vehicle. Thus, Defendants

6 could not have applied for a lien sale 30 days after the lien “arose” since they provided the registered

7 owner with “numerous months” to issue payment for repairs and storage.

8 42. Additionally, Defendants failed to apply for the lien sale 30 days after the lien “arose” because

9 the serves were completed on February 16, 2021, but Defendants did not initiate the lien sale until 8
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 months later in October 2021.
Hermosa Beach, CA, 90254

11 43. Thus, the entirety of Defendants’ lien is extinguished since it failed to apply for a lien sale

12 within 30 days of its lien having arisen.

13 44. Despite said extinguishment, Plaintiff attempted to negotiate release of the Vehicle, but

14 Defendants rejected Plaintiff’s offer.

15 45. Second, Civil Code §3068(c), places various limits on the amount a person or entity is entitled

16 recover from a legal owner.

17 46. A lienholder shall not charge a legal owner in excess of $1,500.00, for work or services

18 performed, subject to limitations set forth in Vehicle Code §10652.5.

19 47. Here, DMV records indicate that Plaintiff is the legal owner of the Vehicle. However,

20 Defendant failed to provide notice to Plaintiff in accordance with Vehicle Code §10652.5.5. Thus,

21 Defendant cannot recover $1,500 from Plaintiff under Civil Code §3068.

22 48. In good faith, Plaintiff offered Defendants $1500 for services rendered, however, Defendants

23 rejected Plaintiff’s offer.

24 49. Civil Code §3068(c) also provides that a lienholder may not charge a legal owner in excess

25 of $1,025.00, if application for authorization to conduct a lien sale pursuant to Civil Code §3071 has

26 been filed with the DMV within 30 days of commencing storage.

27 50. Defendant commenced storage of the Vehicle in October 2020 and failed to apply

28 for a lien sale application within 30 days of possession. Thus, Defendant cannot recover $1,025.00
6
COMPLAINT
1 from Plaintiff.

2 51. Again, despite the extinguishment, Plaintiff offered Defendants $1,025 for storage in good

3 faith. However, Defendants rejected Plaintiff’s offer.

4 52. Lastly, Civil Code §3068(c) provides that a lienholder shall not charge a legal owner in excess

5 of $1,250.00, unless prior to commencing any work or storage the person claiming the lien gave actual

6 notice in writing by personal service or registered letter addressed to the legal owner named in the

7 registration certificate and obtained the written consent of the legal owned by performing any work.

8 53. Instead of following the proper procedure according to Civil Code §3068(c) Defendant

9 did not secure written consent of the legal owner (Plaintiff) prior to commencing storage. Therefore,
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 Defendant is not entitled to $1,250.
Hermosa Beach, CA, 90254

11 54. Plaintiff has been damaged as a result of Defendant’s violation of Civil Code §3068, and any

12 lien that Defendant may have had is extinguished and no lien sale shall be conducted.

13 55. Defendant has refused to turn over to Plaintiff the Vehicle and its refusal to permit

14 peaceable repossession of the Vehicle demonstrates a clear disregard of California Civil Code §3068

15 as well as in addition the stated remedy found in Civil Code §3068(d).

16 IV. THIRD CAUSE OF ACTION

17 (Violations of Veh. Code §10652.5 Against All Defendants)

18 56. Plaintiff incorporates by reference the prior paragraphs and allegations as though fully set

19 forth herein.

20 57. Per Vehicle Code §10652.5, whenever the name and address of the legal owner of a vehicle

21 may be ascertained from the registration records of from the DMV records, no fee or service change

22 may be imposed upon a legal owner for storage except for the first 15 days of possession and

23 following that 15-day period, the period starting three days after written notice by the person in

24 possession is sent to the legal owner, by certified mail, return receipt requested, and continuing for a

25 period not exceeding the time limit set forth in Civil Code section 3068 or 3068.1

26 58. Plaintiff’s information may be ascertained from DMV records since it is the designated legal

27 owner. Defendant failed to provide written notice to Plaintiff under Vehicle Code §10652.5, then

28 continued to demand thousands in storage fees, in excess of the period permitted under Vehicle Code
7
COMPLAINT
1 §10652.5.

2 59. Defendants came into possession of the Vehicle in October 2020, but failed to provide Plaintiff

3 with appropriate notice and instead demanded Plaintiff pay $15,703.55.

4 60. At the time Mr. Hinton informed Plaintiff of the Vehicle’s location, it was unaware

5 that the Vehicle was located at 5850 Griffith Street, Riverside, CA, 92504.

6 61. Plaintiff has been damaged because of Defendant’s violation of Vehicle Code §10652.5 & is

7 entitled to attorney’s fees in the amount of $1750 for violation of Veh. Code §10652.5

8 62. Furthermore, Defendants’ failure to comply with Vehicle Code §10652.5 causes Defendants to

9 be liable to Plaintiff for the cost of removal, transportation, and storage, damages resulting from the
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 towing, removal, transportation, or storage of the vehicle, attorneys’ fees, and court costs in
Hermosa Beach, CA, 90254

11 accordance with Civil Code 3070(d)(1).

12 V. FOURTH CAUSE OF ACTION

13 (Violations of Civil Code §3071 Against All Defendants)

14 63. Plaintiff incorporates by reference the prior paragraphs and allegations as though fully set

15 forth herein.

16 64. According to Civ. Code §3071(l), “Any lien sale pursuant to this section shall be void if the

17 lienholder does not comply with this chapter. Any lien for fees or storage charges for parking

18 and storage of a motor vehicle shall be subject to Section 10652.5 of the Vehicle Code.”

19 65. On information and belief, Defendant failed to properly follow the procedure as directed in

20 Vehicle Code Section 10652.5 and thus, any potential lien is void in accordance with Civ. Code

21 §3071(l).

22 VI. FIFTH CAUSE OF ACTION

23 (Conversion against All Defendants)

24 66. Plaintiff incorporates by reference the prior paragraphs and allegations as though

25 fully set forth herein.

26 67. Plaintiff is informed and believes and based upon such information and belief,

27 alleges that Defendants and Does 1 through 10, prior to the commencement of this action, excised

28 control, secreted or otherwise converted the Vehicle for their own use.
8
COMPLAINT
1 68. Additionally, based on Defendants’ refusal to release Plaintiff’s Vehicle,

2 Plaintiff has been damaged and seeks immediate recovery of the vehicle, and attorney’s fees of no less

3 than $5,000.

4 69. Due to the conversion of the Vehicle by Defendants and Does 1 through 10, Plaintiff is

5 entitled to conversion damages in a sum equal to $31,500 if possession of the Vehicle cannot be had.

6 70. Said conduct of Defendants and Does 1 through 10, was and is tortious, malicious,

7 outrageous, oppressive, fraudulent, made in bad faith, and in conscious disregard for the rights of

8 Plaintiff. Therefore, in addition to general and compensatory damages, Plaintiff prays for punitive

9 damages according to proof.
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 71. Plaintiff contends that any alleged lien claimed by Defendant is invalid as it failed to follow
Hermosa Beach, CA, 90254

11 the proper procedure according to Civil Code §3068.

12 72. Due to Defendant’s refusal to surrender the Vehicle to Plaintiff, it is withholding and

13 converting the Vehicle for its own use.

14 IV. SIXTH CAUSE OF ACTION

15 (Violation of Veh. Code §22651.07 All Defendants)

16 73. Plaintiff incorporates by reference the prior paragraphs and allegations as though

17 fully set forth herein.

18 74. Cal Veh Code §22651.07 specifically outlines the duties of persons charging for

19 towing or storage and the rights of vehicles owners or agents.

20 75. Cal Veh Code §22651.07(c) is explicit, “Prior to paying any towing, recovery, or storage

21 related fees, a vehicle owner or his or her agent or a licensed reposssessor shall, at any facility where

22 the vehicle is being stored, have the right to all of the following: […] Be permitted to pay by cash,

23 insurer’s check, or a valid bank credit card […].

24 76. A person who violates this section is civilly liable to a registered or legal owner of the vehicle,

25 or a registered owner’s insurer, for up to two times the amount charged. Liability in any action

26 brought under this section shall not exceed five hundred dollars ($500) per Vehicle. Cal Veh Code

27 §22651.07(k).

28 77. Here, Defendant issued a demand to Plaintiff which required Plaintiff to make payment, “By
9
COMPLAINT
1 Direct Deposit Only to Business Bank Account”

2 78. On information and belief, Defendant failed to properly follow the procedure as directed in

3 Vehicle Code Section 22651.07(c)(5) and thus, is entitled to $500 per Vehicle. Cal Veh Code

4 §22651.07(k).

5 VII. PRAYER FOR RELIEF

6 WHEREFORE, Plaintiff prays for relief as follows:

7 1. For a determination of the extinguishment of any lien advanced by Defendants.

8 2. For an order and judgment returning possession of the Vehicle to Plaintiff peaceably.

9 3. For a preliminary injunction prohibiting Defendants from removing the
2447 Pacific Coast Hwy, Suite 200
Goldfein & Associates, P.C.

10 Vehicle from its business location and prohibiting the sale, transfer, renting, or leasing the Vehicle
Hermosa Beach, CA, 90254

11 until this Court makes a final determination regarding the possession of the Vehicle.

12 4. For a judgment declaring that Defendants have violated the code sections listed

13 in this complaint.

14 5. For cost of removal, transportation, and storage, damages resulting from the towing, removal,

15 transportation, or storage of the vehicle, attorneys’ fees, and court costs in accordance with Civil Code

16 3070(d)(1).

17 6. For attorney’s fees in the amount of $1750 for violation of Veh. Code §10652.5.

18 7. For attorneys’ fees in the amount of $1750 for violation of California Civil Code §3068

19 8. For additional attorney’s fees in the amount of $1500 in accordance with Civil Code

20 3070(d)(1).

21 9. For $500 in accordance with Vehicle. Cal Veh Code §22651.07(k).

22 10. For damages in the amount of $31,500 if possession of the Vehicle cannot be had.

24 Respectfully submitted on this 25 day of March 2022 by:
Goldfein & Associates, P.C.
25

26
By:______________________
27 Sarah A. Cuellar, Esq.
Attorney for Plaintiff
28
10
COMPLAINT
EXHIBIT 1
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Case Info

Judge

Irma Poole Asberry Track Judge’s New Case

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Document Filed Date

April 12, 2022

Case Filing Date

March 01, 2020

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Complaint,Petition: U.S. BANK NATIONAL ASSOCIATION vs I.G. DIEGO ENGINE & TRANSMISSION REBUILDERS

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