Motion to amend judgment to add judgment debtors
impact Plaintiff’s statutory right to recover prevailing party costs under Code of Civil Procedure sections 1032 and 1033.5, and a memorandum of costs. This ruling is limited to this motion and the request to recover attorney fees and expenses pursuant to the partition statutes. Plaintiff’s counsel is ordered to give notice of this ruling.
10. Bryan Cave Leighton Paisner LLP vs. Napster Corporation 2026-01548951 OFF CALENDAR based on notice of withdrawal filed on May 21, 2026.
11. Domaoal vs. Caring Moments, Inc. 2019-01104318 Before the court is the motion of judgment creditor Alicia Domaoal (Domaoal) to amend the judgment to add Joan Christine Sangrones Botin A/K/A Joan Christine Botin (Botin) and Immanuel Care Home LLC (Immanuel). As more fully set forth below, the motion is DENIED WITHOUT PREJUDICE.
Judgment was entered in this action in October 2019 on the request of the California Labor Commissioner following administrative proceedings before the Labor Commissioner regarding the failure to pay wages. The Labor Commissioner awarded Domaoal $73,631.26 in unpaid wages, damages, interest, penalties, and costs as against Caring Moments, Inc, a suspended California corporation.
By this motion, Domaoal seeks to amend that judgment to add Botin and Immanuel as judgment debtors pursuant to Labor Code sections 200.3, subdivision (a), 238, subdivision (e), and 558.1, subdivision (a). Botin and Immanuel are not parties to the judgment. Domaoal, however, has only served this motion on Botin and Immanuel by mail, and has failed to show merely mailing copies of this motion to Botin and Immanuel at multiple unexplained addresses is sufficient to provide a basis for the court to exercise personal jurisdiction over these nonparties.
When a party seeks to amend a judgment to at a nonparty as an alter ego of a judgment debtor, the court must have jurisdiction over the judgment debtor’s alter ego in order to enter a valid judgment against the alter ego, and that is normally accomplished by service of process. (See Milrot v. Stamper Med. Corp. (1996) 44 Cal.App.4th 182, 186.)
The court recognizes this is not a motion to amend the judgment to add an alter ego in the traditional sense, but rather a motion to amend under the foregoing Labor Code provisions. Nonetheless, Domaoal has not presented any authority to show the same due process requirements do not apply here. Indeed, Domaoal has not shown the court may add a nonparty as a judgment debtor without the nonparty being served in a sufficient manner to confer jurisdiction over the nonparty. Based on the foregoing, the motion is DENIED WITHOUT PREJUDICE. Domaoal’s counsel is ordered to give notice of this motion.
12. Santos vs. Crenshaw Manufacturing Inc. 2025-01488879- Before the court is the motion of judgment creditor Marivel Santos (Santos) to amend judgment pursuant to Code of Civil Procedure section 187. As more fully set forth below the motion is DENIED WITHOUT PREJUDICE.
On July 14, 2023, Santos obtained an award from the Workers’ Compensation Appeals Board of the State of California against judgment debtor Crenshaw Manufacturing Inc. (Crenshaw) in the amount of $194,356.55 arising out of an injury Santos sustained while working for Crenshaw.
On June 3, 2025, Santos filed these proceedings and obtained a judgment against Crenshaw based on the Appeal Board award. By this motion, Santos seeks to amend that judgment to add nonparty Waleed Mansour (Mansour) as a judgment debtor on the ground Mansour is an alter ego of Crenshaw.
Code of Civil Procedure section 187 provides, “When jurisdiction is, by the Constitution or this Code, or by any other statute, conferred on a Court or judicial officer, all the means necessary to carry it into effect are also given; and in the exercise of this jurisdiction, if the course of proceeding be not specifically pointed out by this Code or the statute, any suitable process or mode of proceeding may be adopted which may appear most conformable to the spirit of this Code. “The authority provided to courts by section 187 includes the power to add a judgment debtor where a person or entity is an alter ego of the original judgment debtor.” (Butler America, LLC v. Aviation Assurance Co., LLC (2020) 55 Cal.App.5th 136, 145.) “‘Amending a judgment to add an alter ego of an original judgment debtor “‘is an equitable procedure based on the theory that the court is not amending the judgment to add a new defendant but is merely inserting the correct name of the real defendant.’”’”
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