American First Credit Union v. Platinum Properties Investment Network CA4/3

CourtCalifornia Court of Appeal
DecidedApril 23, 2026
DocketG064901N
StatusUnpublished

This text of American First Credit Union v. Platinum Properties Investment Network CA4/3 (American First Credit Union v. Platinum Properties Investment Network CA4/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American First Credit Union v. Platinum Properties Investment Network CA4/3, (Cal. Ct. App. 2026).

Opinion

Filed 4/23/26 American First Credit Union v. Platinum Properties Investment Network CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

AMERICAN FIRST CREDIT UNION, G064901 Plaintiff and Respondent, (Super. Ct. No. 30-2022- v. 01255653)

PLATINUM PROPERTIES ORDER MODIFYING INVESTOR NETWORK, INC., et al., OPINION AND DENYING PETITION FOR REHEARING; Defendants and Appellants. NO CHANGE IN JUDGMENT

It is ordered that the opinion filed on March 24, 2026, be modified as follows: 1. On page 16, first incomplete paragraph, after last sentence that ends in “we do not address the legal merits of its argument,” add the following footnote:

In a rehearing petition, Platinum Entities claim that none of the appellate briefs discussed the theory that they made an “alleged tacit admission of ROI’s claim.” They contend rehearing is required under Government Code section 68081, so they can brief this theory. However, there is no “right under [Government Code] section 68081 to . . . be granted a rehearing each time an appellate court relies upon authority or employs a mode of analysis that was not briefed by the parties. The parties need only have been given an opportunity to brief the issue decided by the court, and the fact that a party does not address an issue, mode of analysis, or authority that is raised or fairly included within the issues raised does not implicate the protections of section 68081.” (People v. Alice (2007) 41 Cal.4th 668, 679, italics added.) The theory highlighted by Platinum Entities was fairly included within the issues raised by their opening brief. For example, they argued “[Platinum] LLC was the only party with a present possessory right to the interpleaded funds at the time this action was commenced.” (Italics added.) Evaluating this argument required analyzing whether ROI had a present claim to the levied funds. This modification does not change the judgment. The petition for rehearing is DENIED.

MOORE, J.

WE CONCUR:

MOTOIKE, ACTING P. J.

SANCHEZ, J.

2 Filed 4/1/26 American First Credit Union v. Platinum Properties Investment Network CA4/3

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

AMERICAN FIRST CREDIT UNION, G064901 Plaintiff and Respondent, (Super. Ct. No. 30-2022- v. 01255653)

PLATINUM PROPERTIES ORDER MODIFYING INVESTOR NETWORK, INC., et al., OPINION; NO CHANGE IN JUDGMENT Defendants and Appellants.

It is ordered that the opinion filed on March 24, 2026, be modified as follows: 1. On page 1, delete “(Super. Ct. No. 30-2022- 01255635)” and replace with “(Super. Ct. No. 30-2022- 01255653)” in its place. This modification does not change the judgment.

2 Filed 3/24/26 American First Credit Union v. Platinum Properties Investor Network CA4/3 (unmodified opinion)

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

AMERICAN FIRST CREDIT UNION, G064901 Plaintiff and Respondent, (Super. Ct. No. 30-2022- v. 01255635)

PLATINUM PROPERTIES OPINION INVESTOR NETWORK, INC., et al.,

Defendants and Appellants.

Appeal from orders of the Superior Court of Orange County, Michael J. Strickroth, Judge. Affirmed. Diefenbach Law Group and James C. Diefenbach for Defendants and Appellants. No appearance for Plaintiff and Respondent. * * * This appeal challenges the trial court’s orders (1) finding that plaintiff credit union had the right to file this interpleader action, (2) discharging the credit union from this proceeding, and (3) awarding the credit union attorney fees. It arises from a $233,498.54 judgment that defendants ROI Property Group Management, LLC and ROI Property Group 2, LLC (collectively, ROI) obtained against defendant Platinum Properties Investor Network, Inc. (Platinum Inc.), which is a subsidiary of defendant Platinum Properties Investor Network, LLC (Platinum LLC). Both Platinum Inc. and Platinum LLC are run by Jason Hartman. ROI sought to levy one of Platinum Inc.’s bank accounts at plaintiff American First Credit Union (American First). American First withdrew $233,498.54 (plus a $40 writ fee) from the account of Platinum LLC rather than Platinum Inc. Hartman discovered this error and then engaged in two contradictory actions. He demanded that American First return the levied funds to Platinum LLC’s account. American First then reached out to ROI to facilitate return of the levied funds. However, ROI provided American First with proof that Hartman had told ROI to apply the levied funds to satisfy the judgment ROI had against Platinum Inc. In other words, Hartman wanted to have his cake and eat it too: he sought to allow ROI to keep the levied funds in satisfaction of Platinum Inc.’s judgment debt while demanding that American First reimburse Platinum LLC for the amounts taken. Despite the confusion, American First asked ROI to return the levied funds, but ROI asserted the levy was proper because Platinum Inc. was either the alter ego of Platinum LLC or had fraudulently conveyed the funds to Platinum LLC to avoid paying the judgment. ROI only agreed to return the levied funds to American First if it filed this interpleader action.

2 American First agreed and filed this action after receiving the funds from ROI. In this appeal, Platinum Inc. and Platinum LLC (collectively, Platinum Entities) primarily argue the trial court incorrectly ruled that American First was entitled to file this interpleader action. The thrust of their argument is that the levied funds clearly belonged to Platinum LLC, and American First should have returned them rather than forcing Platinum Entities into this litigation. However, this argument overlooks Hartman’s role in creating confusion over the funds’ ownership by both seeking their return and having them credited to the judgment against Platinum Inc. As another court has opined, “in litigation as in life, you can’t have your cake and eat it too.” (Guess?, Inc. v. Superior Court (2000) 79 Cal.App.4th 553, 555.) Platinum Entities also contend the trial court erred by denying them a full evidentiary hearing on American First’s right to interplead. However, they have not cited any authority showing they were entitled to such a hearing. Nor have they shown any prejudice from the alleged error. Finally, Platinum Entities claim that the trial court erred by discharging American First from this action and awarding it attorney fees. They claim the relevant statutes do not allow for a plaintiff to be discharged and awarded fees. We disagree. Existing case law has rejected Platinum Entities’ argument, and they have failed to adequately explain why this case law is incorrect. For these reasons, we affirm the relevant orders.

3 FACTS AND PROCEDURAL HISTORY I. LEGAL BACKGROUND “When a person may be subject to conflicting claims for money or property, the person [(known as a stakeholder)] may bring an interpleader action to compel the claimants to litigate their claims among themselves.

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American First Credit Union v. Platinum Properties Investment Network CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-first-credit-union-v-platinum-properties-investment-network-ca43-calctapp-2026.