Braun v. Moser CA4/1

CourtCalifornia Court of Appeal
DecidedDecember 10, 2014
DocketD064630
StatusUnpublished

This text of Braun v. Moser CA4/1 (Braun v. Moser CA4/1) 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
Braun v. Moser CA4/1, (Cal. Ct. App. 2014).

Opinion

Filed 12/10/14 Braun v. Moser CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

CONRAD J. BRAUN, D064630

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2013-00041628- CU-FR-CTL) KENNETH J. MOSER,

Defendant and Respondent.

APPEAL from an order of the Superior Court of San Diego County, John S.

Meyer, Judge. Affirmed in part, reversed in part and remanded with directions.

Conrad J. Braun, in pro. per., for Plaintiff and Appellant.

William Gerald Gillespie for Defendant and Respondent.

Plaintiff and appellant Conrad J. Braun, a self-represented litigant, appeals from a

judgment in favor of defendant and respondent Kenneth J. Moser entered after the trial

court granted Moser's Code of Civil Procedure1 section 425.16 special motion to strike.

1 Statutory references are to the Code of Civil Procedure unless otherwise specified. Section 425.16 is commonly referred to as the anti-SLAPP (Strategic Lawsuit Against Public Participation) statute. (Navellier v. Sletten (2002) 29 Cal.4th 82, 85.) Braun contends the principal thrust or gravamen of his complaint was Moser's non-

litigation-related conduct in advertising Moser's residential telephone number as a

business so as to solicit lawful business calls for the purpose of filing fraudulent claims

and obtaining fraudulent judgments for Telephone Consumer Protection Act (TCPA)

violations.2 We agree with Braun, and conclude that with the exception of Braun's

claims for declaratory and injunctive relief, Moser did not establish that Braun's

complaint arose from protected speech or petitioning under the anti-SLAPP statute.

Because the anti-SLAPP statute does not apply, we need not decide whether Braun

established a probability of prevailing on the merits of those claims. As for Braun's

causes of action for declaratory and injunctive relief, we conclude the trial court correctly

granted Moser's motion. We therefore affirm in part and reverse in part the order

granting the special motion to strike and remand with directions set forth below.

FACTUAL AND PROCEDURAL BACKGROUND

The background facts are taken from the allegations of Braun's complaint, which

we accept as true for purposes of Moser's motion. (Hylton v. Frank E. Rogozienski, Inc.

(2009) 177 Cal.App.4th 1264, 1267, fn. 2.)

2 The TCPA was enacted to " 'protect the privacy interests of residential telephone subscribers by placing restrictions on unsolicited, automated telephone calls . . . by restricting certain uses of facsimile machines and automatic dialers.' " (Satterfield v. Simon & Schuster, Inc. (9th Cir. 2009) 569 F.3d 946, 954; Apple Inc. v. Superior Court (2013) 56 Cal.4th 128, 149.)

2 In May 2008, Moser, doing business as Marketing Support Systems, wrote Braun

demanding that he pay $4,500 for an asserted TCPA violation for calling Moser's

business telephone number. That same month, Moser sued Braun in San Diego County

Small Claims Court, and was awarded $1,000 for claimed TCPA violations. Braun

eventually settled the matter with Moser.

In July 2012, Moser sent additional demand letters to Tax Defense Network and

Debt Care USA, both clients of Braun's company HomeyTel, Inc. In response, Braun

found a Better Business Bureau (BBB) listing that indicated the telephone number

belonged to Moser, dba Marketing Support Systems, from an address at Spica Drive.

Braun informed Moser that commercial business-to-business calls were exempt from the

TCPA right to a private action, and he asked Moser to stop sending demand letters

purporting his business number to be residential. In August 2012, Braun's client Tax

Defense Network told Braun that even though Moser's claim had no merit, it would settle

with Moser for $1,500 rather than risk a nuisance small claims action, and that it would

charge the settlement toward monies owed to Braun.

Thereafter, Moser filed two small claims lawsuits against Braun, HomeyTel, Inc.

and Braun's clients Debt Care USA, Adam Hungerford, and Bill Conley. Moser

dismissed Braun and HomeyTel, Inc. from the suits, but Moser obtained a judgment

against Debt Care USA, Hungerford, and Conley for $5,000 plus court costs. Moser

falsely claimed at a prove-up hearing that the telephone number dialed was his residence

number when in fact it was his business number.

3 Since 2008, Moser has filed numerous TCPA claims in which he pleaded the

telephone number called was his residential telephone number so as to obtain small

claims jurisdiction. He also falsely asserted a private right of action under the TCPA to

inflate demands in extortionate letters and lawsuits. From May 2008 to August 2012,

Moser operated an active business listing with the BBB using a telephone number ending

in 4190, but after August 2012, Moser deliberately changed the BBB listing to a different

phone number to cover up his fraud.

At some point, Moser wrote a letter to Debt Care USA, Hungerford, and Conley

notifying them about the judgments and telling them, "In the future you may not want to

take the jail house legal advice of a convicted felon like Mr. Braun. Especially after he

was stupid enough to call the same personal number he called on your behalf last year, as

he did four years ago which was the subject of the previous judgment!" Braun lost Debt

Care USA as a client.

Braun sued Moser, and in April 2013 filed an amended complaint asserting causes

of action for "loss of business and reputation due to fraud and libel" (first cause of

action), abuse of process (second cause of action), "implied and equitable indemnity"

(third cause of action) injunctive relief (fourth cause of action), and declaratory relief

(fifth cause of action). (Some capitalization omitted.) Braun generally alleged that

Moser conducted a fraudulent scheme to acquire jurisdiction and judgments in California

small claims courts. He alleged Moser had filed a "plethora of fraudulent TCPA claims"

and got away with it because the small claims courts misapplied the TCPA. According to

the complaint, "professional small claims litigants and even a few attorneys have made a

4 business out of extracting money from small business for pre-recorded B2B [business to

business] calls protected under the TCPA, . . . creating a chilling effect against a small

and fledgling legitimate B2B voice broadcasting industry." In his first cause of action,

Braun alleged Moser "began a series of 'demand letters' which were actually extortive

shakedown letters to a client of Plaintiff, by falsely representing telephone business

numbers as residential numbers and a cause of private action under TCPA." He alleged

Moser falsely stated under penalty of perjury that his home number was a business

number. In his second cause of action for abuse of process, Braun alleged Moser made

his false claim in small claims proceedings to gain judgments through fraud. In his third

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