Diabetes Research Restitution v. Katz CA4/1

CourtCalifornia Court of Appeal
DecidedFebruary 11, 2014
DocketD062586
StatusUnpublished

This text of Diabetes Research Restitution v. Katz CA4/1 (Diabetes Research Restitution v. Katz 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
Diabetes Research Restitution v. Katz CA4/1, (Cal. Ct. App. 2014).

Opinion

Filed 2/11/14 Diabetes Research Restitution v. Katz CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

DIABETES RESEARCH RESTITUTION, D062586 LLC,

Plaintiff and Respondent, (Super. Ct. No. v. 37-2012-00090260-CU-BT-CTL)

RONALD KATZ et al.,

Defendants and Appellants.

APPEAL from an order of the Superior Court of San Diego County, Steven R.

Denton, Judge. Affirmed.

Wachtel Masyr & Missry, Elliot Silverman for Defendants and Appellants SMR

Trust III, Katz, Wachtel, EuroAmerican Investment Corporation, Knobel, Knobel

Children's Trust and Levine.

Sandler, Lasry, Laube, Byer & Valdez, Jeffrey M. Byer; Baker Donelson Bearman

Caldwell & Berkowitz and William Edward Routt for Defendants and Apellants First

Tennessee Brokerage, Inc. and McConkey. Keker & Van Nest, Susan J. Harriman for Defendant and Appellant Hagenbuch.

Klinedinst, PC, Robert Joseph Hatem, G. Dale Britton, and Gregory A. Garbacz

for Defendants and Appellants Anderson, Hoffman, Conn and Frankel.

Edleson & Rezzo, L.B. Chip Edleson and Joan Rezzo; Reynolds APC, Paul

Anthony Reynolds for Plaintiff and Respondent.

I.

INTRODUCTION

After acquiring the litigation claims of a former biotech company called

MicroIslet, Inc. (MicroIslet), Diabetes Research Restitution, LLC (DRR) brought this

action against several individuals who were formerly associated with MicroIslet. In its

complaint, DRR brought a claim for breach of fiduciary duty against a group of former

MicroIslet directors and officers and a claim for aiding and abetting breach of fiduciary

duty against a number of the company's former creditors and brokers. Both claims were

based on allegations that defendants pursued a scheme to acquire MicroIslet by providing

debt financing to the company on unfavorable terms, intending that the debt financing

would subsequently go into default and be converted to equity interests. DRR claimed

that the alleged scheme "caused MicroIslet's collapse and bankruptcy" and that, as a

result of defendant's conduct, MicroIslet "lost all value and assets."

2 Appellants filed a special motion to strike1 pursuant to the anti-SLAPP statute

(Code Civ. Proc., § 425.16)2 in which they contended that DRR's claims arose from

MicroIslet's filing of a petition for bankruptcy—an activity that is protected by the anti-

SLAPP statute. DRR opposed the motion on several grounds, including that its claims

did not arise from MicroIslet's filing of a bankruptcy petition, but rather, from defendants'

"layering [of MicroIslet's] balance sheet with toxic insider debt . . . in an ill-fated attempt

to take over the company . . . ." DRR further contended that references in the complaint

to MicroIslet's bankruptcy were merely incidental to, and not the gravamen of, DRR's

claims.

The trial court denied the motion on the ground that DRR's claims did not arise

from MicroIslet's filing a bankruptcy petition, but rather, from appellants' alleged

implementation of a scheme to provide unfavorable debt to MicroIslet in an attempt to

take over the company.

On appeal, appellants claim that the trial court erred in denying their special

motion to strike. We conclude that DRR's claims did not arise from the filing of the

1 Appellants are Ronald Katz, Keith B. Hoffman, Robert W. Anderson, Steven Frankel, William Wacthel, EuroAmerican Investment Corporation (EuroAmerican), SMR Trust III, Peter Knobel, Knobel Children's Trust, Harold Levine, John Hagenbuch, Brian Conn, Philip McConkey, and First Tennessee Brokerage, Inc. The complaint also named Michael J. Andrews and Barry Ritholtz as defendants, both of whom were alleged to be former directors of MicroIslet. Andrews and Ritholtz did not join in the special motion to strike and, consequently, they are also not parties to this appeal.

2 "SLAPP" stands for Strategic Lawsuit Against Public Participation. (See Equilon Enterprises v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 57.) Unless otherwise specified, all subsequent statutory references are to the Code of Civil Procedure. 3 bankruptcy petition nor from acts taken in connection with that filing, and that appellants

failed to carry their burden of establishing that DRR's claims arose from activity that is

protected under the anti-SLAPP statute. Accordingly, we affirm the trial court's order.

II.

FACTUAL AND PROCEDURAL BACKGROUND

A. The parties and the complaint

MicroIslet was a publicly traded corporation whose focus was on developing a

treatment for Type 1 diabetes. In late 2008, MicroIslet filed a bankruptcy petition

seeking reorganization (11 U.S.C. § 1101 et seq.). The company later converted the

petition to one seeking liquidation (11 U.S.C. § 701 et seq.). DRR's predecessors,

Bankruptcy Acquisition Company and Bankruptcy Acquisition Partners, purchased

MicroIslet's litigation claims during an auction of the company's assets conducted in the

bankruptcy proceedings, and assigned the claims to DRR.

In January 2012, DRR filed a complaint in which it alleged a cause of action for

breach of fiduciary duty against a group of former directors and officers of MicroIslet

(the "director/officer defendants"),3 and a cause of action for aiding and abetting breach

of fiduciary duty against a group of individuals who had either loaned money to

3 The director/officer defendants are Katz, Andrews, Hoffman, Anderson, Frankel, Ritholtz, and Conn. 4 MicroIslet ("creditor defendants") or had assisted the company in raising funds ("broker

defendants") (collectively the "creditor/broker defendants").4

In its breach of fiduciary duty cause of action, DRR alleged that after it became

apparent that MicroIslet was on the "verge of becoming immensely valuable," the

creditor defendants5 "developed and pursued a scheme to steal the business by saddling it

with expensive debt that could not or would not be repaid and that they could then

convert to ownership." According to DRR, the director/officer defendants eschewed

available equity funding for the company, and instead "arranged to make loans

themselves or through friends and related parties to provide financing to the [c]ompany

on terms unfavorable and unfair to the business, all designed to cause the debt to go

unpaid so that the [d]efendants would take over most or all of the ownership of the

business from existing shareholders."

More specifically, DRR alleged that since MicroIslet's founding in 1998 and

through 2006, MicroIslet had been funded with equity contributions and research grants,

rather than with debt. By early 2006, according to DRR, MicroIslet's public equity

market value exceeded $120 million. DRR further alleged that beginning in 2007, the

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Diabetes Research Restitution v. Katz CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/diabetes-research-restitution-v-katz-ca41-calctapp-2014.