Finn v. Girardi CA2/5

CourtCalifornia Court of Appeal
DecidedJanuary 28, 2025
DocketB324878
StatusUnpublished

This text of Finn v. Girardi CA2/5 (Finn v. Girardi CA2/5) 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
Finn v. Girardi CA2/5, (Cal. Ct. App. 2025).

Opinion

Filed 1/28/25 Finn v. Girardi CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION FIVE

ROBERT P. FINN, B324878

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. v. 20STCV47160)

ERIKA GIRARDI,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Richard L. Fruin, Jr., Judge. Affirmed. Spertus, Landes & Josephs, James W. Spertus, and Ezra D. Landes; Law Offices of Ronald Richards & Associates and Ronald Richards for Plaintiff and Appellant. Greenberg Gross, Evan C. Borges, and Heejin H. Hwang for Defendant and Respondent. Robert P. Finn (Finn) sued Erika Girardi (defendant), claiming she aided and abetted her husband and his law firm’s breach of their fiduciary duty to him in connection with cases Finn referred to the husband’s firm. The trial court granted defendant’s motion for summary judgment, finding the undisputed facts showed she had no actual knowledge of a breach of any fiduciary duty. We consider whether Finn has identified any material factual dispute about defendant’s actual knowledge.

I. BACKGROUND In December 2020, Finn sued, among others, defendant, defendant’s husband Thomas V. Girardi (Girardi), and his law firm Girardi & Keese (G&K).1 In the operative second amended complaint, Finn—a solo-practitioner lawyer himself—alleged he entered into a number of retainer agreements with individuals who required legal assistance in prosecuting claims arising out of exposure to toxic chemicals; those claims became part of the so- called “TXI Cases.” Finn referred all of his TXI clients to G&K. Pursuant to written agreements, Finn and G&K agreed to jointly represent Finn’s clients. The TXI Cases, according to the operative pleading, were ultimately resolved with a cash settlement in the amount of $31 million. When Finn did not receive his share of the settlement from G&K (i.e., $3.94 million), he filed suit.

1 Among the other named defendants was an entity, EJ Global, LLC (EJ Global), which Finn alleged was owned by defendant. Shortly after it granted summary judgment to defendant, the trial court granted EJ Global’s motion for judgment on the pleadings.

2 Finn’s lawsuit asserts a single cause of action against defendant: aiding and abetting a breach of fiduciary duty. Finn alleges Girardi and G&K owed him a fiduciary duty and breached it by misappropriating funds owed to him from the settlement of the TXI Cases. He avers further that defendant “knew” Girardi and G&K were in breach of their fiduciary duty to him and that she “substantially assisted and encouraged” her husband and his law firm in their misappropriation scheme by, among other things, “not taking any action to stop the tortious conduct” and “by participating in the tortious conduct.” Specifically, Finn asserts defendant knew the misappropriated fees funded her “notoriously lavish lifestyle [as] chronicled on The Real Housewives of Beverly Hills” and maintained defendant’s conduct was a “substantial factor” in causing him harm. Defendant eventually moved for summary judgment on the operative complaint. Among other things, she argued Finn could not meet his burden of proof on two core elements of the cause of action against her: (1) that she had actual knowledge of the alleged breach of fiduciary duty, or (2) that she provided any substantial assistance to Girardi and G&K in connection with such a breach. In support of her motion, defendant declared under penalty of perjury that she was “never” a lawyer and “never” worked at G&K; she had “no knowledge” of the TXI Cases or the dealings between Finn, Girardi, and G&K regarding those cases; and had “no knowledge of, . . . never communicated with [Finn], [Girardi] or anyone at [G&K] regarding, and never participated in” any of Finn’s agreements or transactions with Girardi or G&K relating to the TXI Cases, Finn’s requests for payment of fee-sharing or money related to the TXI cases, the receipt by G&K of any funds related to the TXI Cases, or the

3 disbursement of funds relating to the TXI Cases. Defendant’s supporting statement of undisputed material facts was based, in principal part, on her declaration. Finn opposed defendant’s motion for summary judgment.2 He argued defendant’s knowledge of the breach of fiduciary duty by her husband and his law firm could be inferred from circumstantial evidence indicating she benefitted from their alleged misconduct. He pointed, for instance, to a letter from the Franchise Tax Board (FTB) regarding EJ Global, which defendant formed in 2008 when she decided to resume her career as an entertainer. The FTB’s audit of EJ Global showed the company had operated at a significant net loss since its inception (e.g., between 2008 and 2014, the company earned on average $21,500 per year; during that same period, it lost on average $2.9 million per year.) Finn argued EJ Global was a sham business funded by Girardi and G&K to fund defendant’s extravagant lifestyle. Relying on statements and appearances defendant made as a cast member of the Real Housewives of Beverly Hills and news stories from the New York Post and Us Weekly, Finn also argued defendant helped “obfuscate” the truth of the alleged breach of fiduciary duty. Finn’s separate statement submitted with his opposition, however, did not dispute any of defendant’s

2 The record provided by Finn to this court includes only redacted copies of his opposition and separate statement and omits copies of documents lodged conditionally under seal in the trial court. Finn moved to augment the record with copies of the unredacted and omitted documents, but the motion was denied because the accompanying materials lacked Superior Court filing stamps or other indicia of filing.

4 facts regarding her lack of knowledge about the TXI Cases, Finn’s dealings with Girardi and G&K regarding those cases, and the payment and disbursement of funds from settlement of those cases. In reply, defendant argued she was entitled to judgment as a matter of law because, among other things, Finn conceded it was undisputed she had no actual knowledge of the alleged misappropriation scheme. Defendant also again argued Finn had not produced evidence creating a factual dispute concerning whether she was a substantial factor in causing his alleged harm. The trial court held a hearing on the summary judgment motion in August 2022 and concluded the motion should be granted for two reasons. First, the trial court found the legal foundation of the aiding and abetting claim was faulty. Relying on Beck v. Wecht (2002) 28 Cal.4th 289, which holds there exists no fiduciary duty between co-counsel, the court ruled defendant cannot have aided or abetted a fiduciary duty that did not exist (among Finn, Girardi, and G&K). Second, as a factual matter, the court found it was undisputed that defendant had no actual knowledge of a breach of any fiduciary duty. The court found the evidence submitted in support of Finn’s opposition (e.g., information regarding EJ Global’s finances) was “irrelevant”: in the trial court’s words, “[defendant’s] lavish and extravagant hobby funded by the spouse[’]s community property is not evidence of ‘actual knowledge’ of any breach of fiduciary duty between Girardi, [G&K], and [Finn]. In fact, [Finn] admit[s] that directly [in his separate statement].”3

3 The court further remarked that Finn’s concessions in his separate statement were “amazing.” The court observed that it

5 II.

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Finn v. Girardi CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/finn-v-girardi-ca25-calctapp-2025.