Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8

CourtCalifornia Court of Appeal
DecidedDecember 21, 2020
DocketB297193
StatusUnpublished

This text of Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8 (Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8) 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
Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8, (Cal. Ct. App. 2020).

Opinion

Filed 12/21/20 Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 EIGHT

MOHAMMAD A. MAZED B297193

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. BC654452) v.

LEECH, TISHMAN, FUSCALDO & LAMPL, LLP, et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, Joseph R. Kalin and Robert S. Draper, Judges. Affirmed. The David Epstein Law Firm and David G. Epstein for Plaintiff and Appellant. Nemecek & Cole, Jonathan B. Cole, Mark Schaeffer and Vikram Sohal for Defendants and Respondents. ____________________ Mohammad A. Mazed appeals the trial court’s rejection of his legal malpractice claim. Two fatal procedural problems infect his appeal. First, Mazed relies solely on an appellate argument he did not properly brief in the trial court. Second, Mazed’s appellate briefing is deficient. We therefore affirm. I Plaintiff and appellant Mohammad Mazed had a financial dispute with his former patent lawyer, respondent Ivan Posey. (We refer to Posey and his law firm, respondent Leech, Tishman, Fuscaldo & Lampl, LLP, collectively as Posey.) Posey asked Mazed to pay about $20,000 in legal fees. Mazed claimed he owed nothing and sued for a declaratory judgment saying so. Mazed’s complaint had nine counts. One was for legal malpractice. Mazed filed a first amended complaint. It is the operative pleading. This complaint alleged three areas of dispute. First, Mazed continued to seek a declaratory judgment he owed Posey nothing. Second, Mazed claimed Posey owed Mazed money for serving as Posey’s expert witness. Third, Mazed increased the number of his legal malpractice allegations to three: 1. Posey did not properly act upon a notice. 2. Posey made errors in materials Posey submitted to the patent office on Mazed’s behalf. 3. Posey injured Mazed through “diminution of foreign patent rights.” Posey responded with a counterclaim against Mazed, asserting Mazed did owe Posey money. Posey moved for summary judgment and adjudication. Mazed filed an 11-page brief in opposition, with voluminous attachments.

2 The trial court granted Posey’s motion on Mazed’s third malpractice count, which is all that remains at issue. The court ruled Posey’s alleged malpractice could not have harmed Mazed because the time to seek international patent protection passed before Mazed retained Posey. Mazed moved for reconsideration. The trial court denied this motion because Mazed could not point to a new fact or a new legal development since the court’s summary adjudication ruling. Mazed appealed. His lone issue on appeal focuses only on his third legal malpractice issue; he excludes other issues. The substance of Mazed’s appellate argument is the trial court misapplied patent law by starting a time clock too soon. The trial court, Mazed submits, started a 12-month clock on a date in 2006. Mazed argues the proper date was 2012. Key to this argument is Mazed’s contention his patent application was a particular kind called a continuation-in-part application. A continuation-in-part adds new matter to an earlier patent application. (See, e.g., The United States Patent and Trademark Office, Manual of Patent Examining Procedure, § 201.08 Continuation-in-Part Application [as of Dec. 17, 2020], archived at .) Mazed says this fact about his patent application moved the timing trigger from 2006 to 2012. II Mazed appeals on the basis of his continuation-in-part argument, but his brief in the trial court did not state this argument. In the trial court, Mazed unjustifiably reserved his briefing on this topic to a motion for reconsideration. The trial

3 court properly denied Mazed’s motion for reconsideration. We therefore affirm. Posey identifies this problem with Mazed’s appeal. Posey quotes the entirety of the pertinent bit of Mazed’s opposition brief from the trial court. This bit consists of four sentences only. None of Mazed’s four sentences mentions continuations-in-part, or indeed any legal authorities at all. This problem is lethal, for we may review only those material issues framed by the pleadings and presented to the trial court. (Martinez v. Scott Specialty Gases, Inc. (2000) 83 Cal.App.4th 1236, 1244.) An appellant must raise its point in the trial court before an appellate court will review that point. (See Litt v. Eisenhower Medical Center (2015) 237 Cal.App.4th 1217, 1222.) For this reason, we generally will not consider an argument or theory if it is raised for the first time on appeal. (American Continental Ins. Co. v. C & Z Timber Co. (1987) 195 Cal.App.3d 1271, 1281.) In reviewing attacks on summary judgments, the appellate court must disregard possible theories appellants did not fully state to the trial courts. (Havstad v. Fidelity Nat. Title Ins. Co. (1997) 58 Cal.App.4th 654, 661.) These principles of appellate review doom Mazed’s appeal, for Mazed never briefed his continuation-in-part argument to the trial court. Only after the trial court granted summary judgment did Mazed brief his continuation-in-part argument. This was in Mazed’s motion for reconsideration. This was too late. For vital reasons, the law severely restricts the proper scope of reconsideration motions. The proper scope for reconsideration is designedly small.

4 Reconsideration motions are proper when the law has changed after a court has ruled, as when an appellate court issues a new precedent that changes a trial court’s legal analysis. And reconsideration motions can also be proper if facts come to light that a diligent party could not previously have discovered. For sound reasons, courts strictly enforce this essential requirement of diligence. (E.g., Even Zohar Construction & Remodeling, Inc. v. Bellaire Townhouses, LLC (2015) 61 Cal.4th 830, 839–840.) Motions for reconsideration are improper when the losing party merely thinks up a snappier response after the court has ruled and the battle is lost. The trial court properly applied this law to deny Mazed’s motion for reconsideration: Mazed had no justification for failing to put his continuation-in-part argument in his original briefing. This ruling was correct. Mazed recounts but does not attack this ruling. Indeed, Mazed could not separately appeal the denial of his reconsideration motion. (Code Civ. Proc., §1008, subd. (g) [an order denying a motion for reconsideration is not separately appealable, and can be appealed only if the order that was the subject of the motion for reconsideration is appealable and indeed has been appealed); see Powell v. County of Orange (2011) 197 Cal.App.4th 1573, 1576–1577.) For this additional reason, it was essential for Mazed to brief his continuation-in-part argument in opposition to Posey’s summary judgment motion. In his reply to us, Mazed instead says he did place his continuation-in-part argument before the trial court. Mazed

5 asserts the record “reflects these concepts.” This euphemism is inadequate. Mazed’s lawyer had to do more than create a record that “reflects these concepts.” He had to do what lawyers always do during the summary judgment process: write a brief identifying the pertinent legal authorities and showing how these legal authorities control the dispute at hand. Something outside the brief attached to something else that reflects concepts is not sufficient.

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Related

American Continental Insurance v. C & Z Timber Co.
195 Cal. App. 3d 1271 (California Court of Appeal, 1987)
Martinez v. Scott Specialty Gases, Inc.
100 Cal. Rptr. 2d 403 (California Court of Appeal, 2000)
In Re Marriage of Falcone & Fyke
164 Cal. App. 4th 814 (California Court of Appeal, 2008)
Havstad v. Fidelity National Title Ins. Co.
58 Cal. App. 4th 654 (California Court of Appeal, 1997)
Litt v. Eisenhower Medical Center
237 Cal. App. 4th 1217 (California Court of Appeal, 2015)
Jameson v. Desta
420 P.3d 746 (California Supreme Court, 2018)
Powell v. County of Orange
197 Cal. App. 4th 1573 (California Court of Appeal, 2011)
United Grand Corp. v. Malibu Hillbillies, LLC
248 Cal. Rptr. 3d 294 (California Court of Appeals, 5th District, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Mazed v. Leech, Tishman, Fuscaldo & Lampl CA2/8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mazed-v-leech-tishman-fuscaldo-lampl-ca28-calctapp-2020.