Navellier v. Putnam

CourtCalifornia Court of Appeal
DecidedFebruary 2, 2026
DocketA172077
StatusPublished

This text of Navellier v. Putnam (Navellier v. Putnam) 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
Navellier v. Putnam, (Cal. Ct. App. 2026).

Opinion

Filed 2/2/26 CERTIFIED FOR PARTIAL PUBLICATION*

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

LOUIS NAVELLIER et al., Plaintiffs and Appellants, A172077

v. (City & County of San Francisco DONALD PUTNAM et al., Super. Ct. No. CGC-19-574779) Defendants and Respondents.

Our local rules require that all parties promptly notify us about a bankruptcy that could affect our ability to decide an appeal. Despite this requirement, the parties in this case waited over four months after the filing of a bankruptcy petition by plaintiff Navellier and Associates, Inc. (NAI) and just two days before oral argument to tell us about that petition. Exacerbating the potential consequences of this delay, plaintiffs Louis Navellier and NAI now contend that the automatic bankruptcy stay precludes us from deciding this appeal. (11 U.S.C. § 362(a)(1).) If plaintiffs are correct, then the parties’ failure to provide timely notice of the bankruptcy would have caused this court to squander its valuable time and resources. Fortunately, plaintiffs are not correct because Navellier did not file for bankruptcy and because NAI, the debtor, brought this action.

* Pursuant to California Rules of Court, rules 8.1105(b) and 8.1110, this

opinion is certified for publication with the exception of parts B, C, and D of the Discussion.

1 Although the harm to this court caused by the parties’ violation of our local rules is therefore minimized, this does not excuse their misconduct. Although we do not sanction the parties, we do admonish them and advise them to learn and follow our local rules in the future. As for the contentions raised in plaintiffs’ appeal from a judgment in favor of defendants Donald Putnam and Grail Partners, LLC (Grail) following a jury trial on plaintiffs’ breach of contract and fraud claims, we reject them. Plaintiffs contend that the trial court prejudicially erred in failing to give their proposed special jury instructions on contract formation. We disagree because plaintiffs’ opening brief failed to support this contention with adequate reasoning or citations and because there was no prejudice. Plaintiffs also contend that the trial court’s award of attorney fees to defendants should be reversed because: (1) the contract plaintiffs sued on did not contain a fee provision; and (2) the fee award was excessive and unreasonable. We are unpersuaded and affirm. I. BACKGROUND A. Facts Plaintiffs provided subadvisory investment services to FolioMetrix, an investment advisory firm founded by Jerry Murphey and Greg Rutherford. Between 2013 and 2014, Navellier loaned FolioMetrix $1.5 million “via three separate $500,000 capital injections.” The loans were personally guaranteed by Murphey and Rutherford through a promissory note they executed in December 2013.1 Plaintiffs also provided subadvisory investment services to another investment advisory firm, American Independence. Grail and its

1 The promissory note only covered $1 million of the $1.5 million loaned

by Navellier because he did not send the remaining $500,000 to FolioMetrix until April 2014.

2 managing partner, Putnam, were involved with both FolioMetrix and American Independence and proposed merging the two to form a new company called RiskX. In March 2015, Navellier and Putnam met in New York to discuss the merger and Navellier’s role in providing investment advice to RiskX. At this point, Murphey and Rutherford had not repaid any portion of Navellier’s $1.5 million loan. According to Navellier, Putnam said during the meeting that he “wanted to relieve [Murphey and Rutherford] of their [loan] obligations” and “would take [the liability] on.” After the meeting, Navellier e-mailed Craig Cognetti, an officer at Grail, to congratulate him on the merger. Navellier noted that “[o]n the FolioMetrix books, it should show that I loaned [Murphey and Rutherford] $1.5 million . . . before Grail . . . took control.” Cognetti responded that “one of my priorities over the next few weeks is to make sure the balance sheet of Foliometrix is in order, this includes your loan.” Putnam, who was copied on the e-mail, responded that “[b]efore the transaction closes we intend that [the debt] be correctly recorded at the Company, and therefore the individuals will get out of the middle.”2 By August 2015, Putnam had a falling out with Rutherford and told Navellier in a voicemail that Rutherford “is out.” Navellier understood this to mean that Rutherford “would not be a part of the combined entity.” With respect to the promissory note, Putnam continued, “I would like to assume the company and relieve [Murphey and Rutherford] of the obligations. In [Rutherford’s] case, only if he goes along with the merger.” In early September 2015, Navellier became concerned that Putnam

2 When Grail acquired FolioMetrix, its balance sheet showed two loans

from Murphey and Rutherford, rather than Navellier, for $750,000 each.

3 would not repay the $1.5 million that Navellier had loaned to Murphey and Rutherford and sent Putnam a draft promissory note and pledge agreement to sign. Putnam refused and responded, “Are you kidding? Why would I ever do this? [¶] Right now, [Navellier] has $750[K] loaned to [Murphey] and $750[K] loaned to [Rutherford] . . . [¶] . . . We will find a way to get [Murphey] funds because we like him, but we are determined to screw [Rutherford] in any way we can.” Neither Putnam nor Grail repaid Navellier any portion of the $1.5 million he loaned to Murphey and Rutherford. B. Trial and Attorney Fees In March 2019, plaintiffs sued defendants for breach of contract, fraud, negligent misrepresentation, and breach of the covenant of good faith and fair dealing. For the breach of contract cause of action, plaintiffs’ complaint referenced Navellier’s loan to Murphey and Rutherford and alleged that in March 2015, defendants “entered into a written agreement whereby they agreed to assume and repay [plaintiffs] the $1.5 [m]illion in loans plus interest.” In addition to that $1.5 million, the complaint sought “accrued interest from December 30, 2013 to judgment at the rate of 10% per annum as provided in the promissory notes assumed by Plaintiffs.” At trial, Navellier testified that Putnam agreed to assume the obligations of the promissory note and to abide by all the terms of that note. According to Navellier, Putnam’s e-mail confirmed “that [he] was taking over [Rutherford’s] and [Murphey’s] liabilities” under the loans. Putnam, however, testified that he did not agree to assume any obligations under the note and that Navellier only requested that his loan be properly recorded on FolioMetrix’s books, to which Putnam agreed. Putnam continued that his comment about getting Murphey and Rutherford “out of

4 the middle” simply meant that the new company would be “exchanging two loans from its officers for one loan on the same terms” with Navellier. Cognetti also testified that Putnam and Grail “never agreed to assume any liability” and only wanted to replace the loans from Murphey and Rutherford to FolioMetrix with a loan directly from Navellier to FolioMetrix. The jury returned a verdict in favor of defendants. It found that the parties did not enter into a contract and that defendants did not promise to repay plaintiffs for the loans. Following trial, defendants sought $373,885.71 in attorney fees (and costs) pursuant to Civil Code section 1717.3 This amount included the time of five attorneys. The motion relied on the attorney fee provision in the promissory note executed by Murphey and Rutherford. Plaintiffs opposed, arguing that the contract they sued upon was not the note but the parties’ March 2015 agreement, and that the amount of fees requested was excessive and unreasonable.

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Navellier v. Putnam, Counsel Stack Legal Research, https://law.counselstack.com/opinion/navellier-v-putnam-calctapp-2026.