Prato v. Gioia

CourtCalifornia Court of Appeal
DecidedJune 27, 2025
DocketG064139
StatusPublished

This text of Prato v. Gioia (Prato v. Gioia) 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
Prato v. Gioia, (Cal. Ct. App. 2025).

Opinion

Filed 6/27/25

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

SHEILA PRATO,

Plaintiff and Appellant, G064139

v. (Super. Ct. No. 30-2021 01234131) THOMAS JOHN GIOIA et al., OPINION Defendants and Respondents.

Appeal from a judgment of the Superior Court of Orange County, Jonathan S. Fish, Judge. Reversed and remanded with directions. Sheila Prato, in pro. per., for Plaintiff and Appellant. Law Offices of Thomas P. Aplin and Thomas P. Aplin for Defendant and Respondent Thomas John Gioia. Morasse Collins & Clark and Desmond J. Collins for Defendant and Respondent Lee & Associates Commercial Real Estate Services, Inc.– Irvine. * * * “The American legal profession exists to help people resolve disputes cheaply, swiftly, fairly, and justly.” (Karton v. Ari Design & Construction, Inc. (2021) 61 Cal.App.5th 734, 747.) The legitimacy of the legal profession also relies on attorneys acting with both civility and rectitude, especially when dealing with the courts and with nonattorneys. In appellant Sheila Prato’s case, the profession failed to deliver on most, if not all, of these objectives–especially the one regarding civility and rectitude. Ms. Prato appeals an award of over $70,000 in attorney fees entered jointly and severally against her and her company, Prato Properties, LLC (Prato LLC), after their civil complaint was dismissed without prejudice due to their failure to appear at trial. (See Code Civ. Proc., § 581, subd. (b)(5).) 1 At the time the case was set to go to trial, however, plaintiffs’ attorney of record, Timothy McFarlin, had been rendered inactive and ineligible to practice law by the State Bar of California while disciplinary proceedings against him were pending. It appears Ms. Prato was not aware of this at the time. But her opponents in the case–respondents Thomas John Gioia and Lee & Associates (the Lee Firm)–were. And it is what their counsel did with this information that troubles us. At its core, this case presents a disturbing litany of mistakes by a profession we deem far too estimable to make so many. And there is plenty of culpability to go around, starting with Ms. Prato’s own attorney, who failed to inform her he was no longer eligible to practice law. But the circle grows. We see nothing in the record to show the State Bar took steps to inform Ms.

1 All undesignated statutory references are to the Code of Civil

Procedure.

2 Prato (or any of McFarlin’s other clients) of his status once he entered disciplinary proceedings. Respondents’ attorneys certainly seemed to be in no hurry to flag for the court or Ms. Prato that she lacked representation; even though they should have known it was impacting the case. And the record does not show the trial court took any action even when informed about McFarlin’s proceedings. What might have changed the course of events here? We have an idea. Perhaps just a modicum of courtesy on the part of respondents’ attorneys would have made all the difference. Something to the effect of: “Your Honor, we’re not sure Ms. Prato knows her lawyer is ineligible to practice.” Or, “Your Honor, with the court’s permission, may we send notice to Ms. Prato directly to ensure she is aware of her counsel’s status?” We do not know why respondents’ counsel chose not to make such nominal attempts at basic professionalism and civility. What we do know is the attorneys’ conduct was more tactical than anything else–they obtained a dismissal of Ms. Prato’s lawsuit while she was unrepresented, and then had the audacity to move for an award of attorney fees against her. This conduct does not comport with the professional and ethical standards we expect from lawyers. But, as it happens, neither does it comport with the law on the books. Under the authority of section 286, a party represented by counsel who dies or is removed or suspended from the practice of law is entitled to written notice of same before further proceedings may be taken against her. Clearly, respondents’ counsel knew about the requirements of section 286, because they provided notice under its auspices after filing motions for attorney fees after trial. But they did not serve Ms. Prato with such notice before trial, when she would have been in a better position to

3 affect the outcome of the case (and potentially thwart respondents’ plan to seek attorney fees in the first place). And they did not serve the notice in time to allow Ms. Prato to meet statutory deadlines to try and vacate the dismissal of her case. When she did finally receive notice from respondents under section 286, Ms. Prato appeared in court, hired new counsel, and filed an opposition pointing out respondents’ failure to serve such notice earlier. But to no avail. The trial court granted the fee motions anyway. On appeal, Ms. Prato 2 argues it was unreasonable for the court to enter an attorney fee award against her when respondents were aware before trial that her lawyer was in disciplinary proceedings. She is correct. Inactive status renders an attorney ineligible to practice law. Thus, McFarlin could not legally represent Ms. Prato at trial. And a litigant abandoned by counsel is not the same as a self-represented litigant, who might be expected to appear on her own. We therefore hold that an attorney whom the State Bar of California has made involuntarily inactive and ineligible to practice law meets the definition of an attorney who has been “removed or suspended” for purposes of section 286. And any party who

2 A notice of appeal was only filed on behalf of Ms. Prato, not

Prato LLC. While Ms. Prato asserts that both she and Prato LLC are appealing, no counsel has appeared or filed an appeal on Prato LLC’s behalf. “[U]nder a long-standing common law rule of procedure, a corporation, unlike a natural person, cannot represent itself before courts of record in propria persona, nor can it represent itself through a corporate officer, director or other employee who is not an attorney. It must be represented by licensed counsel in proceedings before courts of record.” (CLD Construction, Inc. v. City of San Ramon (2004) 120 Cal.App.4th 1141, 1145.)

4 becomes aware that an opponent’s attorney has been made involuntarily inactive and ineligible to practice law by the State Bar must promptly give notice to his or her opponent under section 286. We also hold that trial courts, when notified of an attorney’s involuntarily inactive status, are encouraged to order counsel to issue section 286 notice to the affected party before further proceedings may be taken against him or her. 3 In this case, not only did respondents fail to provide section 286 notice to Ms. Prato in a timely fashion, it appears to this court based on this record, they took advantage of her unrepresented status during this litigation. Such conduct by members of the bar cannot be countenanced. We thus reverse and remand for the trial court to reconsider respondents’ motions for attorney fees in light of section 286. STATEMENT OF FACTS AND PROCEDURAL HISTORY Ms. Prato was a partner and principal owner of Mocha Family Limited Partnership (Mocha), which owned a commercial property located on Via Lido in Newport Beach. In June 2015, Ms. Prato, acting on behalf of Mocha, leased the property to KEP MTM1, LLC d/b/a Klein Epstein & Parker (Lessee). The Lee Firm, represented by its senior vice president, Gioia, acted as a dual agent for both Mocha and the Lessee in the transaction. The lease required that the lessor approve any sublease of the demised premises. It also contained an attorney fee provision. In June 2016, Mocha conveyed the property to Prato LLC. The lease was amended to reflect the new lessor. However, in March 2017, Ms.

3 This is in addition to the procedures detailed in Business &

Professions Code section 6180 et seq.

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Prato v. Gioia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prato-v-gioia-calctapp-2025.