Bogota Corporation v. Seiden CA2/1

INTRODUCTION

The trial court imposed monetary sanctions for discovery misconduct against appellant Lewis Seiden payable to respondent KGM3, LLC (KGM3).1 In this appeal, Seiden challenges those monetary sanctions on three procedural grounds. First, he contends the trial court erred when, after he did not file any written opposition to KGM3’s motion for sanctions, it issued its ruling via minute order the day before the scheduled hearing without holding an in-court oral hearing. Second, he contends we should reverse because KGM3 served its motion by e-mail even though he was representing himself at the time and had not consented to electronic service. Third, he contends the court’s minute order did not adequately state the court’s ruling. We find no merit to any of Seiden’s arguments and affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Seiden’s Commercial Landlord Sues Him and Seiden Cross-complains against KGM3 Seiden sells and leases cars. Seiden leased office space from Bogota Corporation (Bogota) to operate his business. He utilized two parking spaces on the leased property to show cars to

1 The trial court also imposed terminating sanctions which are the subject of a…