Helix Media v. Clark CA2/4

INTRODUCTION

Helix Media LLC (Helix) sued Natalie Clark (Clark), Freya Holdings LLC (Freya), and 41 limited liability companies for 25 causes of action sounding in both contract and tort. Clark and Freya moved to strike several causes of action in the operative complaint under Code of Civil Procedure section 425.16, the anti- SLAPP statute.1 The trial court (Hon. Ralph C. Hofer) denied the motion, and this court affirmed the denial order. (Helix Media LLC v. Natalie Clark, et al. (Nov. 17, 2022, B315990) [nonpub. opn.] (Helix I).) The trial court (Hon. William Crowfoot) subsequently granted Helix’s motion for attorneys’ fees against Clark, Freya, and their attorneys of record, for filing a frivolous anti-SLAPP motion. (§ 425.16, subd. (c)(1).) In this appeal, Robert Winkler (Winkler), Clark and Freya’s attorney of record in the proceedings below, contends the trial court erred by granting the attorneys’ fee motion because: (1) the trial court granted the motion without a finding of subjective bad faith; (2) the order did not adequately describe the conduct warranting sanctions; (3) the anti-SLAPP motion was not frivolous; and (4) the trial court improperly awarded fees incurred…