Cotton

I. BACKGROUND

A. The Complaint Marie and her late husband, John Cotton, owned and operated an automotive body repair shop known as Coach Kraft Body Shop (CKBS). CKBS was located on Marie and John’s property in Sonoma County. John’s adult son, Soul and Soul’s son, Cody, lived in a trailer on that property. John died on September 21, 2011. Marie filed suit against Soul on July 27, 2012, alleging five causes of action against Soul: unfair business practices; intentional interference with economic relations; negligence; conversion; and trespass. The gist of the complaint was that following the death of his father, Soul, operating through his own business entity, Coach Kraft Autobody (CKA), held himself out as the owner of CKBS to service providers, governmental entities, and members of the public. Marie alleged that Soul, without her knowledge or permission, changed the locks at CKBS and utilized CKBS property, including tools and equipment. After Marie sued

2 All further undesignated statutory references are to the Code of Civil Procedure.

2 Soul, and before he countersued, Marie filed two unlawful detainer actions against Soul, Cody, and various “Doe” defendants.3 B. The…