Socal Lien Solutions, LLC v. BDB Properties

Filed 12/31/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

SOCAL LIEN SOLUTIONS, LLC, B340151

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. 19STCV28189) v.

BDB PROPERTIES,

Defendant and Respondent.

APPEAL from an order of the Superior Court of Los Angeles County, Tony L. Richardson, Judge. Reversed with directions. Keiter Appellate Law and Mitchell Keiter for Plaintiff and Appellant. Law Offices of D. Hess Panah & Associates and Vania Nemanpour for Defendant and Respondent.

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The Corporations Code authorizes a plaintiff to serve process on a domestic corporation by hand delivery to the corporation’s designated agent. But when the designated agent cannot with reasonable diligence be found, the court may authorize service upon the corporation by hand delivery to the Secretary of State (the Secretary). Service in this manner is deemed complete 10 days later, regardless of whether the Secretary forwards notice of service to the defendant. Here, the trial court voided a default and default judgment against a corporate defendant after the court determined service to be incomplete until the Secretary forwarded notice to the defendant, which did not occur until a month after the court entered the default judgment. Because the court’s determination is inconsistent with the plain language of the Corporations Code, we reverse.

FACTUAL AND PROCEDURAL BACKGROUND A. Efforts To Serve the Corporate Defendant In the Secretary’s public records, BDB Properties (BDB) lists 1200 South Hope Street as the address of BDB’s principal executive office, its principal business office, chief executive officer, chief financial officer, secretary, and agent for service of process, as well as the address for service of process and general mailing. In 2019, SoCal Lien Solutions, Inc. (SoCal) served a summons and complaint on BDB at 1200 South Hope Street. When BDB failed to answer the complaint, SoCal obtained a default and a default judgment which the court later set aside. SoCal filed a first amended complaint with a proof of service on BDB attesting to personal service on BDB’s agent of process. The court rejected SoCal’s subsequent request for default, because the