SG LLC fraud 499
April 9th, 2012 
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Misik v D’Arco 197 Cal.App.4th 1065 (2/3) (2011) Misik successfully sued SG, LLC, for fraud and breach of contract. San-Diego-Auto-Accident-lawyer After judgment, Misik moved to amend judgment, naming D’Arco as alter ego although alter ego not alleged in complaint. Denied, reversed. [1] Denying amendment motion is an appealable order. CCP § 904.1. [2] CCP § 187 authorizes post-judgment amendment to add judgment debtor whether as alter ego or otherwise, “great liberality.” [3] No requirement to show fraud, only need show that protecting legal fiction of corporate status would promote injustice (Here D’Arco owned 100% of SG., paid its bills, operated out of his residence, etc.) [4] Pleading alter ego in complaint not prerequisite to amendment. San Diego personal injury attorney