A long-standing legal battle between an investor and her former advisor has taken another turn, with the court reaffirming a decade-old judgment. On June 17, 2024, Curtis J. Sathre III filed a complaint in the Court of Appeal of the State of California against Jaimie Davis. The case was heard in Los Angeles County Superior Court under Judge Richard L. Fruin, Jr.
The dispute dates back to 2012 when Davis lost an arbitration against her former investment advisor, Curtis J. Sathre III, and his company. She had sought to recover losses from risky investments that she claimed were misrepresented as safe by Sathre. The arbitration panel ruled against Davis, awarding over $135,000 in costs and expert fees to Sathre—a sum that remains unpaid. As the 10-year anniversary of this judgment approached, Sathre sought its renewal under Code of Civil Procedure section 683.110, which the court granted.
In her appeal against the renewal of judgment, Davis argued that new evidence from a FINRA investigation into WFP Securities—where Sathre was a registered representative—would have substantiated her claims of fraud and negligence. She alleged that crucial information was withheld during the original arbitration process, constituting extrinsic fraud. However, the court found no merit in these claims, noting that any concealment of evidence would be considered intrinsic fraud and not grounds for vacating a judgment renewal.
Davis also contended that the trial court lacked jurisdiction to confirm the original arbitration award and enter judgment in 2012. She argued that federal courts have exclusive jurisdiction over FINRA arbitration awards—a claim dismissed by both the trial court and appellate judges who affirmed that state courts hold concurrent jurisdiction for such matters.
Moreover, Davis attempted to introduce new claims related to misconduct by her attorney during the original arbitration proceedings and procedural errors by the arbitrators themselves. These arguments were similarly rejected as they did not constitute valid defenses against renewing a judgment but rather aimed at relitigating issues already settled.
Ultimately, Davis's motions to vacate both the original and amended renewals of judgment were denied by Judge Fruin on grounds consistent with established legal standards for renewing judgments in California.
Representing Curtis J. Sathre III were attorneys Brandon S. Reif, Marc S. Ehrlich, and Drew Frey from Reif Law Group. Jaimie Davis represented herself pro se in this matter before Judges Segal, Martinez P.J., and Feuer J., under Case ID B324459.