Video Tech Services v. Abdalla CA2/5
Plaintiff and appellant Video Tech Services, Inc. obtained a judgment against several defendants, including Thomas Woolsey, after terminating sanctions were imposed as a sanction for discovery abuse. Video Tech appeals from a post-judgment order denying a motion to amend the judgment to add Thomas, in his capacity as trustee of the H.E. Woolsey Trust (Trust 1), as a judgment debtor. Video Tech contends the trial court applied an incorrect legal standard to determine whether a trustee is the alter ego of a judgment debtor, specifically, by requiring Trust 1 to have been involved in the underlying dispute. The record on appeal is inadequate to demonstrate prejudicial error, as it contains no reporter’s transcript of the hearing on the motion to amend the judgment, or suitable substitute such as a settled statement or agreed statement, as authorized by California Rules of Court, rules 8.134 and 8.137. Assuming the record on appeal is adequate for review, however, we conclude the co
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