Yesterday, the California Court of Appeal found substantial evidence in the record to uphold a trial court's decision to add an affiliated corporation as a judgment debtor under the "single enterprise" theory. Toho-Towa Co., Ltd. v. Morgan Creek Productions, Cal. Ct. Appeal Case No. B242095, July 11, 2013. Some of the factors cited were:
- The entities were owned by the same person;
- The entities exploited the same assets;
- The "work" of the entities was performed by employees of one of the entities; and
- Payments were made by one of the entities' lender.