Judge: Armen Tamzarian, Case: 20STCV34720, Date: 2022-07-29 Tentative Ruling

Case Number: 20STCV34720    Hearing Date: July 29, 2022    Dept: 52

Tentative Ruling:   

Plaintiff Alfonso Bartolo’s Motions to Compel Further Supplemental Responses to Special Interrogatories and Requests for Production

Special Interrogatories

Plaintiff Alfonso Bartolo moves to compel further supplemental responses to special interrogatories Nos. 15-19 and 21-24.  A party propounding interrogatories may move to compel further responses when an answer “is evasive or incomplete,” “[a]n exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate,” or “[a]n objection to an interrogatory is without merit or too general.”  (CCP § 2030.300(a).) 

Defendant Jonny Appleseed Landscaping, Inc.’s responses are evasive or incomplete.  Special interrogatories Nos. 15, 16, 23, and 24 ask for information about other potential aggrieved employees in this PAGA action.  Defendant Jonny Appleseed Landscaping, Inc responded, “The Belaire-West Process is ongoing, and further responses will be provided pending notice from the claims administrator.”  That response does not answer the questions.  It is a promise to answer the questions later.  Defendant did not do so.  (Nguyen Decl., ¶¶ 6-12.)

No. 17 asks defendant to state the total number of aggrieved employees who formerly worked for defendant.  No. 18 asks defendant to state the total number of aggrieved employees who currently work for defendant.  No. 19 asks defendant to state the number of employees per pay period from June 15, 2019, to the present.  For all three questions, defendant answered, “The total number of potential AGGRIEVED EMPLOYEES is 33.” 

Nos. 17 and 18 ask different questions and should, in all likelihood, have different answers.  Properly responding to No. 19 requires separate answers for each pay period.   

Finally, Nos. 21 and 22 ask for the dates of employment for each employee identified in response to Nos. 15 and 16.  Again, defendant responded, “The total number of potential AGGRIEVED EMPLOYEES is 33.”  That response does not answer the questions. 

Defendant’s objections are overruled.

Plaintiff’s motion to compel further supplemental responses to special interrogatories, set one, is granted.  Defendant Jonny Appleseed Landscaping, Inc. is ordered to provide further responses to special interrogatories Nos. 15-19 and 21-24 within 20 days.  

Requests for Production

Plaintiff Alfonso Bartolo moves to compel further responses to requests for production Nos. 54-75 and 79-81.  A requesting party may move to compel further responses if “[a] statement of compliance with the demand is incomplete,” “[a] representation of inability to comply is inadequate, incomplete, or evasive,” or “[a]n objection in the response is without merit or too general.”  (CCP § 2031.310(a).)

To each request, defendant responded, “The Belaire-West Process is ongoing, and further responses will be provided pending notice from the claims administrator.”  Again, that respond does not answer the request.  It is a promise to provide answers later.  Defendant did not do so.  (Nguyen Decl., ¶¶ 6-12.)  Defendant must respond with a statement of compliance (CCP § 2031.220) or inability to comply (§ 2031.230).  

Defendant’s objections are overruled.

Plaintiff’s motion to compel further supplemental responses to requests for production, set one, is granted.  Defendant Jonny Appleseed Landscaping, Inc. is ordered to provide further responses to requests for production Nos. 54-75 and 79-81 within 20 days.