Judge: Armen Tamzarian, Case: 21STCV07947, Date: 2023-01-06 Tentative Ruling
Case Number: 21STCV07947 Hearing Date: January 6, 2023 Dept: 52
Defendant BNSF Railway Company’s Motions to Compel Further
Responses to: (1) Requests for Production; (2) Form Interrogatories; and (3)
Special Interrogatories
Requests for Production
Defendant BNSF Railway Company (BNSF)
moves to compel plaintiff Wayne Olson to serve further responses to requests
for production, set one, Nos. 1-29. A party propounding requests for production
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).)
Plaintiff made objections that were
too general. His response began with
numerous “general objections,” which are improper.
Plaintiff
also made meritless objections. To nearly
all requests, plaintiff responded only, “Plaintiff objects to this request [as]
overly broad, unduly burdensome, and as it requires Plaintiff to prematurely
marshal his evidence. Subject to these objections, Plaintiff reserves the right
to supplement.” These objections are
without merit and the response is evasive.
Most of the requests ask for documents that support plaintiff’s various
contentions. Those documents are
discoverable as “matter involved in the pending action” that “either is itself
admissible in evidence or appears reasonably calculated to lead to the
discovery of admissible evidence.” (CCP
§ 2017.010.)
Moreover, requiring
the responding party to “prematurely marshal his evidence” is not a valid
objection. A responding party must make “a
diligent search and a reasonable inquiry” to comply, and the sworn response
must “affirm” he did so. (CCP §
2031.230.)
Plaintiff’s
objections are overruled.
Plaintiff’s
response to No. 24 is an incomplete statement of compliance. A statement of compliance “shall state that
the production … demanded, will be allowed either in whole or in part, and that
all documents or things in the demanded category that are in the possession,
custody, or control of that party and to which no objection is being made will
be included in the production.” (CCP §
2031.220.) Plaintiff responded, “The
medical records responsive to this request are being produced.” That response is incomplete because it does
not state plaintiff is allowing the demand in whole and does not state under
oath that he will produce all responsive documents in his possession,
custody, or control.
Plaintiff’s
responses also include inadequate statements of inability to comply. Such responses must “affirm that a diligent
search and a reasonable inquiry has been made,” specify the reason for
plaintiff’s inability to comply, and identify anyone believed to possess the
items requested. (CCP § 2031.230.)
That
plaintiff “reserves the right to supplement” is effectively a statement of
inability to comply. It neither states
plaintiff will permit the inspection nor that he is withholding documents based
on objections. To Nos. 19, 28, and 29,
plaintiff responded that he “has no responsive documents.” These responses are inadequate, incomplete,
and evasive because they do not affirm a diligent search, specify the reason
for his inability to comply, or identify anyone believed to possess the items.
Defendant
is entitled to an order compelling further responses without objections to the
requests for production.
Form Interrogatories
Defendant
BNSF moves to compel further responses by plaintiff Wayne Olson to form
interrogatories, set one, Nos. 6.4, 6.5, 6.7, 8.2-8.8, 9.1, 9.2, 10.2, 10.3,
12.1, 14.1, and 17.1. A party may move
to compel further responses to interrogatories when an answer “is evasive or
incomplete” (CCP § 2030.300(a)(1), “[a]n exercise of the option to produce
documents under Section 2030.230 is unwarranted or the required specification
of those documents is inadequate” (§ 2030.300(a)(2)), or an objection “is
without merit or too general” (§ 2030.300(a)(3)).
Plaintiff
made objections that were too general.
His response began with over a page of “general objections.”
Plaintiff
also made meritless objections to form interrogatories Nos. 9.1 and 12.1. No.
9.1 asked him to describe “any other damages” he attributes to the incident,
defined as “[t]he alleged exposures to asbestos or chemicals that form the basis
of your complaint.” Plaintiff responded
by objecting that the interrogatory “is vague, uncertain and overbroad, and
being without limitation as to time or specific subject matter in its use of
the word ‘incident.’ ”
No. 12.1 asked plaintiff to identify
people who witnesses the incident, made any statements at the scene, heard any
statements made at the scene, or has knowledge of the incident. Plaintiff objected that the interrogatory is
“not applicable and irrelevant” and “vague, uncertain and overly broad, and
being without limitation as to time or specific subject matter in its use of
the word ‘incident.’ ”
Plaintiff alleges exposure over four
decades (Comp., ¶¶ 16, 18), so there are likely many witnesses. But the request is not vague or
uncertain. Plaintiff understands the
question; it is just hard to answer.
Despite the long duration, that is what plaintiff alleges in his
complaint, so the question is not overly broad.
Moreover, he gave a partial substantive response that his exposure “was
witnessed by several individuals, including his co-workers and supervisors,”
but he did not identify any of those witnesses as required. Plaintiff may not remember every person but
must identify those he remembers.
Plaintiff’s
objections are overruled.
In
plaintiff’s response to No. 6.7, he refers to documents without complying with
Code of Civil Procedure section 2030.230.
When an answer “would necessitate the preparation or the making of a
compilation,” the responding party may instead “specify the writings from which
the answer may be derived or ascertained.
This specification shall be in sufficient detail to permit the
propounding party to locate and to identify, as readily as the responding party
can, the documents from which the answer may be ascertained.” (CCP § 2030.230.)
No. 6.7 asks
for information regarding whether any “health care provider advised that
[plaintiff] may require future or additional treatment for any injuries that
you attribute to the incident?” Plaintiff’s
response included that he “refers Defendants to the medical records produced in
this case to date.” He fails to
establish that answering this question necessitates the preparation or making
of a compilation or summary. Plaintiff also
does not specify any document. That
response does not have sufficient detail to permit defendant to ascertain an
answer.
Plaintiff also gave evasive and
incomplete responses. For example, No.
8.1 asks if he attributes any loss of income or earning capacity to the
incident. He responded only, “Plaintiff
will supplement this request.” To No.
10.3, he responded, “Discovery and investigation continue.” Most of plaintiff’s responses amount to
stating he will answer later.
Those responses are inadequate. “If the responding party does not have
personal knowledge sufficient to respond fully to an interrogatory, that party
shall so state, but shall make a reasonable and good faith effort to obtain the
information by inquiry to other natural persons or organizations, except where
the information is equally available to the propounding party.” (CCP § 2030.220(c).) “[A] responding party generally may not respond
to interrogatories just by asserting its ‘inability to respond.’ ” (Sinaiko Healthcare Consulting, Inc. v.
Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 406.) Plaintiff therefore must perform a reasonable
and good faith investigation and attempt to answer each interrogatory.
Defendant
is entitled to an order compelling further responses without objections.
Special Interrogatories
Defendant BNSF moves to compel
further responses by plaintiff Wayne Olson to special interrogatories, set one,
Nos. 1-9, 12-14, 17-29, 31-34, 36-43, 47, 49-50, 53-60, 66-73, 80-106, and
108-114.
As
with the form interrogatories, plaintiff’s response began with improper “general objections.”
Plaintiff
again made meritless objections to specific interrogatories. To many interrogatories, he responded, “Plaintiff
objects to this request overly broad, unduly burdensome, and as it requires Plaintiff
to prematurely marshal his evidence.”
(E.g., Nos. 1-9, 17-27, 34.) The
requests are not overly broad or unduly burdensome. For example, Nos. 1-8 are standard
interrogatories about facts, writings, and witnesses, supporting various
contentions in plaintiff’s complaint.
That information is discoverable.
(CCP § 2017.010 [“Discovery may be obtained of the identity and location
of persons having knowledge of any discoverable matter, as well as of the
existence … of any document”]; § 2030.010(b) [“An interrogatory may relate to
whether another party is making a certain contention, or to the facts,
witnesses, and writings on which a contention is based”].)
In addition, requiring plaintiff to
prematurely marshal evidence is not a valid objection. As discussed above, the responding party has
a duty to investigate to obtain the information necessary to answer
interrogatories.
To several requests, plaintiff
objected that “this information is best obtained through the deposition
testimony of Plaintiff and medical witnesses.”
(E.g., Nos. 34, 36, 37, 39.) That
is not a valid objection. The requesting
party gets to choose which discovery method to employ, regardless of whether it
is the “best” method.
Plaintiff’s objections are overruled.
Again, some of plaintiff’s responses
refer to documents without complying with Code of Civil Procedure section
2030.230. His responses to several
interrogatories include, “Plaintiff refers Defendant to medical and billing
records being produced in this matter” (Nos. 31, 47), or “to the medical
records produced in this case to date” (e.g., Nos. 32, 33, 37-43). Plaintiff fails to establish that answering
those questions necessitates the preparation or making of a compilation or
summary. He also does not specify any
document, so the response lacks sufficient detail to permit defendant to
ascertain an answer.
Plaintiff also made evasive or
incomplete responses. To almost every
interrogatory, he gave no substantive answer and instead stated he “reserves
the right to supplement” (e.g., Nos. 1-9, 12-14, 17-29, 32-34, 37), or he “will
supplement this response” (e.g., Nos. ), or “will supplement this request [sic]”
(e.g., Nos. 12-14, 28, 29, 32-34, 37.)
As discussed above, these answers are insufficient. Instead of promising future answers,
plaintiff must perform a reasonable and good faith investigation and attempt to
answer each interrogatory.
Defendant
is entitled to an order compelling further responses without objections to its
special interrogatories.
Sanctions
In
each motion, defendant moves for monetary sanctions.
The notices of motion specify defendant seeks sanctions under Code of
Civil Procedure sections 2023.030, 2030.300, subdivision (d) for interrogatories,
and 2031.300, subdivision (c) for requests for production. (The latter is an error. The appropriate statute is section 2031.310,
subdivision (h), because this is a motion to compel further responses, not to
compel a response by a party who failed to timely respond.)
The court cannot issue sanctions
under these three statutes. The Court of
Appeal recently held, “Section 2023.030 describes the types of sanctions
available under the Discovery Act when another provision authorizes a
particular sanction. Section 2023.030
does not independently authorize the court to impose sanctions for discovery
misconduct.” (City of Los Angeles v.
PricewaterhouseCoopers, LLC (2022) 84 Cal.App.5th 466, 502.)
Sanctions are not available under the
statutes independently authorizing sanctions, Code of Civil Procedure sections
2030.300, subdivision (d) and 2031.310, subdivision (h) because plaintiff did
not oppose this motion. Both subdivisions
provide, in relevant part, “The court shall impose a monetary sanction under
Chapter 7 (commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion to compel a further
response to interrogatories, unless it finds that the one subject to the
sanction acted with substantial justification or that other circumstances make
the imposition of the sanction unjust.”
Plaintiff did not unsuccessfully oppose these motions because he did not
file any oppositions.
Disposition
Defendant
BNSF Railway Company’s requests for sanctions are denied.
Defendant
BNSF Railway Company’s motion to compel further responses to requests for
production is granted. Plaintiff Wayne Olson is hereby ordered to provide further verified responses without
objections to requests for production Nos. 1-29 within 30 days.
Defendant BNSF Railway Company’s
motion to compel further responses to form interrogatories is granted. Plaintiff
Wayne Olson is hereby ordered to provide
further verified responses without objections to form interrogatories Nos. 6.4, 6.5, 6.7, 8.2-8.8, 9.1,
9.2, 10.2, 10.3, 12.1, 14.1, and 17.1 within 30 days.
Defendant
BNSF Railway Company’s motion to compel further responses to special
interrogatories is granted. Plaintiff Wayne Olson is hereby ordered to provide further verified responses without objections
to special interrogatories Nos. 1-9, 12-14, 17-29, 31-34, 36-43, 47, 49-50,
53-60, 66-73, 80-106, and 108-114 within 30 days.