Judge: Armen Tamzarian, Case: 21STCV30275, Date: 2023-05-15 Tentative Ruling

Case Number: 21STCV30275    Hearing Date: May 15, 2023    Dept: 52

Plaintiff Fabienne Sanegor’s Motions to Compel Defendant Walmart, Inc. to: (1) Respond to Form Interrogatories, Set Two; and (2) Respond to Demands for Inspection, Set Two

            Plaintiff Fabienne Sanegor moves to compel defendant Walmart, Inc. to respond without objections to plaintiff’s form interrogatories – general, set two, and demand for inspection, set two.

When a party fails to timely respond to interrogatories or demands for inspection, the requesting party may move for an order compelling responses.  (CCP §§ 2030.290(b) [interrogatories]; 2031.300(b) [demands for inspection].)  Failure to timely respond waives any objections.  (CCP §§ 2030.290(a); 2031.300(a).)

Plaintiff served these discovery requests on Walmart, Inc. on October 12, 2022.  (Meenan Decls., ¶ 12, Ex. 1.)  Walmart did not serve a timely response.  (Id., ¶ 15.) 

Plaintiff therefore is entitled to an order compelling Walmart to respond, without objections, to form interrogatories – general, set two, and to demand for inspection, set two. 

Sanctions

In each motion, plaintiff moves for $2,000 in sanctions against Walmart.  Failing to respond to an authorized method of discovery is a misuse of the discovery process subject to monetary sanctions.  (CCP § 2023.010(d).)  For interrogatories and demands for inspection, sanctions are mandatory unless the responding party acted with substantial justification or sanctions would otherwise be unjust under the circumstances.  (CCP § 2030.290(c) [interrogatories]; § 2031.300(c) [demands for inspection].)

Walmart did not timely respond to plaintiff’s discovery requests.  The court finds it did not act with substantial justification, and sanctions are just under the circumstances.

The court finds, however, that plaintiff did not reasonably incur $2,000 in fees for each motion.  Plaintiff’s counsel states he spent two hours working on each motion and expected to spend another two hours drafting a reply and appearing at the hearing.  (Meenan Decls., ¶ 16.)  Plaintiff did not file a reply.  The court is hearing both motions at the same time.  Moreover, an experienced attorney such as plaintiff’s counsel should have been able to draft these simple motions in less time.  The court finds plaintiff reasonably incurred 1.5 hours of fees at $500 hourly, plus the $60 filing fee, for a total of $810 in sanctions on each motion.

Disposition

            Plaintiff Fabienne Sanegor’s motion to compel defendant Walmart, Inc. to respond without objections to plaintiff’s form interrogatories – general, set two is granted.  Defendant Walmart, Inc. is ordered to serve verified responses without objections to form interrogatories – general, set two, within 20 days.  Defendant Walmart, Inc. is ordered to pay plaintiff $810 in sanctions within 20 days.

            Plaintiff Fabienne Sanegor’s motion to compel defendant Walmart, Inc. to respond without objections to plaintiff’s demand for inspection, set two is granted.  Defendant Walmart, Inc. is ordered to serve verified responses without objections to demand for inspection, set two, within 20 days.  Defendant Walmart, Inc. is ordered to pay plaintiff $810 in sanctions within 20 days.

 

Plaintiff Fabienne Sanegor’s Motions: (1) To Compel Defendant UKAP Trading, L.L.C. to Respond to Form Interrogatories, Set Two; (2) To Compel Defendant UKAP Trading, L.L.C. to Respond to Demand for Inspection, Set Two; and (3) To Deem Admitted the Truth of Matters Specified in Requests for Admission, Set One

(1) Interrogatories and (2) Demand for Inspection

Plaintiff Fabienne Sanegor moves to compel defendant UKAP Trading, L.L.C. Inc. to respond without objections to plaintiff’s form interrogatories – general, set two, and demand for inspection, set two.

Plaintiff served these discovery requests on UKAP Trading, L.L.C. on October 12, 2022.  (Meenan Decl., ¶ 12, Ex. 1.)  Plaintiff gave UKAP Trading five extensions to respond.  (Id., ¶ 15.)  UKAP Trading did not respond by the final deadline of January 6, 2023.  (Ibid.)

Plaintiff therefore is entitled to an order compelling UKAP Trading to respond, without objections, to plaintiff’s form interrogatories – general, set two and demand for inspection, set two. 

(3) Requests for Admission

            Plaintiff Fabienne Sanegor moves for an order deeming the truth of matters specified in request for admissions, set one, admitted against defendant UKAP Trading, L.L.C. 

When a party fails to respond to requests for admission, the requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted.  (CCP § 2033.280(b).)  An order deeming matters admitted is mandatory “unless [the court] finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220.”  (CCP § 2033.280(c).) 

Plaintiff served her requests for admission, set one on UKAP Trading, L.L.C. on October 12, 2022.  (Meenan Decl., ¶ 12, Ex. 1.)  Plaintiff gave UKAP Trading five extensions to respond.  (Id., ¶ 15.)  UKAP Trading did not respond by the final deadline of January 6, 2023.  (Ibid.)

UKAP Trading has not served a proposed response to the requests for admission.  An order deeming the matters admitted is therefore mandatory.

Sanctions

In each motion, plaintiff moves for $1,060 in sanctions against defendant UKAP Trading, L.L.C.  Failing to respond to an authorized method of discovery is a misuse of the discovery process subject to monetary sanctions.  (CCP § 2023.010(d).)  For interrogatories and demands for inspection, sanctions are mandatory unless the responding party acted with substantial justification or sanctions would otherwise be unjust under the circumstances.  (CCP § 2030.290(c) [interrogatories]; § 2031.300(c) [demands for inspection].)  For requests for admission, sanctions are mandatory—with no exception for substantial justification or other circumstances.  (CCP § 2033.280(c).)

UKAP Trading did not timely respond to plaintiff’s discovery requests.  The court finds it did not act with substantial justification, and sanctions are just under the circumstances.

The court finds, however, that plaintiff did not reasonably incur $1,060 in fees for each motion.  Plaintiff’s counsel states he spent one hour working on each motion and expected to spend another hour drafting a reply and appearing at the hearing.  (Meenan Decls., ¶ 18.)  Plaintiff did not file any reply.  The court is hearing these motions at the same time.  Moreover, an experienced attorney such as plaintiff’s counsel should have been able to draft these simple motions in less time.  The court finds plaintiff reasonably incurred 1.5 hours of fees at $500 hourly, plus the $60 filing fee, for a total of $810 in sanctions on each motion.

Disposition

            Plaintiff Fabienne Sanegor’s motion to compel defendant UKAP Trading, L.L.C. to respond without objections to plaintiff’s form interrogatories – general, set two is granted.  Defendant UKAP Trading, L.L.C. is ordered to serve verified responses without objections to form interrogatories – general, set two, within 20 days.  Defendant UKAP Trading, L.L.C. is ordered to pay plaintiff $810 in sanctions within 20 days.

            Plaintiff Fabienne Sanegor’s motion to compel defendant UKAP Trading, L.L.C. to respond without objections to plaintiff’s demand for inspection, set two is granted.  Defendant UKAP Trading, L.L.C. is ordered to serve verified responses without objections to demand for inspection, set two, within 20 days.  Defendant UKAP Trading, L.L.C. is ordered to pay plaintiff $810 in sanctions within 20 days.

            Plaintiff Fabienne Sanegor’s motion to deem admitted the truth of the matters specified in requests for admission, set one to defendant UKAP Trading, L.L.C.  is granted.  The truth of the matters specified in plaintiff Fabienne Sanegor’s requests for admission, set one to defendant UKAP Trading, L.L.C. is hereby deemed admitted.  Defendant UKAP Trading, L.L.C. is ordered to pay plaintiff $810 in sanctions within 20 days.