Judge: Armen Tamzarian, Case: 23STCV23071, Date: 2025-04-03 Tentative Ruling
Case Number: 23STCV23071 Hearing Date: April 3, 2025 Dept: 52
Plaintiff The People of the State of California’s Motion for Discovery
Sanctions
Plaintiff The People of the State of
California, acting by and through the Department of Transportation, moves for terminating
sanctions against defendants Metro Investments Group, Inc. (Metro) and Anthony
Nowaid. Plaintiff further moves for evidence,
issue, and monetary sanctions and an order compelling defendants to comply with
this court’s discovery orders.
After the
court grants a motion to compel responses to requests for production, if the
responding “party then fails to obey,” the court may impose terminating
sanctions, issue sanctions, evidence sanctions, and/or monetary sanctions. (Code Civ. Proc., § 2031.300, subd. (c).) A
court may impose terminating sanctions by striking out a party’s pleadings and
rendering default judgment against a defendant.
(Code Civ. Proc., § 2023.030, subd. (d).)
Metro and
Nowaid disobeyed orders compelling responses to requests for production. On July 1, 2024, the court ordered Metro to
serve verified responses without objections to plaintiff’s requests for
production, sets one and two. (Choi
Decl., Ex. 3, p. 2.) The court further
ordered Nowaid to serve verified responses without objections to plaintiff’s
requests for production, set one. (Id.,
p. 3.) Defendants “have failed to
provide any responses or documents.”
(Choi Decl., ¶ 14.)
Metro and
Nowaid also disobeyed orders imposing monetary sanctions. On May 23, 2024, the court ordered Metro and
its counsel to pay $750 in sanctions and ordered Nowaid and his counsel to pay
$625 in sanctions. (Choi Decl., Ex. 2,
p. 2.) On July 1, 2024, the court
ordered Metro and its counsel to pay $1,050 in sanctions and ordered Nowaid and
his counsel to pay $625 in sanctions.
(Choi Decl., Ex. 3, p. 3.)
Plaintiff’s counsel testifies that neither Metro, Nowaid, nor their
counsel have paid any of the monetary sanctions ordered. (Choi Decl., ¶¶ 11, 14.)
Appropriate Sanctions
Discovery sanctions should be imposed
incrementally, “starting with
monetary sanctions and ending with
the ultimate sanction of termination.” (Lopez
v. Watchtower Bible & Tract Society of New York, Inc. (2016) 246
Cal.App.4th 566, 604.) Appropriate sanctions are those “such as are
suitable and necessary to enable the party seeking discovery to obtain the
objects of the discovery he seeks, but [not] which are designed not to
accomplish the objects of discovery but to impose punishment.” (Laguna Auto Body v. Farmers Ins. Exchange (1991)
231 Cal.App.3d 481, 488.)
Terminating sanctions are appropriate.
Lesser sanctions have been ineffective to curb Metro and
Nowaid’s misuse of the discovery process.
The monetary sanctions had no effect.
Plaintiff has been unable to accomplish the objects of discovery. “The
purpose of discovery is to make trial ‘ “less a game of blindman’s bluff and
more a fair contest with the basic issues and facts disclosed to the fullest
practicable extent.” ’ ” (Reales
Investment, LLC v. Johnson (2020) 55 Cal.App.5th 463, 473.) Metro and Nowaid have not complied with their
discovery obligations. They disobeyed
the court’s orders compelling them to do so.
Their misuse of the discovery process has prevented plaintiff from
conducting discovery. Absent
terminating sanctions, plaintiff would face trial by surprise. Under these circumstances, the court finds
terminating sanctions appropriate. The
court therefore will strike Metro and Nowaid’s answer and enter their
defaults. The court will also strike
Metro’s first amended cross-complaint.
The court
exercises its discretion not to impose additional monetary sanctions on Metro
and Nowaid.
Disposition
Plaintiff The People of the State of
California’s motion for terminating sanctions against defendants Metro
Investments Group, Inc. and Anthony Nowaid is granted.
The court hereby strikes the verified
answer of defendants Metro Investments Group, Inc. and Anthony Nowaid. The court hereby enters the defaults
of defendants Metro Investments Group, Inc. and Anthony Nowaid. The court hereby strikes the first
amended cross-complaint by defendant/cross-complainant Metro Investments Group,
Inc. as against plaintiff/cross-defendant The People of the State of
California.