Judge: Barbara M. Scheper, Case: 23STCV21726, Date: 2024-10-16 Tentative Ruling




Case Number: 23STCV21726    Hearing Date: October 16, 2024    Dept: 30

Dept. 30

Calendar No.

Macri vs. Guseinov, et. al., Case No. 23STCV21726

Tentative Ruling re: Plaintiff’s Motion to Compel Further Discovery Responses

 

Lucrezia Macri (Plaintiff) moves for an order compelling International Equity Partners, LLC (Defendant) to answer Plaintiff’s special interrogatories, set one, propounded on October 26, 2023. (Astanehe Decl. ¶ 3.) Defendant produced allegedly deficient responses on February 23, 2024. (Id. ¶ 5.) Plaintiff also seeks monetary sanctions for attorney fees and costs incurred relating to this motion, pursuant to Code of Civil Procedure Section 2030.290. The motion is granted in part. The Court does not award sanctions.

 

A party may move for an order compelling a further response to an interrogatory if: (1) an answer to a particular interrogatory is deemed evasive or incomplete; (2) documents produced pursuant to section 2030.230 are unwarranted or not sufficiently specified; or (3) an objection to an interrogatory is meritless or overly general. (Code Civ. Proc., § 2030.300, subd. (a).) Such a motion must be accompanied by a meet and confer declaration under section 2016.040. (Id., § 2030.300, subd. (b)(1).) Any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further responses is subject to monetary sanctions, unless they acted with substantial justification. (Id., § 2030.300, subd. (d).)

 

Defendant provided objections and substantive responses to interrogatories 17–20, 28, 34, 36, 56, and 63. Plaintiff must show these objections are meritless and that Defendant’s answer is evasive or incomplete. (Id., § 2030.300, subd. (a)(1), (3).) Defendant provided objections and documents as allowed under section 2030.230 to interrogatories 8, 9, 12, 14, 37, and 52. Plaintiff must show these objections are meritless and that the documents provided were insufficiently specified to permit Plaintiff to locate the answer. (Id., §§ 2030.300, subd. (a)(3), 2030.230.) Defendant provided only objections to interrogatories 6, 7, 10, 48, 49, and 66. Plaintiff need only show that these objections are meritless or overly general to compel further responses. (Id. § 2030.300, subd. (a)(3).)

Interrogatories 17–20, 28, 34, 36, 56, and 63

            Plaintiff deems Defendant’s responses to interrogatories 17–20, 28, 34, 36, 56, and 63 insufficient. Defendant provided substantive responses and objections. Thus, Plaintiff must both demonstrate that the answer is evasive or incomplete and that the objections are meritless. (Id., § 2030.300, subd. (a)(1), (3).)

            Interrogatories 17–20 pertain to the number of units, separate front door, separate address, and separate water service at the dwelling. (Plaintiff’s Separate Statement pp. 19–25.) Defendant explains that the dwelling is a single-family unit. Thus, it is one unit, has a front door, has one address, and does not have a separate water service. These responses are complete and not evasive.

            Interrogatory 28 requires Defendant to identify all communications relating to Plaintiff’s tenancy at the home from 2015 until present day. (Id. at pp. 25–28.) Plaintiff began her tenancy in 2022. Defendant has produced text messages and communications from 2022 onward with Plaintiff concerning her tenancy. Plaintiff argues that the production of documents is insufficient, but the interrogatory specifically requests communications. Thus, this response is complete and not evasive.

            Interrogatory 34 requires Defendant to identify all habitability defects in the home from 2010 until the start of Plaintiff’s tenancy. (Id. at pp. 28–30.) Defendant does not identify any defects and instead produces government records concerning the property. This response is incomplete and evasive. Defendant objects that this interrogatory is overbroad, burdensome, and harassing, reasoning that defects in the property from 14 years ago are not relevant to Plaintiff’s case. Defendant also points to the government records provided as sufficient because they identify the information sought. However, not every defect in the home need have been resolved in a manner that would produce a government record. Defendant’s responsive documents are thus insufficient. Nevertheless, Defendant’s objection to the interrogatory as overbroad is well taken. Finding information relating to every possible issue with the property in the last 14 years could be a daunting task. Plaintiff does not identify any reason for requesting records concerning every defect since 2010 in her Separate Statement. Thus, Defendant’s objection to the interrogatory as overbroad and burdensome is sustained.

            Similarly, interrogatory 36 requires Defendant to produce all documents related to habitability defects in the home from 2015 until the present. (Id. at pp. 30–33.) This interrogatory is overbroad for the same reasons. Once again, Plaintiff does not offer justification.

            Interrogatory 56 asks Defendant to describe all actions taken to legalize the property. (Id. at pp. 40–42.) Defendant responded that he was unaware of any requirement to legalize any portion of the property. Interrogatory 56 only requires a response if Defendant affirmatively responds to interrogatory 55. (Defendant’s Separate Statement p. 51.) Defendant answered interrogatory 55 the same way. Thus, interrogatory 56 did not require any response from Defendant given that he did not affirm interrogatory 55. Thus, Defendant offered a complete and non-evasive response.

            Interrogatory 63 asks Defendant to state his reasons for placing a “for rent” sign in the front yard during Plaintiff’s tenancy. (Plaintiff’s Separate Statement pp. 42–43.) Defendant answered that he did so because the property was for rent. This answers the question.  Defendant’s response is complete and non-evasive.

 

Interrogatories 8, 9, 12, 14, 15, 37, and 52

            Plaintiff deems Defendant’s responses to interrogatories 8, 9, 12, 14, 37, and 52 insufficient as well. Defendant provided documents and objections. Plaintiff must show that the documents are insufficient or not properly specified, and that any objections are meritless. (Code Civ. Proc., §§ 2030.300, subd. (a)(3), 2030.230.)

            Interrogatory 8 asks Defendant to identify all persons who performed repair work on the property from 2015 until the present. (Plaintiff’s Separate Statement pp. 5–7.) Similarly, interrogatory 12 asks Defendant to identify all persons who inspected the subject property during the same period. (Id. at pp. 12–14.) Defendant provides “government records” without specifying which records contain the required names. Thus, Defendant’s responses are incomplete, and the records produced are insufficiently specified. Defendant’s objections that the interrogatories are unduly burdensome is without merit. Property managers regularly keep records of repair work and inspections. Producing those records, or the relevant names, is not overly burdensome or unreasonable. Thus, Defendant is compelled to provide further responses to these interrogatories.

 

            Interrogatory 9 asks Defendant to describe all habitability defects on the property from 2015 until the present. (Id. at pp. 7–10.) This interrogatory is overbroad for the same reasons as interrogatories 34 and 36.

            Interrogatory 14 directs Defendant to identify all certificates of occupancy relating to the property. (Id. at pp. 14–16.) Plaintiff’s request is relevant, as it would help her identify when the home had previously been occupied. Defendant claims that his proffered government records contain the information sought by Plaintiff but does not identify where in the records that information is located. Defendant is compelled to identify which submitted records contain the information or provide a further response to interrogatory 14.

Interrogatory 15 similarly directs Defendant to identify certificates of occupancy relating to the unit. (Id. at pp. 16–19.) Since the property is a single unit, this interrogatory is duplicative, and no further response is required.

            Interrogatory 37 asks Defendant to identify all complaints made to him by Plaintiff. (Id. at pp. 33–35.) Defendant has provided all communications between himself and Plaintiff. These would include all complaints made by Plaintiff. Plaintiff has not indicated otherwise, rather objecting to the specificity of the unrelated government records submitted by Defendant. Because the submitted communications are between Plaintiff and Defendant, Plaintiff is just as capable of identifying the relevant information as Defendant.

Interrogatory 52 asks Defendant to identify all communications with Plaintiff regarding her security deposit. (Id. at pp. 38–40.) Defendant’s provision of all communications between himself and Plaintiff are sufficient for the same reasons. Thus, Defendant has submitted documents sufficient to satisfy these interrogatories.

 

Interrogatories 6, 7, 10, 48, 49, and 66

Plaintiff deems Defendant’s responses to interrogatories 6, 7, 10, 48, 49, and 66 insufficient. Defendant provided only objections to these interrogatories. Thus, Plaintiff need only show that these objections are meritless or overly general to compel further responses. (Id. § 2030.300, subd. (a)(3).)

Interrogatory 6 instructs Defendant to identify all occupants of the home from 2015 to the present. (Plaintiff’s Separate Statement pp. 2–3.) Interrogatory 7 asks Defendant to describe each former occupant’s reason for vacating the home. (Id. at pp. 3–5.) Interrogatory 10 instructs Defendant to identify all complaints from previous tenants pertaining to water intrusion at the property. (Id. at pp. 10–11.) Interrogatory 48 requires a description of the occupancy history of the property, while interrogatory 49 requires a description of how Defendant used the upstairs unit. (Id. at pp. 35–38.) Interrogatory 66 asks Defendant to identify the name of the occupants he told Plaintiff he would lease the home to in November 2022. (Id. at pp. 43–44.)

Defendant objects to all these interrogatories on the ground that they violate the California Constitution’s right to privacy. “Even when discovery of private information is found directly relevant to the issues of ongoing litigation, it will not be automatically allowed; there must then be a careful balancing of the compelling public need for discovery against the fundamental right of privacy.” (Davis v. Superior Court (1992) 7 Cal.App.4th 1008, 1014.) Where privacy rights are implicated, the scope of discovery must be circumscribed and specific, proceeding in the least intrusive manner possible. (Ibid.) Information is deemed private when well-established social norms recognize the need for an individual to have control over its dissemination to prevent embarrassment. (Pioneer Electronics (USA), Inc. v. Superior Court (2007) 40 Cal.4th 360, 370.)

Plaintiff’s interrogatories 6, 48, and 66 require the Defendant to identify previous tenants. (Plaintiff’s Separate Statement pp. 2–3, 35–37, 43–44.) There is no privacy protection for the identity, address, or contact information of percipient witnesses. “[A] percipient witness’s willingness to participate in civil discovery has never been considered relevant — witnesses may be compelled to appear and testify whether they want to or not.” (Puerto v. Superior Court (Wild Oats Markets, Inc.) (2008) 158 Cal.App.4th 1242, 1251–1252.) Plaintiff likely seeks the identities of previous tenants to garner testimony about previous issues with the property. Those individuals’ privacy rights are not implicated by the requested disclosure of their identities as potential percipient witnesses. Thus, Defendant is compelled to answer interrogatories 6, 48, and 66.

Plaintiff’s interrogatories 7 and 10 require the Defendant to disclose previous tenants’ reasons for leaving (Plaintiff’s Separate Statement pp. 3–5) and complaints regarding water intrusion (id. at pp. 10–11). A person’s reasons for leaving a property or their complaints about that property are not generally recognized as private information. Defendant points to no well-established social norms recognizing a need for discretion regarding this information. Because no privacy interest is implicated, Defendant is compelled to respond to these interrogatories as well.

Interrogatory 49 follows the same analysis. Plaintiff asks Defendant to describe how he used the upstairs portion of the property from 2015 to the present. (Id. at pp. 37–38.) There is no well-established social norm regarding this information. Additionally, Defendant’s objection that the interrogatory is too vague is unfounded. Thus, Defendant is compelled to respond.

Accordingly, Defendant is ordered to respond to interrogatories 6, 7, 8, 10, 12, 48, 49, and 66. Defendant is additionally compelled to identify with specificity the submitted documents addressing interrogatory 14.

Monetary Sanctions

“[T]he 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 response to a demand for inspection, copying, testing, or sampling, 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. If a party then fails to obey the order compelling a response, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). In lieu of or in addition to this sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010).” (Code Civ. Proc., § 2031.300, subd. (c).)

 

Here, both Plaintiff’s motion to compel and Defendant’s opposition were warranted. Thus, the Court does not award sanctions.