Judge: Cherol J. Nellon, Case: 24STCV01477, Date: 2025-03-13 Tentative Ruling

Case Number: 24STCV01477    Hearing Date: March 13, 2025    Dept: 14

#6

Case Background

This is an action for negligence, products liability, fraudulent concealment, breach of implied warranties, and loss of consortium. Plaintiff alleges he fell ill after inhaling toxic dust generated by stone products manufactured and distributed by Defendants.

On January 19, 2024, Plaintiff Cesar Manuel Gonzalez Quiroz filed his Complaint against a large number of Defendants.

On February 22, 2024, Plaintiff filed a First Amended Complaint.

On May 28, 2024, Plaintiff filed a Second Amended Complaint (SAC).

On September 20, 2024, Plaintiff filed a Third Amended Complaint (TAC).

On February 24 and 26, 2025, Plaintiff filed motions to compel depositions of persons most knowledgeable (PMKs) of Defendants Mohawk Industry, Inc. (Mohawk), Dal-Tile LLC and Dal-Tile Distribution LLC (collectively “Dal-Tile”), and San Fernando Marble & Granite, Inc. (SFMG).

On February 27, 2025, Thomas Crawford filed an application to appear pro hac vice on behalf of Defendant BMosaics, Inc.

On March 6, 2025, the affected Defendants filed oppositions.

On March 10, 2025, Plaintiff filed replies.

Instant Pleading

Counsel Thomas M. Crawford moves to appear pro hac vice for Defendant BMosaics, Inc. (BMosaics).

Plaintiff moves to compel the depositions of the PMKs of Defendants Mohawk, Dal-Tile, and SFMG.

Decision

The petition to appear pro hac vice filed by Counsel Thomas M. Crawford is GRANTED.

The motion to compel the depositions of PMKs of Defendants Mohawk and Dal-Tile are GRANTED. Mohawk and Dal-Tile are ordered to produce their PMKs for deposition within 10 days of this order.

Because Plaintiff’s motions were substantially similar and straightforward, Plaintiff’s request for sanctions is excessive. The Court awards Plaintiff $1,360 each from Mohawk and the two Dal-Tile Defendants for two hours of attorney time at a rate of $250 per hour and filing fees. Defendants Dal-Tile LLC, Dal-Tile  Distribution, LLC, and Mohawk Industry, Inc. are to pay $1,360 each to Plaintiff Cesar Manuel Gonzalez Quiroz within 20 days of this order.

The motion to compel the deposition on SFMG’s PMK is DENIED.

Discussion

1.     Pro Hac Vice

Counsel Thomas M. Crawford moves to appear pro hac vice for Defendant BMosaics.

Crawford attests to his residence address and office address, which are in Colorado and Illinois respectively. (Crawford Decl., ¶¶ 2-3.) He attests to all the courts he has been admitted to (with dates of admission), that he is in good standing with the State Bar of Illinois and Maryland, and that he is not currently suspended or disbarred from practice in any court. (Id. at ¶¶-6.) Crawford submits the name and address of the active California State Bar member with whom he is associated. (Id. at ¶ 8.) He also attests that he has appeared as counsel pro hac vice once in the state court of California in the last two years. (Id. at ¶7.) Further, Ashley Morris, BMosaic’s local counsel, testifies the requisite fee was sent to the State Bar of California, and the Notice of Hearing and the instant application were served on all interested parties and on the State Bar of California. (Morris Decl., ¶¶7-8.)

The application is GRANTED. Counsel Crawford has complied with California Rules of Court Rule 9.40.

 

2.     Motions to Compel Deposition

Plaintiff moves to compel the depositions of PMKs for Defendants Mohawk, Dal-Tile, and SFMG.

Legal Standard

Any party may obtain discovery, subject to restrictions, by taking the oral deposition of any person, including any party to the action. (Code Civ. Proc., section 2025.010.) A party desiring to take an oral deposition shall give a notice in writing which states the specification of reasonably particularly of any materials to be produced by the deponent. (Code Civ. Proc., section 2025.220, subd. (a)(4).) A properly served deposition notice is effective to require a party to attend and to testify, as well as to produce documents for inspection and copying. (Code Civ. Proc., section 2025.280, subd. (a).) A party served with a deposition notice waives any error or irregularity unless that party promptly serves a written objection at least three calendar days prior to the date for which the deposition is scheduled. (Code Civ. Proc., section 2025.410, subd. (a).)

“If, after service of a deposition notice, a party to the action … without having served a valid objection … fails to appear for examination, or to proceed with it, or to produce for inspection any document, … described in the deposition notice, the party giving the notice may move for an order compelling the deponent's attendance and testimony, and the production for inspection of any document … described in the deposition notice.” (Code Civ. Proc., section 2025.450, subd. (a).) 

If a motion to compel deposition is granted, sanctions are mandatory in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. Proc., section 2025.450, subd. (g)(1).) Sanctions may be imposed for misuse of discovery process. (Code Civ. Proc., section 2023.030, subd. (a).)

Mohawk and Dal-Tile

Plaintiff’s counsel testifies that she served deposition notices on Mohawk and the two Dal-Tile entities on January 6, 2025. (Maneker Decl., ¶2.) All three Defendants objected to the notice and the deposition did not proceed. (Id.) Plaintiff’s counsel served a second deposition notice on Mohawk and Dal-Tile on January 24, 2025. (Id., ¶3.) The depositions did not take place due to the three Defendants’ unavailability. (Id.) The Defendants’ counsel failed to provide deposition dates despite Plaintiff’s counsel’s requests for dates. (Id., ¶¶6-9.) Although the parties discussed stipulating to using deposition testimony from prior depositions in other cases, the parties never agreed on a stipulation. (Id., ¶¶10-11.) The depositions seek information about whether these entities sold artificial stone slabs to Plaintiff’s hirers, whether they knew of the hazards of silica, and other relevant information. (Id., ¶¶14 or 15.)

In opposition, Mohawk and Dal-Tile argue that there is no evidence that Plaintiff was ever exposed to an artificial stone product they were responsible for. Mohawk and Dal-Tile argue that Plaintiff does not need their PMK depositions because Plaintiff has already taken these depositions in other cases and already dismissed these defendants in other cases. However, Dal-Tile and Mohawk’s liability is still in dispute in this case. Mohawk and Dal-Tile’s belief that they are not liable for Plaintiff’s injuries is no reason to refuse to participate in discovery. Even if the same PMKs have been deposed in other silicosis cases, Plaintiff has a right to obtain discovery through oral depositions in this case and the parties have not stipulated to using previous testimony.

Mohawk and Dal-Tile also argue Plaintiff did not meet and confer properly before filing these motions. However, Plaintiff did request deposition dates from Mohawk and Dal-Tile without success before filing these motions. Although the Court normally requires parties to participate in an IDC before filing discovery motions, trial preference was granted in this matter and no IDC dates were available before trial. The Court granted Plaintiff’s ex parte motion to advance the hearing dates on these motions despite the lack of an IDC. The Court finds Plaintiff properly filed the motions.

Because Mohawk and the two Dal-Tile entities failed to proceed with their properly noticed depositions, Plaintiff’s motions to compel the depositions are GRANTED.

Because Plaintiff’s motions were substantially similar and straightforward, Plaintiff’s request for over $3,000 in sanctions from each Defendant is excessive. The Court awards Plaintiff $1,360 each from Mohawk and the two Dal-Tile Defendants for two hours of attorney time at a rate of $250 per hour and filing fees.

SFMG

Plaintiff also moves to compel the deposition of SFMG’s PMK. The parties agree that SFMG has provided deposition dates, March 11 and 13, 2025, since the date this motion was filed. However, Plaintiff represents he will not withdraw the motion to compel until the depositions have concluded. Assuming SFMG produced its PMK for deposition, the motion is denied. The Court does not find under the circumstances that sanctions are justified here because SFMG ultimately produced its PMK for deposition.

Conclusion

The petition to appear pro hac vice filed by Counsel Thomas M. Crawford is GRANTED.

The motion to compel the depositions of PMKs of Defendants Mohawk and Dal-Tile are GRANTED. Mohawk and Dal-Tile are ordered to produce their PMKs for deposition within 10 days of this order.

Because Plaintiff’s motions were substantially similar and straightforward, Plaintiff’s request for sanctions is excessive. The Court awards Plaintiff $1,360 each from Mohawk and the two Dal-Tile Defendants for two hours of attorney time at a rate of $250 per hour and filing fees. Defendants Dal-Tile LLC, Dal-Tile  Distribution, LLC, and Mohawk Industry, Inc. are to pay $1,360 each to Plaintiff Cesar Manuel Gonzalez Quiroz within 20 days of this order.

The motion to compel the deposition on SFMG’s PMK is DENIED.