Judge: Curtis A. Kin, Case: 21STCV40805, Date: 2023-03-23 Tentative Ruling

Case Number: 21STCV40805    Hearing Date: March 23, 2023    Dept: 72

MOTIONS(3) FOR ISSUE

AND MONETARY SANCTIONS (3)

  

Date:               3/23/23 (8:30 AM)

Case:               12 Albany, LLC v. OG Farmz, Inc. et al. (21STCV40805)

  

TENTATIVE RULING:

 

Plaintiff 12 Albany, LLC’s UNOPPOSED Motion for Issue and Monetary Sanctions against Defendant Chong Sang Eric Tak is GRANTED IN PART.

 

Plaintiff 12 Albany, LLC’s UNOPPOSED Motion for Issue and Monetary Sanctions against Defendant OG Farmz, Inc. is GRANTED IN PART.

 

Plaintiff 12 Albany, LLC’s UNOPPOSED Motion for Issue and Monetary Sanctions against Defendant The One1 Entertainment, Inc. is GRANTED IN PART.

 

Plaintiff 12 Albany, LLC moves for issue sanctions against defendants Chong Sang Eric Tak, OG Farmz, Inc., and The One1 Entertainment, Inc. based on the violation of a court order compelling responses to discovery.

 

On December 13, 2022, the Court granted plaintiff’s motions to compel responses from defendants to Form Interrogatories-General, Set One. (Chung Decls. ¶¶ 4 & Exs. B.) Defendants did not file any opposition to the motions. (12/13/22 Minute Order at 1.) The Court ordered defendants to serve written verified responses, without objection, to their respective Form Interrogatories-General, Set One within 15 days. (Id.) Defendants did not attend the hearing on December 13, 2022. However, plaintiff served notice of the ruling on defendants. (Id.) The responses were due on December 30, 2022. (See CCP § 1010.6(a)(3)(B) [two court days added with email service of notice].) On January 6, 2023, having received no responses, plaintiff attempted to meet and confer with defendants concerning the missing responses. (Chung Decls. ¶¶ 6 & Ex. 6.) 

 

Despite service of the notice of ruling and plaintiff’s attempt to meet and confer, defendants have not served responses to plaintiff’s discovery ordered by the Court on December 13, 2022. (Chung Decls. ¶¶ 7.)

 

After the Court issues an order compelling a response to interrogatories, if the party fails to comply with the order, the Court may make orders that are just, including the imposition of an issue sanction. (CCP § 2030.290(c).) “The court may impose an issue sanction ordering that designated facts shall be taken as established in the action in accordance with the claim of the party adversely affected by the misuse of the discovery process.” (CCP § 2023.030(b).)

 

A court may impose issue sanctions that are “properly tailored to the specific harm caused by such withheld discovery.” (Vallbona v. Springer (1996) 43 Cal.App.4th 1525, 1548.) “Only two facts are absolutely prerequisite to imposition of [a discovery] sanction: (1) there must be a failure to comply…and (2) the failure must be wilful [citation].” (Calvert Fire Ins. Co. v. Cropper (1983) 141 Cal.App.3d 901, 904.)

 

Here, the Court finds that, under the circumstances, defendants’ failure to respond to the discovery as ordered by the Court was willful. Simply put, defendants failed to respond to plaintiff’s form interrogatories initially, failed to oppose plaintiff’s motions to compel responses to such interrogatories, and further failed to produce responses to the subject interrogatories after having been served notice of the Court’s order to respond and after plaintiff attempted to meet and confer regarding the interrogatories. 

 

Accordingly, the Court finds that issue sanctions appropriately tailored to the violation at issue are warranted. Plaintiff’s requested issue sanctions correspond to the contents of Form Interrogatory Nos. 15.1 and 50.1, which were served on defendants, and accordingly are tailored to the harm caused by defendants’ failure to respond. (Chung Decls. ¶ 2 & Exs. A.)

 

As set forth in plaintiff’s Memorandum of Points and Authorities, the Court designates the following facts as established in the instant action:

 

1.                  The Loan and Security Agreement (Exhibit A to Complaint) is a true and correct copy of an agreement entered into between plaintiff 12 Albany, LLC, on the one hand, and defendants Chong Sang Eric Tak and OG Farmz, Inc., on the other hand.

 

2.                  The Term Promissory Note (Exhibit B to Complaint) is a true and correct copy of an agreement entered into between plaintiff 12 Albany, LLC, on the one hand, and defendants Chong Sang Eric Tak and OG Farmz, Inc., on the other hand.

 

3.                  The Revolving Promissory Note (Exhibit C to Complaint) is a true and correct copy of an agreement entered into between 12 Albany, LLC, on the one hand, and defendants Chong Sang Eric Tak and OG Farmz, Inc., on the other hand.

 

4.                  There are no parts of the Loan and Security Agreement (Exhibit A to Complaint), Term Promissory Note (Exhibit B to Complaint) and Revolving Promissory Note (Exhibit C to Complaint) (collectively, “Agreements”) that are not in writing.

 

5.                  There are no documents that evidence any parts of the Agreements that are not in writing.

 

6.                  There are no documents that are part of any modification to the Agreements.

 

7.                  There are no modifications to the Agreements that are not in writing.

 

8.                  There are no documents that evidence any modifications to the Agreements that are not in writing.

 

9.                  Defendants Chong Sang Eric Tak and OG Farmz, Inc. breached the Agreements by failing and refusing to pay the principal balance of $340,000 when due.

 

10.              Defendants Chong Sang Eric Tak and OG Farmz, Inc.’s performance under the Agreements were not excused.

 

11.              The Agreements were not terminated by mutual agreement, release, accord and satisfaction, nor novation.

 

12.              The Agreements are fully enforceable.

 

13.              The Agreements are not ambiguous.

 

14.              Defendants Chong Sang Eric Tak, OG Farmz, Inc., and The One1 Entertainment, Inc. do not raise any special defense in this Action.

 

15.              Defendants Chong Sang Eric Tak, OG Farmz, Inc., and The One1 Entertainment, Inc. do not raise any affirmative defense in this action.

 

16.              There are no facts to support any denial or special or affirmative defense in this action.

 

17.              There are no documents or other tangible things to support any denial or special or affirmative defense in this action.

 

With respect to the first, second, third, ninth, and tenth issue sanctions listed above, plaintiff seeks to designate the facts set forth therein with respect to defendant The One1 Entertainment, Inc. Form Interrogatory No. 50.1, the interrogatory which corresponds to these sanctions, pertains to “each agreement alleged in the pleadings.” (Chung Decls. ¶ 2 & Ex. A.) However, there is no agreement alleged between plaintiff and The One1 Entertainment, Inc. The Agreements are between plaintiff and defendants OG Farmz, Inc. and Tak. (Compl. ¶¶ 10-12.) The first cause of action asserting breach of the Agreements is asserted against OG Farmz, Inc. and Tak, not The One1 Entertainment, Inc. (Compl. at 13:26.) Accordingly, the Court imposes the first, second, third, ninth, and tenth issue sanctions listed above against OG Farmz, Inc. and Tak only.

 

Plaintiff also seeks to establish that all defendants do not deny any material allegation contained in the Complaint. However, each defendant filed an Answer in which such defendant generally denied each and every allegation of the Complaint. (See 2/4/22 Tak Answer; 2/28/22 The One1 Answer; 2/7/22 The One1 Answer.) The three Answers remain operative. Accordingly, the requested issue sanction would conflict with the general denial contained in the Answers and would constitute an overbroad remedy in view of the conduct to be sanctioned.  The Court therefore declines to impose any issue sanction establishing that defendants do not deny any material allegation in the Complaint.

 

For the foregoing reasons, the motions are GRANTED IN PART. Issue sanctions are imposed as set forth above.

 

For continuing to fail to comply with discovery obligations and court orders, thereby causing plaintiff to file these three motions, the Court also imposes monetary sanctions on each defendant as follows:

 

·                     $661.67 against defendant Chong Sang Eric Tak

·                     $661.67 against defendant OG Farmz, Inc.

·                     $661.67 against defendant The One1 Entertainment, Inc.

 

The monetary sanctions are based on 1.5 hours of attorney Jay J. Chung’s time preparing all three motions (instead of 1 hour for each motion) at an hourly rate of $550, 3 hours for the time associates spent in preparing the motion (instead of 2 hours for each motion) at an hourly rate of $295, and 0.5 hours of attorney Chung’s time preparing a notice of non-opposition and preparing for and attending the hearing for all three motions (instead of 1 hours per motion for preparing a reply and preparing for and attending the hearing) at an hourly rate of $550. The total sanctions are allocated equally among each of the three defendants.

 

Monetary sanctions shall be paid to counsel for plaintiff 12 Albany, LLC within 30 days hereof.