Judge: Douglas W. Stern, Case: 22STCV36344, Date: 2023-11-09 Tentative Ruling

Case Number: 22STCV36344    Hearing Date: November 22, 2023    Dept: 68

Motion to Compel Further Responses to Special Interrogatories (Set One) and Request for Sanctions (1016 Industries, Inc.)

Motion to Compel Further Responses to Special Interrogatories (Set One) and Request for Sanctions (Peter Northrop)

Giavanna Papasavvas vs. 1016 Industries, Inc., et al., 22STCV36344

Moving Parties: Defendants 1016 Industries, Inc. and Peter Northrop

Motion

            Defendants 1016 Industries, Inc., and Peter Northrop (Defendants) filed these motion after Plaintiff Giavanna Papasavvas (Plaintiff) objected to some of their special interrogatories and did not provide what Defendants considered to be full and complete responses.

For Defendant 1016 Industries, the relevant Special Interrogatories are Nos. 3, 17, 19, and 20.  Defendant filed this motion pursuant to CCP §§ 2030.300 and 2023.010. Defendant filed the motion on October 25, 2023. At some point prior to Defendant filing the motion, Plaintiff supplemented her responses to some of the interrogatories. 1016 Industries has requested sanctions in the amount of $8,183.00 against Plaintiff for having to bring the motion.

For Defendant Peter Northrop, the relevant Special Interrogatories are Nos. 3, 5, 19-23, 25, 27, 29, 31, 33, 37, and 39-40. Defendant filed this motion pursuant to CCP §§ 2030.300 and 2023.010. Defendant filed the motion on October 25, 2023. Prior to Defendant filing the motion, Plaintiff supplemented some of her responses. Northrop requested sanctions in the amount of $20,232.00 for having to bring the motion.

In Plaintiff’s oppositions to Defendants’ motions, Plaintiff argues that she responded to the requests in full and did not withhold any information. She argues that she answered in a straightforward manner, and the additional responses requested by Defendants go beyond what is asked in the interrogatories. Plaintiff also disputes the sanctions requested by Defendants.

Defendants argue in their replies that Plaintiff’s responses are inadequate. Defendants also argue that Plaintiff failed to substantiate her objections.

An Observation

Plaintiff has made allegations against Defendants which are the subject of this discovery.  Should this case go to trial, Plaintiff shall be obligated to prove the allegations she has made.  Undoubtedly she shall attempt to do more than merely parrot the conclusory statements in the complaint which are the subject of this discovery.  Yet much of her present responses merely repeat the allegations of the Complaint without providing details that have been requested.  Presumably Plaintiff shall desire to provide detail regarding the events she claims took place when she is  called upon to prove her case at trial.  Yet she does not provide that detail now in response to most of the discovery.

The Court notes that details not disclosed in discovery by a party when such details have been sought may result in the Court precluding the party from introducing the undisclosed information at trial.  Therefore the parties may deem it appropriate to provide full and complete responses to discovery.

Defendant 1016 Industries’ Motion

            Special Interrogatories:

                        Special Interrogatory No. 3:

            “Describe all of your responsibilities and obligations related to your employment by 1016 Industries, Inc.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad and seeks information in the possession of the propounding party.

 Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

When Plaintiff began working for Defendants 1016 Industries Inc. and Peter Northop in February 2021, she was providing influencer services. In approximately May 2022, she was given the title, “brand manager” and began engaging in marketing and sales. Plaintiff would also often attend events on behalf of the company.

            Finding of the Court: Plaintiff does not say what any of her responsibilities were for the company. She only gives her job title and the vague description of “influencer services.” Plaintiff must expand her answer to this Interrogatory.

            Defendant’s motion to compel further response to Interrogatory No. 3 is GRANTED.

                        Special Interrogatory No. 17:

            “Describe all facts supporting your allegation in paragraph 19 of the complaint that “Plaintiff was an employee of Defendants and/or DOES 1-20 and covered by California Government Code section 12940 et seq. (‘FEHA’).””

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, calls for a legal conclusion, calls for an expert opinion, lacks reasonable particularity, and seeks premature disclosure of expert testimony.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff was an individual under the direction and control of her employer(s), Defendants 1016 and Peter Northrop. When Plaintiff began working for Defendants 1016 Industries Inc. and Peter Northop in February 2021, she was providing influencer services. In approximately May 2022, she was given the title, “brand manager” and began engaging in marketing and sales. Defendants had the right to control how Plaintiff performed the work, and the services performed by Plaintiff were to be performed over a long period of time. Defendants supplied Plaintiff with a vehicle and oftentimes the place of work, and Defendant Northrop expressed to Plaintiff that there was an employer-employee relationship between Plaintiff and Defendants.

            Finding of the Court: Defendant is asking Plaintiff to describe why her case is covered by California’s FEHA. Plaintiff has not done so. Instead, she just repeats part of her answer to a previous question. Plaintiff must answer Defendant’s question regarding FEHA.

            Defendant’s motion to compel further response to Interrogatory No. 17 is GRANTED.

                        Special Interrogatory No. 19:

            “How much money do you claim 1016 Industries, Inc. owes you by reason of the allegations in the complaint?”

            Plaintiff’s amended response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, harassing, calls for speculation, calls for a legal conclusion, calls for an expert opinion, lacks reasonable particularity, and seeks premature disclosure of expert testimony.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff incorporates by reference, her response to Form Interrogatory 8.6, 8.7, and 8.8, in which Plaintiff provides information regarding her lost wages. Plaintiff seeks general damages, special damages, compensatory and consequential damages, punitive damages, attorney’s fees costs of suit, and any other and further relief the Court deems proper and just.

            Finding of the Court: Defendant appears to be asking for a dollar figure. To the extent that Plaintiff can quantify what she is requesting, she should do so, even if it is just an estimate at this point.

            Defendant’s motion to compel further response to Interrogatory No. 19 is GRANTED.

                        Special Interrogatory No. 20:

            “Describe how you calculated the amount of money stated in your response to the special interrogatory immediately preceding this one.”

            Plaintiff’s amended response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, harassing, calls for speculation, calls for a legal conclusion, calls for an expert opinion, lacks reasonable particularity, and seeks premature disclosure of expert testimony.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff incorporates by reference, her response to Form Interrogatory 8.6, 8.7, and 8.8, in which Plaintiff provides information regarding her lost wages. Plaintiff seeks general damages, special damages, compensatory and consequential damages, punitive damages, attorney’s fees, costs of suit, and any other and further relief the Court deems proper and just.

            Finding of the Court: For whatever dollar figure Plaintiff comes up with in her further response to Interrogatory 19, she should explain how she calculated that amount in response to this Interrogatory.

            Defendant’s motion to compel further response to Interrogatory No. 20 is GRANTED.

            Monetary Sanctions:

            The Court shall impose a monetary sanction…against a party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or circumstances make the imposition of the sanction unjust.” (CCP § 2030.300(d).)

            Defendant 1016 Industries has requested $8,183.00 in monetary sanctions against Plaintiff for having to bring this motion. Defendant’s attorney’s hourly rate is $495, and he stated that he will have spent 6 hours preparing the motion, reviewing the opposition, preparing a reply, and attending the hearing for a total of $2,970.00. (Ellis Decl., ¶ 13.) Defendant has also requested costs in the amount of $60.00. (Ellis Decl., ¶ 15.)

            Defendant’s attorney’s declaration contains a confusing paragraph about the amount of time that Defendant’s former counsel spent on a motion to compel further responses. (Ellis Decl., ¶ 14.) The billing amounts for these attorneys is how Defendant got to the $8,183.00 amount. The relevance of this paragraph is unclear, and Plaintiff objected to the paragraph on the grounds that it lacks foundation. The Court sustains Plaintiff’s objection to this paragraph.

            Because Plaintiff unsuccessfully opposed this motion, the Court will impose sanctions against Plaintiff in the amount of $3,030.00 ($2,970.00 plus the $60.00 filing fee).

Defendant Peter Northrop’s Motion

            Special Interrogatories:

                        Special Interrogatory No. 3:

            “Describe all of your responsibilities and obligations related to your employment by Peter Northrop.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad and seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

When Plaintiff began working for Defendants 1016 Industries Inc. and Peter Northop in February 2021, she was providing influencer services. In approximately May 2022, she was given the title, “brand manager” and began engaging in marketing and sales. Plaintiff would also often attend events on behalf of the company.

            Finding of the Court: As with the other motion, Plaintiff did not provide any description of her responsibilities and obligations. She must supplement this response.

            Defendant’s motion to compel further response to Interrogatory No. 3 is GRANTED.

                        Special Interrogatory No. 5:

            “Describe why your employment with Peter Northrop was terminated.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it calls for speculation and seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

On or about September 28, 2022, and in response to Plaintiff opposing the sexual harassment, discrimination, and retaliation that she was facing, Defendant Northop told Plaintiff that she was being disrespectful, and terminated Plaintiff’s employment.

            Finding of the Court: Plaintiff’s answer is sufficient. No further response is necessary.

                        Special Interrogatory No. 19:

            “State each date on which you allege that Peter Northrop had sexual contact with you.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that the term “sexual contact” is vague and ambiguous and on the grounds that this interrogatory is unintelligible and grossly overbroad. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff does not recall the exact dates that Peter Northrop ever made sexual contact with her over the course of over a year and a half. Peter Northrop made sexual contact with Plaintiff on many occasions beginning in February 2021 and throughout her employment with Defendants.

            Finding of the Court: If Plaintiff cannot recall then dates, then her answer is sufficient. No further response is necessary.

                        Special Interrogatory No. 20:

            “For each contact identified in the prior special interrogatory, state whether you consented to the sexual contact.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that the term “sexual contact” is vague and ambiguous and on the grounds that this interrogatory is unintelligible and grossly overbroad. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

No

            Finding of the Court: This was essentially a yes or no question. Plaintiff answered no. No further response is necessary.

                        Special Interrogatory No. 21:

            “State each date on which you allege that Peter Northrop had physical contact with you.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that the term “physical contact” is vague and ambiguous and on the grounds that this interrogatory is unintelligible and grossly overbroad. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff does not recall the exact dates that Peter Northrop ever made physical contact with her over the course of over a year and a half. Peter Northrop made physical contact with Plaintiff on many occasions beginning in February 2021 and throughout her employment with Defendants

            Finding of the Court: If Plaintiff does not recall the dates of the physical contact, then there is nothing that she can add to this response. No further response is necessary.

                        Special Interrogatory No. 22:

            “For each contact identified in the prior special interrogatory, state whether you consented to the physical contact.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that the term “physical contact” is vague and ambiguous. Plaintiff further objects that this interrogatory is unintelligible and grossly overbroad. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

No.

            Finding of the Court: This was a yes or no question. Plaintiff answered with “no.” No further response required.

                        Special Interrogatory No. 23:

            “Describe all facts supporting your allegation in paragraph 12 of the complaint that “Beginning in February 2021, Northrop began sexually harassing Plaintiff.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory is grossly overbroad, vague, and ambiguous as to time frame. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Beginning in February 2021, Northrop began sexually harassing Plaintiff, which included, but was not limited to, the following comments and acts:

a. Touching Plaintiff’s intimate parts, including her vagina, without her consent;

b. Forcing and/or coercing Plaintiff to stay in the same hotel room and/or bed as him during work events;

c. Poking Plaintiff’s buttocks with a banana without her consent;

d. Telling Plaintiff that he loves her;

e. Sending Plaintiff a text message stating that she is “the only girl [he] wants”;

f. Sending Plaintiff a text message stating that she is “the only girl [he] see[s] in [his] life”;

g. Sending Plaintiff a text message stating that she is the “Only one [he’s] wanted to change to be a man for”;

h. Letting Plaintiff know that he would not accept her declining his romantic advances by sending Plaintiff a text message that he is “never gonna be ok with friendship” with her; and

i. Sending Plaintiff inappropriate messages about his love and affection for her.

Plaintiff objected to Defendant Northrop’s harassing behavior and told him to stop. In further attempts to avoid the harassment at the hands of Defendant Northrop, but maintain her employment, Plaintiff, amongst other things, requested to have her own hotel room. During work events, requested to bring friends with her to work events so she could stay in a hotel room with them, and say she could not go unless she had her own room.

Defendant Northrop would respond to Plaintiff’s requests in erratic ways such as threatening to terminate her employment, threatening to take her car that she leased through him away, screaming and yelling at Plaintiff, banging on her hotel room door late at night if she had slept in a different hotel room, and/or sending Plaintiff inappropriate and harassing text messages.

Defendant Northrop’s conduct made Plaintiff feel uncomfortable, unsafe, and was unwelcome. Defendants never addressed or remedied the harassment, discrimination, or retaliation of which Plaintiff experienced.

On or about September 28, 2022, and in response to Plaintiff opposing the sexual harassment, discrimination, and retaliation that she was facing, Defendant Northop told Plaintiff that she was being disrespectful, and terminated Plaintiff’s employment. After terminating Plaintiff’s employment, Defendant Northrop continued to contact and further harass Plaintiff.

            Finding of the Court: Plaintiff’s response to this interrogatory is sufficient. No further response is necessary.

                        Special Interrogatory No. 25:

            “Describe all facts supporting your allegation in paragraph 12(a) of the complaint that Peter Northrop “[t]ouch[ed] Plaintiff’s intimate parts, including her vagina, without her consent” including by describing when and where (physical location) such touching occurred.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is vague and ambiguous and on the grounds that this interrogatory is unintelligible and grossly overbroad Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Defendant Northrop touched Plaintiff’s intimate parts in or around February 2021 at Race to Rally, in or around December 2021 at Art Basil, and in or around March 2022 at Legends Rally.

            Finding of the Court: Plaintiff’s allegations regarding Northrop’s nonconsensual touching are the heart of her complaint. Defendant has asked her to describe all facts surrounding those allegations. Plaintiff has only given vague dates and events in response. There is no indication of whether the alleged incidents happened in public, in private, or what any of the circumstances were surrounding the alleged nonconsensual touching. Plaintiff must supplement this response.

            Defendant’s motion to compel further response to Interrogatory No. 25 is GRANTED.

                        Special Interrogatory No. 27:

            “Describe all facts supporting your allegation in paragraph 12(b) of the complaint that Peter Northrop “[f]orc[ed] and/or coerc[ed] Plaintiff to stay in the same hotel room and/or bed as him during work events” including by describing when and where (physical location) this occurred”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Race to Rally, February 2021; Fuel Run, May 2021; Gold Rush Rally, June 2021; Car Week, August 2021; Gold Rush Rally, June 2022.

            Finding of the Court: As with the previous interrogatory, Plaintiff has failed to give all the facts as requested, and Plaintiff’s objections are without merit. Plaintiff must supplement this response.

            Defendant’s motion to compel further response to Interrogatory No. 27 is GRANTED.

                        Special Interrogatory No. 29:

            Describe all facts supporting your allegation in paragraph 12(c) of the complaint that Peter Northrop “[p]ok[ed] Plaintiff’s buttocks with a banana without her consent” including by describing when and where (physical location) this occurred.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad. Plaintiff further objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows: Peter Northrop poked Plaintiff’s buttocks with a banana without her consent at the Legends Rally in or around March 2022.

            Finding of the Court: As with the prior two interrogatories, Plaintiff has not described all the facts surrounding the incident. Further response is required.

            Defendant’s motion to compel further response to Interrogatory No. 29 is GRANTED.

                        Special Interrogatory No. 31:

            “Describe all facts supporting your allegation in paragraph 13 of the complaint that “Plaintiff objected to Defendant Northrop’s harassing behavior and told him to stop” including by describing when and where (physical location) this occurred.”

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, and calls for speculation. Plaintiff further objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff does not recall the exact dates that she objected to Defendant Northrop’s harassing behavior over the course of over a year and a half. Plaintiff objected to Defendant Northrop’s harassing behavior numerous times.

            Finding of the Court: Plaintiff states that she does not recall the exact dates.  However, she has alleged that she made the objections and she must provide information regarding the objections. Defendant’s motion to compel further response to Interrogatory No. 31 is GRANTED.

                        Special Interrogatory No. 33:

            “Describe all facts supporting your allegation in paragraph 15 of the complaint that “Defendant Northrop would respond to Plaintiff’s requests in erratic ways such as threatening to terminate her employment, threatening to take her car that she leased through him away, screaming and yelling at Plaintiff, banging on her hotel room door late at night if she had slept in a different hotel room, and/or sending Plaintiff inappropriate and harassing text messages.””

            Plaintiff’s response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is compound, overbroad and unintelligible. Plaintiff specifies the Complaint and Plaintiff’s document production from which the answer may be derived or ascertained. Plaintiff further objects to this interrogatory on the grounds that it seeks information in the possession of the propounding party.

            Finding of the Court: Plaintiff makes no attempt to answer this question and instead just objects. Plaintiff must describe the facts surrounding these allegations.  The details should be provided.

            Defendant’s motion to compel further response to Interrogatory No. 33 is GRANTED.

                        Special Interrogatory No. 37:

            “Describe all facts supporting your allegation in paragraph 59 of the complaint that “Defendant Northrop sexually battered Plaintiff by using physical force and touching intimate parts of Plaintiff, including but not limited to her vagina” including by describing when and where (physical location) this occurred.”

            Plaintiff’s amended response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, overbroad, and calls for speculation. Plaintiff further objects on the grounds that it seeks a legal conclusion.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Defendant Northrop sexually battered Plaintiff by causing an offensive contact with Plaintiff’s intimate parts in or around February 2021 at Race to Rally, in or around December 2021 at Art Basil, and in or around March 2022 at Legends Rally.

            Finding of the Court: As with previous interrogatories, Plaintiff did not describe all the facts, instead she only gave vague dates and events. Plaintiff must supplement this response.

            Defendant’s motion to compel further response to Interrogatory No. 37 is GRANTED.

                        Special Interrogatory No. 39:

            “How much money do you claim Peter Northrop owes you by reason of the allegations in the complaint?”

            Plaintiff’s amended response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, harassing, calls for speculation, calls for a legal conclusion, calls for an expert opinion, lacks reasonable particularity, and seeks premature disclosure of expert testimony.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff incorporates by reference, her response to Form Interrogatory 8.6, 8.7, and 8.8, in which Plaintiff provides information regarding her lost wages. Plaintiff seeks general damages, special damages, compensatory and consequential damages, punitive damages, attorney’s fees, costs of suit, and any other and further relief the Court deems proper and just.

            Finding of the Court: Plaintiff needs to give a dollar amount, even it if it is just an estimate.

            Defendant’s motion to compel further response to Interrogatory No. 39 is GRANTED.

                        Special Interrogatory No. 40:

            “Describe how you calculated the amount of money stated in your response to the special interrogatory immediately preceding this one.”

            Plaintiff’s amended response:

Objection. Plaintiff objects to this interrogatory on the grounds that it is overbroad, vague, ambiguous, harassing, calls for speculation, calls for a legal conclusion, calls for an expert opinion, lacks reasonable particularity, and seeks premature disclosure of expert testimony.

Subject to and without waiving the foregoing objections, Plaintiff responds as follows:

Plaintiff incorporates by reference, her response to Form Interrogatory 8.6, 8.7, and 8.8, in which Plaintiff provides information regarding her lost wages. Plaintiff seeks general damages, special damages, compensatory and consequential damages, punitive damages, attorney’s fees, costs of suit, and any other and further relief the Court deems proper and just.

            Finding of the Court: Plaintiff should give a calculation for the further response that she gives to Interrogatory No. 39.

            Defendant’s motion to compel further response to Interrogatory No. 40 is GRANTED.

            Monetary Sanctions:

            “The Court shall impose a monetary sanction…against a party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or circumstances make the imposition of the sanction unjust.” (CCP § 2030.300(d).)

            Defendant has requested $20,232.00 in monetary sanctions against Plaintiff for having to bring this motion. Defendant’s attorney’s hourly rate is $495, and he stated that he will have spent 9.2 hours preparing the motion, reviewing the opposition, preparing a reply, and attending the hearing for a total of $4,554.00. (Ellis Decl., ¶ 13.) Defendant has also requested costs in the amount of $60.00. (Ellis Decl., ¶ 15.) Given that the Court is only granting the motion for some of the disputed interrogatories, $3,000 is a reasonable amount for fees and costs for the motion.

            Defendant’s attorney’s declaration contains a confusing paragraph about the amount of time that Defendant’s former counsel spent on a motion to compel further responses. (Ellis Decl., ¶ 14.) The billing amounts for these attorneys is how Defendant got to the $20,232.00 amount. The relevance of this paragraph is unclear, and Plaintiff objected to the paragraph on the grounds that it lacks foundation. The Court sustains Plaintiff’s objection to this paragraph.

            Because Plaintiff unsuccessfully opposed this motion, the Court will impose sanctions against Plaintiff in the amount of $3,000.00.

Order

1.      Defendant 1016 Industries’ motion to compel further responses is granted for Special Interrogatories Nos. 3, 17, 19, and 20.

2.      Defendant 1016 Industries’ request for sanctions against Plaintiff is granted in the amount of $3,030.00.

3.      Defendant Peter Northrop’s motion to compel further responses is granted for Special Interrogatories Nos. 3, 25, 27, 29, 31, 33, 37, 39, and 40.

4.      Defendant Peter Northrop’s request for sanctions against Plaintiff is granted in the amount of $3,000.00.

5.      Plaintiff is to serve further responses to Defendants within 20 days.

6.      Plaintiff is ordered to pay sanctions to Defendants within 45 days.