Judge: Gary I. Micon, Case: 23CHCV01624, Date: 2025-01-10 Tentative Ruling



Case Number: 23CHCV01624    Hearing Date: January 10, 2025    Dept: F43

Dept. F43

Date: 01-10-25

Case # 23CHCV01624, Ayala v. Pitchess Detention Center, et al.

Trial Date: None set.

 

MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES

 

MOVING PARTY: Defendant County of Los Angeles

RESPONDING PARTY: No response has been filed.

 

RELIEF REQUESTED

Order compelling responses to Special Interrogatories, Set Two and $750.00 in sanctions.

 

RULING: Motion is granted.

 

SUMMARY OF ACTION

Plaintiff Juan Ayala (Plaintiff) filed this action against defendants County of Los Angeles (Defendant), City of Los Angeles, State of California, Los Angeles County Sheriff’s Department, and Pitchess Detention Center on June 5, 2023, alleging causes of action for general negligence and premises liability.  On August 28, 2024, Defendant propounded on Plaintiff Special Interrogatories, Set Two numbers 35-50.  The parties agreed to three deadline extensions for responses.  Plaintiff never served responses.

 

Defendant filed this motion to compel responses to Special Interrogatories, Set Two on December 4, 2024.  No opposition has been filed.

 

MEET AND CONFER

A motion to compel interrogatory responses must include a declaration stating facts showing a “reasonable and good faith attempt” to resolve the issues mentioned in the motion before filing.  (Code Civ. Proc., §§ 2030.300, subd. (b), 2016.040.)

 

After Defendant’s counsel sent a meet and confer letter on October 4, 2024, Plaintiff’s counsel replied on October 7, 2024 stating Plaintiff would serve objection-free responses by October 21, 2024.  (Declaration of Kari C. Kadomatsu, ¶¶ 4-5, Exhs. B, C.)  On October 25, 2024, Plaintiff’s counsel sent responses to Defendant’s other discovery requests but not Special Interrogatories, Set Two.  (Kadomatsu Dec., ¶ 6, Exh. D.)  That same day, Defendant’s counsel asked Plaintiff’s counsel to send responses by October 26, 2024.  (Ibid.)  Plaintiff’s counsel stated the responses were late due to an unforeseen medical emergency, and Defendant’s counsel agreed to extend Plaintiff’s deadline to respond to November 1, 2024.  (Ibid.)  Plaintiff did not submit responses by November 1, 2024.  On November 5, 2024, Defendant’s counsel sent an email advising he planned to file a motion to compel.  (Kadomatsu Dec., ¶ 7, Exh. E.)  That same day, counsel spoke on the phone, and Plaintiff’s counsel agreed to serve objection-free responses no later than November 19, 2024.  (Ibid.)  After not receiving responses by the November 19 deadline, Defendant’s counsel sent emails on November 25, 2024 and December 2, 2024 regarding Plaintiff’s failure to respond and informed Plaintiff’s counsel that Defendant would file a motion to compel and request sanctions.  (Kadomatsu Dec., ¶ 8, Exh. F.)  Plaintiff has yet to serve responses.

 

ANALYSIS

A propounding party may move to compel responses to special interrogatories where the responding party fails to provide any responses. (Code Civ. Proc., § 2030.290, subd. (b).)  The propounding party must show that the interrogatories were properly served, that the time to respond expired, and no response has been served. (Leach v. Superior Court (1980) 111 Cal.App.3d 902, 905-906.)  The responding party must serve responses within 30 days after the interrogatories are served or according to an agreed upon deadline extension.  (Code Civ. Proc., §§ 2030.260, subd. (a), 2030.270.)  Failing to respond within these time limits waives objections.  (Code Civ. Proc., § 2030.290, subd. (a).)

 

Defendant has shown that it properly served Plaintiff on August 28, 2024.  Plaintiffs did not serve responses by the original September 27, 2024 deadline or any of Defendant’s subsequent deadline extensions.  As of December 4, 2024, Plaintiff has not served responses.

 

Accordingly, the Court orders Plaintiff to serve code-compliant, objection-free responses to Defendant’s Special Interrogatories, Set Two.

 

            Sanctions        

The Court may impose sanctions against any party who “unsuccessfully makes or opposes a motion to compel responses to interrogatories 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.”  (Code Civ. Proc., § 2030.290, subd. (c).)

 

Defendant requests $750.00 in monetary sanctions against Plaintiff and Plaintiff’s counsel.  Defendant’s counsel, Kari C. Kadomatsu, charges an hourly rate of $250.00.  (Kadomatsu Dec., ¶ 10.)  The request includes the following: (1) 1 hour preparing the motion—$250.00; and (2) 2 hours to respond and to attend the hearing—$500.00.  (Ibid.)

 

The Court finds the hourly rates are reasonable, and the proposed time is unreasonable.  Because Plaintiff has not filed an opposition, the time Mr. Kadomatsu anticipates spending replying to an opposition is reduced to 0 hours.

 

Accordingly, the Court grants Defendant’s request for sanctions in the reduced amount of $500.00: (1) 1 hour preparing this motion; and (2) 1 hour attending the motion hearing.

 

ORDER

Defendant County of Los Angeles’s motion to compel responses to Special Interrogatories, Set Two is granted.

  1. Plaintiff Juan Ayala is ordered to serve code-compliant, objection-free responses within twenty (20) days of the date of this order.
  2. Plaintiff and Plaintiff’s counsel of record are ordered to pay $500.00 in sanctions to Defendant’s counsel within twenty (20) days of the date of this order.

 

Defendant County of Los Angeles to give notice.