Superior Court of California 

County of Los Angeles 

Department 78 

 

STEPHANIE LANGLITZ,

Plaintiff;  

vs. 

UMRO REALY CORP. dba THE AGENCY-BEVERLY,

Defendant. Case No.: 22STCV20757

PLAINTIFF’S MOTION TO COMPEL DEFENDANT’S FURTHER RESPONSES TO REQUESTS FOR PRODUCTION  

Plaintiff’s motion to compel Defendant’s further responses to requests for production is GRANTED in part and DENIED in part. 

Defendant’s consultant is ordered to complete the work in the same manner as proposed by Plaintiff’s consultant. Plaintiff’s consultant is allowed to be present and to observe all the work performed by Defendant’s consultant. 

This work must be completed within the next 30 days.

The files must be produced in native format with metadata.

Defendant must produce a privilege log if any documents are being withheld due to an asserted privilege. Documents may not be withheld for any other reason.

Defendant must follow Plaintiff’s search term protocol as set forth in the 12/7/2023 joint filing regarding search terms for slack message discovery. 

If the quantity of Slack messages retrieved as a result of the searches performed results in the need for additional time to review and produce responsive messages, Defendant may file an ex parte application requesting additional time. Any such application should include information about the volume of messages retrieved and a detailed explanation as to the need for additional time. 

The Court awards sanctions in the amount of  $5,310 (seven hours at $750 per hour plus a $60 filing fee) jointly and severally against Defendant and Defendant’s Counsel. Sanctions are payable within 20 days after the date of this order.  

Moving party to provide notice.

DATED:  December 8, 2023

______________________

Hon. Jill Feeney 

Judge of the Superior Court