Judge: John J. Kralik, Case: 23BBCV02637, Date: 2025-05-02 Tentative Ruling

Case Number: 23BBCV02637    Hearing Date: May 2, 2025    Dept: NCB

Superior Court of California

County of Los Angeles

North Central District

Department B

BACKGROUND

A.    Allegations

Plaintiff Carmi Gallo (“Plaintiff”) alleges that she is a 73-year-old senior citizen who has been residing at 4560 Coldwater Canyon Ave #304, Studio City, CA 91604 since January 31, 2001.  Plaintiff alleges that Defendant Goldman Property Group Inc. (“Defendant”) is the manager of the property where the rental unit is located.  Plaintiff alleges that she had made Defendant aware many times that there was water damage in the premises that came from her patio area through the patio door unit in the master bedroom.  Plaintiff alleges that in 2018, City Inspector Lee Miller visited the premises and gave Defendant 30 days to fix the leak from the patio and remediate any possible mold issue under the broadloom of Plaintiff’s home.  Plaintiff alleges that Daniel Goldman also expected Plaintiff to pay for new flooring for the apartment, but has Plaintiff refused to pay for the new flooring.  Plaintiff alleges that since the inspector’s visit and her refusal to pay for new flooring, she began to be targeted and singled out by Defendant.  Plaintiff alleges that despite giving her a 3-day notice to remove her belongings from the patio, Defendant trespassed and entered into her property early and damaged her personal belongings; Defendant knew she had a roommate but threatened to sue her and levied a penalty against her for $1,200; Defendant failed for years to remediate water intrusion and mold issues on her property despite being given notice; etc. 

The complaint, filed November 9, 2023, alleges causes of action for: (1) elder abuse (IIED); (2) nuisance (Civil Code, § 3479); (3) general negligence; (4) breach of warranty of habitability; (5) breach of covenant of quiet enjoyment; (6) breach of implied covenant of good faith and fair dealing; and (7) harassment (CCP § 527.6(b)(3)).    

The last page of the complaint includes a Verification signed by Plaintiff on November 8, 2023. 

On January 22, 2024, Defendant filed an unverified answer to Plaintiff’s “unverified” complaint.   

B.     Motion on Calendar

On January 3, 2025, Plaintiff filed a motion to compel Defendant’s further responses to Special Interrogatories, set one (“SROG”). 

On March 6, 2025, Plaintiff filed a motion to compel Defendant’s further responses to Request for Production of Documents, set one (“RPD”). 

On March 6, 2025, Plaintiff filed a motion to compel Defendant’s further responses to Requests for Admission, set one (“RFA”). 

On April 24, 2025, Defendant filed an untimely omnibus opposition brief to the 3 motions and 3 separate statements addressing the different discovery at issue.

DISCUSSION  

A.    SROGs

            Plaintiff moves to compel Defendant’s further responses to SROG Nos. 1-12, 48, 49, 51, 57, 59, 62, 63, and 68.  In opposition, Defendant argues that Plaintiff’s separate statement does not comply with the California Rules of Court, Rule 3.1345 and fails to independently state the basis for which a response is needed. 

            The Court notes that Plaintiff’s separate statement states the discovery request, Defendant’s response, and whether supplemental response were provided.  After listing the discovery requests and responses/objections, Plaintiff provides her reasons for the basis for her discovery requests, the law that supports her request, and (for the RPDs) good cause for a further response.  While Plaintiff’s separate statement is not laid out in the conventional manner, the Court notes that CCP § 2030.300(b)(2) requires that either a separate statement be provided or a concise outline of the discovery request and each response in dispute.  Thus, the Court will not deny the motion on the basis that the separate statement (or concise outline) is insufficient.  The Court addresses the merits of the motion. 

            SROG Nos. 1 and 4 ask Defendant to describe every instance when it or its agent placed the blue tarp on the premises (no. 1) and to identify all individuals employed and contracted by Defendant who were responsible for installing/maintaining the blue tarp (no. 4). 

            Defendant objected that the SROGs were compound and vague.  To No. 1, Defendant responded that the tarp was placed when Plaintiff failed to comply with management’s request to remove her belongings from the patio area in order to effectuate a repair concerning a water leak.  This response fails to address when Defendant placed the blue tarp and each instance the blue tarp was placed on the premises.  To No. 4, Defendant responded that it did not recall the identity of maintenance personnel.  To the extent that Defendant lacked knowledge of the individuals’ names, it should comply with CCP § 2030.220(c), which states: “If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”  The motion is granted as to SROG Nos. 1 and 4.   

            SROG Nos. 2-3 ask for the date on which the blue tarp was first installed on the premises by Defendant (no. 2) and why Defendant installed the blue tarp (no. 3).  To No. 2, Defendant stated it could not recall the exact date but stated sometime in 2019.  This is not a sufficient response and Defendant should comply with CCP § 2030.220(c).  To No. 3, Defendant responded in a similar manner as to No. 1.  This response is responsive to the SROG asked in No. 3, such that a further response will not be required.  The motion is granted as to No. 2 and denied as to No. 3. 

            SROG Nos. 5-6 ask if Defendant received complaints/remarks from Plaintiff about the blue tarp (no. 5) and every action Defendant took in response to the complaints/remarks (no. 6).  Defendant objected to the SROGs and “elected” to invoke CCP § 2030.230, which states: “If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to that interrogatory to refer to this section and to specify the writings from which the answer may be derived or ascertained. This specification shall be in sufficient detail to permit the propounding party to locate and to identify, as readily as the responding party can, the documents from which the answer may be ascertained. The responding party shall then afford to the propounding party a reasonable opportunity to examine, audit, or inspect these documents and to make copies, compilations, abstracts, or summaries of them.”  Defendant has not shown how responding to these SROGs would be burdensome to the extent that section 2030.230 is necessary.  Further, even if Defendant properly invoked this section, Defendant’s response fails to specify with sufficient detail which documents are relevant to these SROGs.  The motion is granted as to SROG Nos. 5-6.  

            SROG Nos. 7-8 ask Defendant to identify documents related to Plaintiff’s requests for removal of the blue tarp (no. 7) and why it did not remove the blue tarp for 2 years (no. 8).  Defendant objected that the SROGs were vague.  SROG No. 7 is not so vague such that Defendant is unable to respond as it seeks to know what documents relate to Plaintiff’s request for removal of the blue tarp.  With respect to No. 8, Defendant has explained why it put the tarp on her patio, but has not explained why it did not remove the tarp for 2 years.  Thus, the motion is granted as to SROG Nos. 7-8. 

            SROG No. 9 asks when Defendant removed the blue tarp from the premises. Defendant responded summer of 2021.  Defendant should comply with CCP § 2030.220(c).  The motion is granted as to SROG No. 9. 

            SROG No. 10 asks why Defendant or its agent entered the premises without notice.  Defendant objected that the SROG was compound and assumed facts not in evidence.  Defendant has not provided a full and complete response.  If it did not enter Plaintiff’s premises without her permission, it should state as such.  The motion is granted as to SROG No. 10. 

            SROG No. 11 asks Defendant to detail all communications between Defendant and Plaintiff regarding her hip surgery and her ability to comply with the 3-day notice to remove her belongings from the patio before the blue tarp was installed.  SROG No. 12 asks Defendant to detail all requests made by Defendant for Plaintiff to repair/remove items from her balcony prior to the installation of the blue tarp.  SROG No. 48 asks Defendant to detail communications between the parties regarding interference with Plaintiff’s ability to use her balcony/premises.  SROG No. 51 asks Defendant to state whether it received complaints from Plaintiff regarding noise, dust, or other disturbances caused by construction/maintenance activities at the premises, and if so to state its response.  SROG No. 57 asks Defendant to describe any communication between the parties regarding the installation or replacement of the balcony door.  SROG Nos. 59 and 63 ask Defendant to identify any communications: (59) in which Defendant informed Plaintiff that her complaints were being addressed, and to describe when those occurred; and (63) regarding rent increases and whether they were related to the conditions of the premises.  SROG No. 68 asks Defendant to identify all communications between the parties regarding any addendums or modifications to Plaintiff’s lease agreement.  Defendant objected that the SROGs were compound and sought information equally available to Plaintiff.  However, “[o]rdinarily it is not a ground for objection to an interrogatory that the answer is known to the party who seeks the information.”  (Alpine Mut. Water Co. v. Superior Court for Ventura County (1968) 259 Cal.App.2d 45, 54, fn. 6 [in contrast to information equally available to both parties in the public record].) As such, the objections are overruled.  The motion is granted as to SROG Nos. 11-12, 48, 51, 57, 59, 63, and 68. 

             SROG No. 49 asks Defendant if it conducted any inspection/assessments of the premises to determine whether the blue tarp or other repair activities interfered with Plaintiff’s ability to use or enjoy her home.  Defendant objected that the SROG was compound, vague, and not full and complete in and of itself, and assumed facts not in evidence.  The SROG is straightforward and is not ambiguous in its request.  The objections are overruled.  The motion is granted as to SROG No. 49.

            SROG No. 62 asks Defendant to state whether it informed Plaintiff that her rent would be increased due to maintenance or repair costs, and if so, to detail the basis for each rent increase.  Defendant objected but responded that it never increased Plaintiff’s rent due to maintenance or repair.  This is responsive to the SROG.  As such, the motion is denied as to SROG No. 62. 

            Plaintiff requests monetary sanctions but fails to state in the notice, memorandum of points and authorities, and the declaration of counsel how much in sanctions she is seeking.  CCP § 2023.040 states: “A request for a sanction shall, in the notice of motion, identify every person, party, and attorney against whom the sanction is sought, and specify the type of sanction sought. The notice of motion shall be supported by a memorandum of points and authorities, and accompanied by a declaration setting forth facts supporting the amount of any monetary sanction sought.”  The amount of sanctions was not noticed anywhere in the motion papers.  Plaintiff’s request for sanctions is denied.

            The Court further notes that a sufficient number of special interrogatories has been sent out in this matter and further special interrogatories should be carefully considered.

B.     RPDs

            Plaintiff moves to compel Defendant’s further responses to RPD Nos. 1, 3-7, 9, 11-22, 24-28, and 30-37. 

            RPD No. 1 seeks all documents and communications between Defendant and any agent, employees, or third parties regarding the decision to install, maintain, or remove the blue tarp on the premises.  Defendant objected that the term “premises” was defined to include every unit at 4560 Coldwater Canyon Ave. and raised the attorney-client privilege.  Defendant responded that despite a reasonable and good faith investigation, it was unable to produce responsive documents because they never existed or are no longer in its possession/custody.  The RPD as asked is overbroad as it includes potentially any and all units at the complex.  As such, the RPD will be limited to only the subject unit.  Defendant’s opposition papers do not explain how the decision to install, maintain, or remove the blue tarp would constitute attorney-client communications, such that this objection is overruled.  The motion is granted as to RPD No. 1. 

            RPD No. 3 asks Defendant to produce all documents that discuss the emotional or psychological impact of Defendant’s actions on Plaintiff.  RPD No. 4 asks Defendant to produce all documents showing its awareness/knowledge of Plaintiff’s age and physical condition, including any accommodations requested or provided due to her hip surgery.  RPD No. 5 asks Defendant to produce all documents related to water intrusion, mold, or habitability issues in the unit below Plaintiff’s apartment.  RPD No. 6 asks for all communications between Defendant and any third parties regarding the water intrusion and blue tarp installation at the premises and the unit below Plaintiff’s apartment.  RPD No. 7 asks for all documents reflecting Defendant’s decision-making process for installing and maintaining the blue tarp, including any alternative measures considered to address the water intrusion issue.  RPD No. 9 asks for all documents reflecting Defendant’s policies and procedures for handling tenant repair requests.  RPD No. 30 asks for all documents related to any inspections, assessments, or reports that Defendant conducted or commissioned to determine the habitability of Plaintiff’s unit during her tenancy.  RPD No. 33 asks for all documents that reference its compliance with municipal, state, or federal laws, regulations, policies, and procedures.  RPD No. 34 asks for all documents that govern its compliance with municipal or state building codes, safety standards, or other law as it relates to the premises. 

Defendant objected that the RPDs were vague and sought attorney work product and attorney-client communications; however, Defendant responded in a similar manner as above that despite a reasonable and good faith investigation, it was unable to produce responsive documents because they never existed or are no longer in its possession/custody.  In opposition, Defendant has not substantiated its claims of privilege, such that they are overruled.  Further, the RPDs are not so vague that Defendant is unable to respond.  The Court will limit the RPDs to only Plaintiff’s unit and the unit below Plaintiff’s apartment.  If no documents exist, Defendant should plainly state as such.  The Court grants the motion as to RPD Nos. 3-7, 9, 30, 33, and 34.      

RPD No. 11 asks for all documents related to inspections, assessments, or repairs conducted by third parties, contractors, or repair personnel regarding the premises, in the course of Plaintiff’s tenancy.  RPD No. 12 asks for all healthy, safety, or government inspection reports, notices, or citations related to violations of building codes, health regulations, or safety standards at the premises during Plaintiff’s tenancy.  RPD No. 15 asks for all documents related to any communications between Defendant and health or safety authorities, inspectors, or third-party contractors concerning water intrusion, mold, or safety issues at the premises.  RPD No. 16 asks for documents related to testing or remediation of mold, moisture, or other environmental hazards in the building where the premises is located in the course of Plaintiff’s tenancy.  RPD No. 19 asks for all notices, emails, or communications related to repairs associated with the installation of the blue tarp. 

Defendant objected and responded in a similar manner as above, and also with respect to the over-broadness of the scope and time.  The Court will grant the motion as to RPD Nos. 11-12, 15-16, and 19, but limit the documents produced to only documents regarding Plaintiff’s unit, the unit below her, and the unit above her from January 2015 to the present.  Plaintiff moved into her unit on January 31, 2001, such that requiring 25 years of documents for all units would not be relevant to this action. 

            RPD No. 13 asks for all documents related to efforts by Defendant to address water intrusion, mold, or other conditions at the premises in the course of Plaintiff’s tenancy.  RPD No. 14 asks for all communications with Plaintiff or third parties regarding complaints of unsafe or unhealthy living conditions at the premises, including water intrusion and mold growth.  RPD No. 17 asks for all documents/communications related to Plaintiff’s carpet, water intrusion in the unit below Plaintiff’s apartment, and concerns of mold in her apartment and units surrounding her apartment.  RPD No. 18 asks for all documents/communications related to any interference with her use and enjoyment of the premises caused by repair activities.  RPD No. 22 asks for all communications/documents related to rent increases in the course of Plaintiff’s tenancy.  RPD No. 24 asks for all documents related to Plaintiff’s lease agreement.  RPD No. 25 asks for all documents related to the method it used to determine the percentage increase applied to each tenant.  RPD No. 27 asks for all documents/communications that evidence that Plaintiff “disrupted” the construction of the premises.  RPD No. 31 asks for all documents that it relied on to ensure compliance with local, state, or federal laws, regulations, and procedures related to habitability, tenant rights, and building maintenance at the premises.  RPD No. 32 asks for all documents that support Defendant’s defenses.  RPD No. 35 asks for all documents related to notices to enter given to Plaintiff by Defendant in the course of her tenancy.  RPD No. 36 asks for all documents related to any and all repairs it has done at the premises.  RPD No. 37 asks for all documents that evidence its compliance with equal housing opportunities for seniors at the building where the premises is located. 

Defendant objected in a similar manner as above and responded that after conducting a diligent search and reasonable inquiry, all documents in its possession, custody, or control were produced.  If the documents were already provided, then it is unclear what more Plaintiff seeks.  Plaintiff only provides arguments why there is good cause to produce the documents, but does not provide arguments regarding why Defendant’s responses were inadequate.  (Pl.’s Separate Statement at p. 28.)  As such, the motion is denied as to RPD Nos. 13-14, 17-18, 22, 24-25, 27, 31-32, and 35-37. 

             RPD No. 20 asks for all documents related to Defendant’s Lowe’s Retail Store order related to Plaintiff’s balcony door.  RPD No. 21 asks for all documents/communications related to its attempt to obtain the items necessary to repair Plaintiff’s balcony door from a place other than Lowe’s.  Defendant objected that the RPDs were vague, but responded that despite a reasonable and good faith investigation and inquiry, it was unable to produce the documents, if any exist, because they have never been or no longer in its possession or custody.  CCP § 2031.230 states: “A representation of inability to comply with the particular demand for inspection, copying, testing, or sampling shall affirm that a diligent search and a reasonable inquiry has been made in an effort to comply with that demand. This statement shall also specify whether the inability to comply is because the particular item or category has never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in the possession, custody, or control of the responding party. The statement shall set forth the name and address of any natural person or organization known or believed by that party to have possession, custody, or control of that item or category of item.”  If documents do in fact exist but Defendant is unable to produce them, it should comply with section 2031.230 by stating the contact information of the person/organization believed to be in possession of the documents.  If the documents do not exist, then Defendant should clearly state as such.  The motion is granted as to RPD Nos. 20-21.

             RPD No. 26 asks for all documents/communications that evidence Plaintiff was not the one with the highest rent increase year over year at the building where the premises is located.  RPD No. 28 asks for all documents/communications justifying rent increases imposed on Plaintiff including any comparisons to rent increases applied to other tenants.  Defendant objected that the RPDs were overbroad to include every unit at the premises, violated the individual privacy rights of third parties, seeks evidence of finances of Defendant’s privacy rights, sought the premature disclosure of financial information, and sought pre-trial discovery of Defendant’s profits and financial condition without leave of Court.  With respect to Defendant’s financial privacy rights, while individuals have a recognized privacy right in their personal financial information, “[t]he corporate right to privacy is a lesser right than that held by human beings and is not considered a fundamental right.”  (SCC Acquisitions, Inc. v. Superior Court (2015) 243 Cal.App.4th 741, 756.)  Further, the rent of other tenants is not relevant to this action.  The Court will not require that the rental amounts be disclosed, but will order that the percentage increases in rents for the other units be provided to Plaintiff from 2015 to the present, and justifications thereto.  As such, the motion is granted as to RPD Nos 26 and 28, subject to these limitations.

            For the same reasons discussed above, no sanctions will be awarded. 

C.     RFAs

            Plaintiff moves to compel Defendant’s further responses to RFA Nos. 1, 3-5, 7-8, 12, 15-17, 19, 21, 23-26, and 29-32. 

            RPD No. 1 asks Defendant to admit that it was informed of the “water intrusion” issue in the “subject property” before the installation of the blue tarp.  RFA No. 12 asks Defendant to admit that Plaintiff’s patio furniture was not the actual cause of the water intrusion affecting the units below the premises.  Defendant objected that the terms “water intrusion,” “subject property,” and “premises” were capitalized/bolded but not defined.  Defendant responded without waiving objections: “Pursuant to CCP Section 2033.220(c), after a reasonable inquiry concerning the matter being requested, the information known or readily obtainable is insufficient to enable Responding Party to admit or deny the entire matter with the degree of specificity that is required.”  While the term “water intrusion” is not unclear, the terms “subject property” and “premises” (which includes every unit at the property) is vague.  Plaintiff should redraft the RFA to specifically define the terms and whether “subject property” is distinct from “premises.”  Plaintiff should redraft the RFA to specifically define the terms and whether “subject property” is distinct from “premises.”  The motion is denied as to RFA Nos. 1 and 12. 

            RFA No. 3 asks Defendant to admit that Plaintiff complained to it about the water intrusion on multiple occasions in the course of her tenancy.  Defendant objected that the term “water intrusion” was not defined, but responded by admitting that Plaintiff complained about the water leak.  The term “water intrusion” is not vague or unclear, which is evidenced by Defendant’s ability to respond.  As Defendant did in fact respond to the RFA, the motion is denied as to RFA No. 3. 

            RFA No. 4 asks Defendant to admit that the city inspector instructed it to fix the water intrusion problem in Plaintiff’s apartment in 2018.  RFA No. 5 asks Defendant to admit that it failed to complete repairs to fix the water intrusion within the 30-day period as instructed by the city inspector.  RFA No. 23 asks Defendant to admit that it demanded Plaintiff to pay for the cleaning of her 23-year-old carpet after city inspectors noted its deteriorating condition.  Defendant objected to the terms “city inspector” and “water intrusion” because they were bolded, but undefined.  Defendant also responded in compliance with CCP § 2033.220(c).  The Court does not find the term “city inspector” to be vague, though it was bolded by Plaintiff in its RFAs.  In addition, while Defendant’s response is technically code compliant, this information is in the best knowledge of Defendant.  Defendant should make efforts to ascertain the answer and provide a further response.  The motion is granted as to RFA Nos. 4-5 and 23. 

            RFA No. 7 asks Defendant to admit that it entered the premises on the second day from issuing a 3-day notice to Plaintiff and removed her personal property from the balcony.  Defendant objected to the term “3-day notice” but responded in the same manner with respect to CCP § 2033.220(c).  This is not a vague request as Defendant was the party that issued the 3-day notice.  Although Defendant objected to this RFA, this information would be in the knowledge of Defendant.  As such, the motion is granted as to RFA No. 7. 

             RFA No. 8 asks Defendant to admit that it discarded or damaged Plaintiff’s personal belongings when entering her balcony to remover her personal property.  Defendant objected that the terms were vague, but responded pursuant to CCP § 2033.220(c).  The terms “personal belongings” or “damaged” are not vague.  Further, Defendant would have knowledge regarding this RFA through its agents, such that it should provide a further response.  The motion is granted as to RFA No. 8. 

            RFA No. 15 asks Defendant to admit that the blue tarp obstructed Plaintiff’s view, natural light, and air circulation during the entire period of its installation.  RFA No. 21 asks Defendant to admit that Plaintiff incurred increased utility costs due to lack of air circulation and natural light caused by the blue tarp.  RFA No. 30 asks Defendant to admit that it knew that keeping the blue tarp on her balcony would obstruct her view and prevent circulation during the pandemic.  Defendant objected that the RFAs were vague and called for speculation and the premature disclosure of expert information, but responded pursuant to CCP § 2033.220(c).  This RFA is within the knowledge of Plaintiff and it is better ascertained after Defendant has deposed Plaintiff or conducted an inspection of the property through its expert.  At this time, the motion is denied as to RFA Nos. 15, 21, and 30. 

            RFA No. 16 asks Defendant to admit that Plaintiff made multiple requests to Defendant for the removal of the blue tarp during the period it was installed.  Defendant responded by citing to CCP § 2033.220(c).  However, this information can be easily ascertainable by asking Defendant’s agents or reviewing communications with Plaintiff.  As such, a further response should be provided.  The motion is granted as to RFA No. 16. 

            RFA No. 17 asks Defendant to admit that it did not replace the balcony door of Plaintiff’s unit for over 1 year throughout the whole time the blue tarp was covering Plaintiff’s balcony.  Defendant responded by admitting to the extent the balcony door did not need to be replaced and was not replaced.  This response is sufficient.  The motion is denied as to RFA No. 17. 

            RFA No. 19 asks Defendant to admit that Plaintiff was the only tenant required to sign a service order form after maintenance work was completed in her unit.  Defendant objected to the RFA but responded by admitting that Plaintiff was required to sign a service order form for work completed on her unit on 1 occasion.  The response is sufficient.  The motion is denied as to RFA No. 19. 

            RFA No. 24 asks Defendant to admit that it charged Plaintiff $200 in rent in 2023, which exceeded the rent increases imposed on other tenants in the building.  RFA No. 26 asks Defendant to admit that Plaintiff’s yearly percentage increase was higher than that of other tenants.  Defendant objected that the RFAs were vague.  To RFA No. 24, Defendant responded by admitting that Plaintiff’s rent was increased on April 17, 2023.  This is only partially responsive as it did not admit to whether the increase was more than that imposed on the other tenants in the building.  RFA No. 26 seeks essentially that same information.  As such, a further response should be provided.  The motion is granted as to RFA Nos. 24 and 26. 

            RFA No. 25 asks Defendant to admit that it was aware of Plaintiff’s medical condition related to her hip surgery when issuing the 3-day notice to clear her balcony.  RFA No. 29 asks Defendant to admit that it did not remove the blue tarp during non-rainy seasons despite Plaintiff’s repeated request.  RFA No. 31 asks Defendant to admit that installation of a tarp is not considered construction.           RFA No. 32 asks Defendant to admit that no actual construction was ever done by Defendant to Plaintiff’s unit or balcony.  Defendant objected that the RFAs were vague and responded pursuant to CCP § 2033.220(c).  Again, this too can be responded to by Defendant upon making inquiries to its agents and reviewing documents.  The motion is granted as to RFA Nos. 25, 29, and 31-32. 

For the same reasons discussed above, no sanctions will be awarded.

CONCLUSION AND ORDER

Plaintiff Carmi Gallo’s motion to compel Defendant Goldman Property Group Inc.’s further responses to the SROG is granted as to Nos. 1, 2, 4-12, 48, 49, 51, 57, 59, 63, and 68; and denied as to Nos. 3 and 62. 

Plaintiff Carmi Gallo’s motion to compel Defendant Goldman Property Group Inc.’s further responses to the RPD is granted as to Nos. 1, 3-7, 9, 11-12, 15-16, 19-21, 26, 28, 30, and 33-34; and denied as to Nos. 13-14, 17-18, 22, 24-25, 27, 31-32, and 35-37. 

Plaintiff Carmi Gallo’s motion to compel Defendant Goldman Property Group Inc.’s further responses to the RFA is granted as to Nos. 4-5, 7-8, 16, 23-26, 29, and 31-32; and denied as to Nos. 1, 3, 12, 15, 17, 19, 21, and 30. 

Defendant is ordered to provide further responses within 20 days of notice of this order.

No sanctions shall be awarded.

Plaintiff shall provide notice of this order.

DATED: May 2, 2025                                                            ___________________________

                                                                              John Kralik

                                                                              Judge of the Superior Court