Judge: Joseph Lipner, Case: 21STCV35635, Date: 2024-02-27 Tentative Ruling

Case Number: 21STCV35635    Hearing Date: February 27, 2024    Dept: 72

 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

CHRIS NELSON,

 

                                  Plaintiff,

 

         v.

 

 

PHOEBE BRIDGERS,

 

                                  Defendant.

 

 Case No:  21STCV35635

 

 

 

 

 

 Hearing Date:  February 27, 2024

 Calendar Number:  1

 

 

 

Defendant Phoebe Bridgers (“Defendant”) moves to compel further responses to discovery requests propounded on Plaintiff Chris Nelson (“Plaintiff”) in order to enforce a money judgment previously entered in her favor.

 

The Court DENIES Defendant’s motion with respect to Special Interrogatories Nos. 8 and 9 and Requests for Production Nos. 8 and 9.  Absent a specific showing of need, the Court views demands for social security number and driver license number as too invasive.  Moreover, in the documents produced pursuant to this order, Plaintiff may redact his social security number and driver license number.

 

The Court GRANTS Defendant’s motion with respect to Special Interrogatories 17, 18, 19, 28, and 29 and Requests for Production 16, 17, 26, and 27. For each of these requests, Plaintiff shall not be required to provide information or documents with respect to responsive property with a fair market value of less than $500.00.

 

The Court GRANTS Defendant’s Request for Inspection No. 5, but Plaintiff shall not be required to permit inspection of musical equipment with a fair market value of less than $500 unless that equipment is at the same location as musical equipment with a fair market value of $500 or greater.

 

GRANTS Defendant’s motion with respect to the remaining items at issue.

Plaintiff shall provide the interrogatory answers and documents subject to production within 30 days of this order.

 

The Court GRANTS Defendant’s request for attorney’s fees and costs in the amount of $5,000. Plaintiff shall pay this amount Defendant’s counsel within 30 days of the issuance of this order.

 

Background

 

On November 9, 2022, the Court granted Defendant’s anti-SLAPP motion as to all of Plaintiff’s causes of action against Defendant.

 

          Defendant subsequently moved for an award of attorney’s fees pursuant to the anti-SLAPP statute. On April 18, 2023, the Court entered a judgment in Defendant’s favor in the amount of $490,608.32 in attorney’s fees.

 

          Plaintiff has since refused to pay the judgment. (Strub Decl. ¶ 8.)

 

          On October 31, 2023, Defendant served her First Set of Special Interrogatories and First Set of Requests for Production and Demand for Inspection on Plaintiff. The discovery requests seek information to ascertain whether there is any property of Plaintiff that should be applied to the payment of the judgment.

 

          Plaintiff served his responses on January 9, 2024.

 

          From January 10, 2024 to January 22, 2024, counsels for Plaintiff and Defendant met and conferred regarding the adequacy of the responses.

 

          Defendant filed this motion on January 30, 2024. Plaintiff filed an opposition and Defendant filed a reply.

 

Legal Standard

 

Unless otherwise limited by order of the court in accordance with this title, any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. (Code Civ. Proc. § 2017.010.) Discovery may relate to the claim or defense of the party seeking discovery or of any other party to the action. (Code Civ. Proc. § 2017.010.)

 

“Relevant evidence is defined in Evidence Code section 210 as evidence ‘having any tendency in reason to prove or disprove any disputed fact that is of consequence to the determination of the action.’ The test of relevance is whether the evidence tends logically, naturally, and by reasonable inference to establish material facts. The trial court has broad discretion in determining the relevance of evidence, but lacks discretion to admit irrelevant evidence.”  (Donlen v. Ford Motor Co. (2013) 217 Cal.App.4th 138, 148 [internal quotations and citations omitted].)

 

Requests for Production

 

“A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” (Code Civ. Proc., § 2031.220.)

 

“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.” (Code Civ. Proc., § 2031.230.)

 

“(a) On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply:

          (1) A statement of compliance with the demand is incomplete.

(2) A representation of inability to comply is inadequate, incomplete, or evasive.

          (3) An objection in the response is without merit or too general.

 

(b) A motion under subdivision (a) shall comply with each of the following:

(1) The motion shall set forth specific facts showing good cause justifying the discovery sought by the demand.

(2) The motion shall be accompanied by a meet and confer declaration under Section 2016.040.

(3) In lieu of a separate statement required under the California Rules of Court, the court may allow the moving party to submit a concise outline of the discovery request and each response in dispute.

 

(c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the demanding party and the responding party have agreed in writing, the demanding party waives any right to compel a further response to the demand.

 

… (h) Except as provided in subdivision (j), the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response to a demand, 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., § 2031.310.)

 

          The burden is on the moving party to show both relevance to the subject matter and specific facts justifying discovery. (Glenfed Develop. Corp. v. Superior Court (1997) 53 Cal.App.4th 1113, 1117.)  Once good cause is established by the moving party, the burden then shifts to the responding party to justify any objections made to document disclosure. (Hartbrodt v. Burke (1996) 42 Cal.App.4th 168, 172-174.)

         

Interrogatories

 

Code of Civil Procedure section 2030.220, subdivision (a) requires that “[e]ach answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.” Pursuant to Code of Civil Procedure section 2030.300, a party may move to compel further responses to a form interrogatory if the other party’s answer is “evasive or incomplete.” The responding party has the burden of justifying the objections to the form and special interrogatories. (Coy v. Super. Ct. (1962) 58 Cal.2d 210, 220-221.) 

 

“The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response 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. If a party then fails to obey an order compelling answers, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010).” (Code Civ. Proc. § 2030.290.

 

Discussion

 

          The parties’ respective positions can be found in their filings, including the separate statements. The Court’s rulings on each request are set forth below.

 

Special Interrogatories

 

Special Interrogatory Nos. 1-7: Plaintiff shall provide code-compliant responses to these interrogatories.

 

Special Interrogatory No. 8: Plaintiff shall not be required to disclose his social security number.

 

Special Interrogatory No. 9: Plaintiff shall not be required to disclose his driver’s license information.

 

Special Interrogatory Nos. 10-15: Plaintiff shall provide code-compliant responses to these interrogatories.

 

Special Interrogatory No. 16: Plaintiff shall provide code-compliant responses to this interrogatory, but shall not be required to disclose information regarding musical equipment with a fair market value of less than $500.

 

Special Interrogatory No. 17: Plaintiff shall provide code-compliant responses to this interrogatory, but shall not be required to disclose information regarding musical equipment with a fair market value of less than $500.

 

Special Interrogatory No. 18: Plaintiff shall provide code-compliant responses to this interrogatory, but shall not be required to disclose information regarding musical equipment with a fair market value of less than $500.

 

Special Interrogatory Nos. 19-27: Plaintiff shall provide code-compliant responses to these interrogatories.

 

Special Interrogatory No. 28: Plaintiff shall provide code-compliant responses to this interrogatory, but shall not be required to identify personal assets with a fair market value of less than $500.

 

Special Interrogatory No. 29: Plaintiff shall provide code-compliant responses to this interrogatory, but shall not be required to identify personal assets with a fair market value of less than $500.

 

Special Interrogatory Nos. 30-33: Plaintiff shall provide code-compliant responses to these interrogatories.

 

 

Requests for Production

 

RFP Nos. 1-7: Plaintiff shall produce all responsive documents.

 

RFP No. 8: Plaintiff shall not be required to produce a copy of his driver’s license.

 

RFP No. 9: Plaintiff shall not be required to produce a copy of his social security card.

 

RFP Nos. 10-15: Plaintiff shall produce all responsive documents.

 

RFP No. 16: Plaintiff shall produce all responsive documents, but shall not be required to produce documents that only relate to musical equipment with a fair market value of less than $500.

 

RFP No. 17: Plaintiff shall produce all responsive documents, but shall not be required to produce documents that only relate to musical equipment with a fair market value of less than $500.

 

RFP Nos. 18-25: Plaintiff shall produce all responsive documents.

 

RFP No. 26: Plaintiff shall produce all responsive documents, but shall not be required to produce documents that relate only to personal property with a fair market value of less than $500.

 

RFP No. 27: Plaintiff shall produce all responsive documents, but shall not be required to produce documents that relate only to personal property with a fair market value of less than $500.

 

RFP Nos. 28-43: Plaintiff shall produce all responsive documents.

 

 

Requests for Inspection

 

Request for Inspection Nos. 1-3: Plaintiff shall permit the requested inspections.

 

Request for Inspection No. 4: Plaintiff shall permit the requested inspections.

 

Request for Inspection No. 5: Plaintiff shall permit the requested inspections, but shall not be required to permit inspection of musical equipment with a fair market value of less than $500 unless that equipment is at the same location as musical equipment with a fair market value of $500 or greater.

 

Request for Inspection No. 6: Plaintiff shall permit the requested inspections.

 

Sanctions

 

          The Court awards attorney’s fees in favor of Defendant and against Plaintiff. The Court does not find that any of the statutory exceptions to an award of attorney’s fees are present here.

 

Defendant requests an hourly rate of $1,195.00 for attorney Michael H. Strub. The Court finds this rate to be reasonable in light of the fact that Defendant has voluntarily capped her claim for sanctions at $5,000, which is less than the fees she is actually incurring. 

 

          The court therefore awards a total of $5,000 in sanctions.