Judge: Latrice A. G. Byrdsong, Case: 22STLC02059, Date: 2023-12-27 Tentative Ruling

Case Number: 22STLC02059    Hearing Date: March 20, 2024    Dept: 25

Hearing Date:                         Wednesday, March 20, 2024

Case Name:                             CREDITORS ADJUSTMENT BUREAU, INC v. CONSTRUCTION SERVICING CENTER, INC. AKA CONSTRUCTION SERVICING CENTER INC AKA CONSTRUCTION SERVICING CTR INC DBA SUNUSO ENERGY ADBA SOLAR SERVICING ABDA SERVICING CENTER INC; and DOES 1 through 10, inclusive

Case No.:                                22STLC02059

Motion:                                   Motion for Order for Terminating Sanctions, Striking Defendant’s Answer and Entering Default; Request for Monetary Sanctions

Moving Party:                         Plaintiff Creditors Adjustment Bureau, Inc.

Responding Party:                   None

Notice:                                    OK


 

Tentative Ruling:                    Plaintiff’s Motion for Terminating Sanctions, Striking Defendant’s Answer is GRANTED.  Defendant’s Answer, filed on August 22, 2022, is HEREBY STRICKEN. 

 

Plaintiff may file a request for entry of default.

 

Plaintiff’s request for further monetary sanctions is DENIED. 

 

The Court sets an Order to Show Cause Re: Entry of Default/Default Judgment for MAY 20, 2024 at 9:30AM in Department 25 of the  Spring Street Courthouse.

 

The Trial set for 09/10/2024 is advanced to this date and hereby taken off calendar/vacated.


 

SERVICE: 

 

[   ] Proof of Service Timely Filed (CRC, rule 3.1300)                     OK

[   ] Correct Address (CCP §§ 1013, 1013a)                                      OK

[   ] 16/21 Court Days Lapsed (CCP §§ 12c, 1005(b))                       OK 

 

OPPOSITION:          None filed as of March 07, 2024                    [   ] Late          [X] None 

REPLY:                     None filed as of March 13, 2024                    [   ] Late          [X] None 

 

BACKGROUND

On March 29, 2022, Creditors Adjustment Bureau, Inc. (“Plaintiff”) filed this action for breach of contract and common counts against Construction Servicing Center, Inc. aka Construction Servicing Center Inc aka Construction Servicing Ctr Inc. dba Sunuso Energy adba Solar Servicing adba Servicing Center Inc (“Defendant”).

Defendant filed an answer on August 22, 2022.

On October 25, 2023, Plaintiff filed a (1) Motion for Order Compelling Further Responses to Special Interrogatories, Set One, and Request for Sanctions; and (2) Motion for Order Compelling Further Responses to Requests for Production, Set One, and Request for Sanctions against Defendant. Defendant filed in opposition on November 13, 2023, and Plaintiff replied on November 15, 2023. The Court granted both motions on December 27, 2023, and ordered Defendant to serve code complaint and verified responses to Plaintiff within twenty (20) days. The Court additionally issued sanctions against Defendant for $2,120.00.

On December 04, 2023, Defendant’s counsel Lawrence C. Ecoff, Esq. (“Counsel”) filed a Motion to be Relieved as Counsel for Defendant. The Court granted counsel’s request to be relieved on February 14, 2024.

On January 29, 2024, Plaintiff filed the instant Motion for Order for Terminating Sanctions, Striking Defendant’s Answer and Entering Default, and Request for Monetary Sanctions against Defendant.

No opposition has been filed.

MOVING PARTY POSITION

 

Plaintiff prays for the Court to issue an order for terminating sanctions, striking Defendant’s Answer and for entry of default against Defendant for failure to obey the Court’s prior discovery orders under CCP §§ 2030.290(c), 2031.320(c), and 2023.030(d). Plaintiff asserts that Defendant’s failure to provide responses to Plaintiff s First Request for Production of Documents and to Plaintiff's First Set of Special Interrogatories as ordered by this Court constitute a misuse of the discovery process. Plaintiff additionally requests that sanctions be entered against the Defendant in the amount of $1,561.65.

 

OPPOSITION

 

            No opposition has been filed.

 

REPLY

 

            No reply has been filed.

 

ANALYSIS

 

I.          Legal Standard

Where a party willfully disobeys a discovery order, courts have discretion to impose terminating, issue, evidence, or monetary sanctions.  (Code Civ. Proc., §§ 2023.010(d), (g), 2023.030; R.S. Creative, Inc. v. Creative Cotton, Ltd. (1999) 75 Cal.App.4th 486, 495.) 

 

Code of Civil Procedure § 2030.040 requires that “[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.”  Furthermore, 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.  (Code of Civ. Proc. § 2030.040.) 

 

Monetary sanctions may be imposed “ordering that one engaging in the misuse of the discovery process, or any attorney advising that conduct, or both pay the reasonable expenses, including attorney's fees, incurred by anyone as a result of that conduct…unless [the Court] finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.”  (Code of Civ. Proc. § 2030.030(a).) 

 

Issue sanctions may be imposed “ordering that designated facts shall be taken as established in the action in accordance with the claim of the party adversely affected by the misuse of the discovery process. The court may also impose an issue sanction by an order prohibiting any party engaging in the misuse of the discovery process from supporting or opposing designated claims or defenses.”  (Code of Civ. Proc. § 2030.030(b).) 

 

Evidence sanctions may be imposed “by an order prohibiting any party engaging in the misuse of the discovery process from introducing designated matters in evidence.”  (Code of Civ. Proc. § 2030.030(c).) 

 

In more extreme cases, the Court may also impose terminating sanctions by “striking out the pleadings or parts of the pleadings,” “staying further proceedings,” “dismissing the action, or any part of the action,” or “rending a judgment by default” against the party misusing the discovery process.  (Code of Civ. Proc. § 2030.030(d).)  The court should look to the totality of the circumstances in determining whether terminating sanctions are appropriate.  (Lang v. Hochman (2000) 77¿Cal.App.4th 1225, 1246.)  Ultimate discovery sanctions are justified where there is a willful discovery order violation, a history of abuse, and evidence showing that less severe sanctions would not produce compliance with discovery rules.  (Van Sickle v. Gilbert (2011) 196¿Cal.App.4th 1495, 1516.)  “[A] penalty as severe as dismissal or default is not authorized where noncompliance with discovery is caused by an inability to comply rather than willfulness or bad faith.”  (Brown v. Sup. Ct. (1986) 180 Cal.App.3d 701, 707.)  “Although in extreme cases a court has the authority to order a terminating sanction as a first measure [citations], a terminating sanction should generally not be imposed until the court has attempted less severe alternatives and found them to be unsuccessful and/or the record clearly shows lesser sanctions would be ineffective.”  (Lopez v. Watchtower Bible and Tract Society of New York, Inc. (2016) 246 Cal.App.4th 566, 604-605.) 

 

II.        Discussion

 

Plaintiff moves for terminating sanctions, striking Defendant’s Answer to the Complaint, for default to be entered against Defendant, and for monetary sanctions in the amount of $1,561.65 for expenses incurred in bringing the instant Motion. (Mot. p. 2.) Plaintiff argues that sanctions are appropriate because Defendant has failed to respond to its First Request for Production of Documents and First Set of Special Interrogatories, even after the Court ordered Defendant to provide Plaintiff with full, complete, and objection free responses on December 27, 2023. (Id. p. 3-5) 

 

Plaintiff provides the Court with the declaration of its Counsel who states that on December 27, 2023, the Court ordered Defendant to provide Plaintiff with full, complete, and objection free responses on December 27, 2023. (Tiffanie Brown Decl. ¶ 3.) Counsel avers that Plaintiff served Defendant with a Notice of Ruling on December 28, 2023. (Id. ¶ 4.) Counsel further declares that Defendant has not complied with any aspect of the Court’s order. Thus, the Court finds that Defendant has not complied with the Court’s order. Plaintiff argues that because of Defendant’s obstinance in responding to Plaintiff’s discovery request, Defendant has obstructed Plaintiff’s efforts to prosecute this action and has interfered with the Court’s mission of seeking truth and justice. (Mot. p. 5.)

 

Plaintiff seeks $1,561.65 in monetary sanctions for three (3) hours of attorney time working on the motion at a rate of $500.00 per hour. (Brown Decl. ¶ 5.)  Plaintiff also seeks $61.65 in costs, for a total of $1,561.65 in sanctions. (Id.)

 

The Court notes that since filing its Answer on August 22, 2022, Defendant has not responded to Plaintiff’s discovery requests, motions to compel discovery, or the instant motion for terminating sanctions. The Court additionally notes that it previously relieved Defendant’s former counsel based on a breakdown of the attorney-client relationship. (See 02/14/24 Minute Order.) It appears that the Defendant has willfully abandoned this litigation. Although terminating sanctions are a harsh penalty, the history in the instant case demonstrates that Defendant is unwilling to comply with Plaintiff’s requests or the Court’s orders and thus, lesser sanctions have not been effective in producing compliance. Here, Defendant has not filed any opposition to this Motion to argue why its failure to engage in discovery was due to an inability to comply or otherwise as opposed to bad faith. 

 

For these reasons, the Court finds an order striking Defendant’s Answer to be appropriate. Defendant’s Answer is HEREBY STRICKEN. Plaintiff may separately move for default to be entered against Defendant.

 

However, the Court declines to award further monetary sanctions as doing so would be futile in producing compliance. 

 

III.       Conclusion

           

Plaintiff’s Motion for Terminating Sanctions, Striking Defendant’s Answer is GRANTED.  Defendant’s Answer, filed on August 22, 2022, is HEREBY STRICKEN.

 

Plaintiff may file a request for entry of default. However, Plaintiff’s request for further monetary sanctions is DENIED. 

 

The Court sets an Order to Show Cause Re: Entry of Default/Default Judgment for MAY 20, 2024 at 9:30AM in Department 25 of the Spring Street Courthouse.

 

The Trial set for 09/10/2024 is advanced to this date and hereby taken off calendar/vacated.

 

Moving party is ordered to give notice.