Judge: Latrice A. G. Byrdsong, Case: 23NWLC19496, Date: 2024-04-09 Tentative Ruling

Case Number: 23NWLC19496    Hearing Date: April 9, 2024    Dept: 25

Hearing Date:                         Tuesday, April 09, 2024

Case Name:                             CREDITORS ADJUSTMENT BUREAU, INC v. LLEWELLYN INDUSTRIES, INC. AKA LLEWELLYN INDUSTRIES INC DBA LLEWELLYN SUPPLY COMPANY AKA LLEWELLYN SUPPLY CO; and DOES 1 through 10, Inclusive

Case No.:                                23NWLC19496

 

Motion:                                   Motion to Compel Responses to Plaintiff’s First Set of Special Interrogatories; Motion to Compel Responses to Plaintiff’s First Demand for Identification, Production, Inspection and Copying of Documents and Other Things; Requests for Sanctions

Moving Party:                         Plaintiff Creditors Adjustment Bureau, Inc

Responding Party:                   Defendant Llewellyn Industries, Inc.

Notice:                                    OK


 

Tentative Ruling:                    Plaintiff Creditors Adjustment Bureau’s Motion to Compel Responses to Plaintiff’s First Set of Special Interrogatories is GRANTED.

 

Plaintiff’s Motion to Compel Responses to Plaintiff’s First Demand for Identification, Production, Inspection and Copying of Documents and Other Things is GRANTED.

 

                                                Plaintiff’s Motion for Sanctions is GRANTED in part in the amount of $1,645.50.


 

SERVICE: 

 

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

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

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

 

OPPOSITION:          Filed as of February 28, 2024                         [   ] Late          [   ] None 

REPLY:                     Filed as of February 22, 2024                         [   ] Late          [   ] None 

 

BACKGROUND

 

On July 07, 2023, Plaintiff Creditors Adjustment Bureau, Inc. (“Plaintiff”) filed an action against Defendant Llewellyn Industries, Inc. aka Llewellyn Industries Inc dba Llewellyn Supply Company aka Llewellyn Supply Co (“Defendant”) for 1) open book account, 2) account stated, 3) reasonable value, and 4) breach of contract.

 

Defendant filed its Answer to the Complaint on September 15, 2023.

 

On December 20, 2023, Plaintiff filed the instant Motion to Compel Responses to Plaintiff’s First Set of Special Interrogatories; Motion to Compel Responses to Plaintiff’s First Demand for Identification, Production, Inspection and Copying of Documents and Other Things; and Requests for Sanctions for both motions.

 

On February 26, 2024, the Court reassigned the matter to Commissioner Latrice A.G. Byrdsong in Department 25 at the Spring Street Courthouse.

 

On February 27, 2024, the Court on its own motion scheduled the hearings for the motions for April 09, 2024.

 

Defendant files in opposition. Plaintiff files in reply 

 

MOVING PARTY POSITION

 

            Plaintiff prays for the Court to issue an order compelling Defendant to provide responses to Plaintiff’s First Set of Demand for Identification, Production, Inspection, and Copying of Documents and Other Things as well as Plaintiff’s First Set of Special Interrogatories under CCP § CCP §§ 2030.290(b) and 2031.300(b). Plaintiff asserts that Defendant has failed to provide responses to its discovery requests and has not provided substantial justification for its failure to respond. Plaintiff additionally requests the Court issue an order for $1,572.75 in monetary sanctions for each motion for the sum of three hours spent preparing and arguing the motion at a rate of $500.00 per hour plus $72.75 in court fees.

 

OPPOSITION

 

            In opposition, Defendant argues that the motions to compel should be denied as Defendant has already provided verified responses to the Plaintiff’s discovery requests.

 

REPLY

 

            In reply, Plaintiff asserts that sanctions are warranted in this matter as Defendant’s untimely service of discovery responses and opposition serves as an acknowledgement of Defendant and Defense Counsel’s misuse of the discovery process and attempt to avoid the imposition of sanctions.

 

ANALYSIS

 

I.          Legal Standard

A party must respond to interrogatories and requests for production of documents within 30 days after service. (Code Civ. Proc., § 2030.260, subd. (a); Code Civ. Proc., § 2031.260, subd. (a).) If a party to whom interrogatories or requests for production of documents are directed does not provide timely responses, the requesting party may move for an order compelling responses to the discovery. (Code Civ. Proc., § 2030.290, subd. (b); Code Civ. Proc., § 2031.300, subd. (c).) The party also waives the right to make any objections, including one based on privilege or work-product protection. (Code Civ. Proc., § 2030.290, subd. (a); Code Civ. Proc., § 2031.300, subd. (a).) There is no time limit for a motion to compel responses to interrogatories or production of documents other than the cut-off on hearing discovery motions 15 days before trial. (Code Civ. Proc., §§ 2024.020, subd. (a), 2030.290; Code Civ. Proc., § 2031.300.) No meet and confer efforts are required before filing a motion to compel responses to the discovery. (Code Civ. Proc., § 2030.290; Code Civ. Proc., § 2031.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.)

 

II.        Discussion

 

A.         Motion Compelling Responses to Plaintiff’s Special Interrogatories and Demand for Identification, Production, Inspection and Copying of Documents and Other Things

 

            Plaintiff moves to compel Defendant to serve responses to Plaintiff’s First Set of Demand for Identification, Production, Inspection, and Copying of Documents and Other Things (“RFPs”) as well as Plaintiff’s First Set of Special Interrogatories (“Special Interrogatories”). Noting that the motions essentially provide the same facts, the Court will address both motions together in this order.

 

            Plaintiff provides the declaration of its counsel, who states that his office served Defendant with Plaintiff’s RFPs and Special Interrogatories on September 29, 2023. (Mot. Joseph Jyoo Decl. ¶ 2; Exh. 1.) Counsel declares that he emailed defense counsel with the discovery request the same day. (Id. ¶ 3; Exh. 2.) After not receiving Defendant’s responses to Plaintiff’s discovery requests, counsel sent an email on November 10, 2023, demanding that Defendant serve objection free verified responses by November 15, 2023, or Plaintiff would file the instant motions. (Id. ¶ 4; Exh. 3.) Counsel further states that defense counsel responded on November 10, 2023, that he would prepare responses. (Id. ¶ 5; Exh. 4.) However, Counsel avers that as of the date of filing the instant motions, Plaintiff has not received any responses to its discovery requests nor any request for additional time from the Defendant. (Id. ¶ 6.)

             

In opposition, Defendant argues that its responses were electronically mailed on February 13, 2024. (Oppo. p.3:13-15; Exh. 1.) Both responses are verified and include proof of service indicating that the responses were electronically mailed to the Plaintiff. (Id.)

 

In reply, Plaintiff concedes it has received Defendant’s responses, but states that the tardy responses to Plaintiff’s RFPs are not legally sufficient as the responses fail to comply with CCP § 2031.230 and that monetary sanctions are still warranted as Defendant failed to provide substantial justification for the delay. (Reply, pp. 4, 5:22-23.) The Court agrees, noting that Defendant’s responses only provide boiler plate answers stating that “The Responding Party Produced all documents under his possession and control.” (Oppo.; Exh. 1.) Moreover, Defendant’s Responses to the RFPs do not include any of the documents requested in Plaintiff’s RFPs. Additionally, the Court agrees with Plaintiff that the Defendant has failed to respond to Plaintiff’s Special Interrogatory No. 16 as there is no response included for such request. Thus, the Court finds Defendant’s response to Plaintiff’s RFPs and Special Interrogatories are legally insufficient.

 

As the court in Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants noted,  

“If the propounding party proceeds with the motion, …the trial court has the discretion to rule on the motion. The trial court might compel responses without objection if it finds no legally valid responses have been provided to one or more interrogatoriesit might treat the motion as one under section 2030.300 and either determine that further answers are required, or order the propounding party to "meet and confer" (§ 2030.300, subd. (b)) and file a separate statement (Cal. Rules of Court, rule 3.1020(a)(2), (c)); or it might take the motion off calendar, thereby requiring the propounding party to file a motion under section 2030.300.” 

 

(148 Cal.App.4th at pp. 408-409.) 

 

Further, the Court notes that while Defendant has provided verified responses to Plaintiff’s discovery requests, the responses are untimely. Responses are to be served within 30 days after personal service. (Code Civ. Proc., § 2030.260, subd. (a).) Here, responses should have been served by or before October 30, 2023. Noting that Plaintiff’s counsel’s declaration states that no extensions were given to the Defendant, Defendant served its response almost four months after Plaintiff’s discovery request was initially served.

 

Accordingly based on the above, Plaintiff’s requests to compel responses to Plaintiff’s RFPs and Special Interrogatories are GRANTED.

 

B.         Sanctions

           

The Code of Civil Procedure section 2030.290(c) provides in relevant part that, 

 

“The court shall impose a monetary sanction under [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.”

 

(Code Civ. Proc., § 2030.290(c).) CCP section 2031.300(c) similarly provides the same remedy when a party fails to respond to a demand for production of documents. (Code Civ. Proc., § 2031.300(c).) A court may still award sanctions for the failure to timely respond to discovery request despite an opposing party’s attempt to serve tardy responses after the motion has been filed. (Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants, supra, 148 CA4th at 410-411.)

 

            As mentioned above, the Court finds the Defendant’s responses to be tardy and a misuse of the discovery process. Moreover, Defendant does not provide any explanation or otherwise to show that it acted with substantial justification or that other circumstances would make the issuance of sanctions unjust. Thus, the Court finds that sanctions are warranted in this case.

 

Plaintiff prays for the Court to issue monetary sanctions in the amount of $1,572.75 per motion representing three hours in attorney time spent preparing and arguing the motion at a rate of $500.00 per hour plus $72.75 in court fees. The Court finds the amount unreasonable considering the similarities and simplicity of the motions and replies. Therefore, the Court awards sanctions in the total amount of $1,645.50 for two hours spent preparing the motions at a rate of $500 per hour, plus one hour for the appearance fee, and $145.50 in court fees.

 

III.       Conclusion

           

            Plaintiff Creditors Adjustment Bureau’s Motion to Compel Responses to Plaintiff’s First Set of Special Interrogatories is GRANTED.

 

Plaintiff’s Motion to Compel Responses to Plaintiff’s First Demand for Identification, Production, Inspection and Copying of Documents and Other Things is GRANTED.

           

Plaintiff’s Motion for Sanctions is GRANTED, in part, in the total amount of $1,645.50.

 

DEFENDANT IS ORDERED TO PROVIDE CODE COMPLIANT, OBJECTION FREE RESPONSES, TO PLAINTIFF’S SPECIAL INTERROGATORY NO. 16 WITHIN TWENTY (20) DAYS FROM NOTICE OF THIS COURT’S ORDER.

 

DEFENDANT IS FURTHER ORDERED TO RESPOND TO PLAINTIFF’S FIRST SET OF DEMAND FOR IDENTIFICATION, PRODUCTION, INSPECTION, AND COPYING OF DOCUMENTS AND OTHER THINGS WITH CODE COMPLIANT, OBJECTION-FREE VERIFIED RESPONSES WITHIN TWENTY (20) DAYS FROM NOTICE OF THIS COURT’S ORDER.

 

DEFENDANT IS ADDITIONALLY ORDERED TO PAY PLAINTIFF SANCTIONS IN THE AMOUNT OF $1,645.50 WITHIN THIRTY (30) DAYS FROM NOTICE OF THIS COURT’S ORDER.

 

Moving party is ordered to give notice.

 

TRIAL SETTING CONFERENCE


Pursuant to oral stipulation, the Court orders the Trial set in this action as follows:

Trial is set for January 7, 2025 at 8:30 a.m. in Department 25 of the Spring Street Courthouse.

Discovery and all other trial related deadlines are to comport with the new trial date.

 Parties must comply with the trial requirements as set forth in the court's Third Amended Standing Order for Limited Civil Cases (effective February 24, 2020).

 All trial documents are to be electronically filed at least ten (10) days prior to the trial date.

 Parties should be prepared to submit a JOINT Trial Readiness Binder / Exhibit Binder, and to personally appear on the date of trial.