Judge: Lee S. Arian, Case: 22STCV30547, Date: 2023-11-07 Tentative Ruling

Case Number: 22STCV30547    Hearing Date: March 19, 2024    Dept: 27

Complaint Filed:      9/19/22

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Hon. Lee S. Arian¿¿¿¿¿¿ 

Department 27¿¿¿¿¿¿ 

Tentative Ruling¿¿¿¿¿¿ 

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Hearing Date:           3/19/2024 at 1:30 p.m.¿¿¿¿¿¿ 

Case No./Name:       22STCV30547 ROBERT WILLIAMSON vs GLS US FREIGHT, INC 

Motion:                    MOTION TO COMPEL DEPOSITION OF DEFENDANT FRANCISCO ESCALANTE AND FOR SANCTIONS

Moving Party:           Plaintiff¿ 

Responding Party:    Defendants

Notice:                     Sufficient¿¿¿¿¿¿ 

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Ruling:                     MOTION TO COMPEL DEPOSITION OF DEFENDANT FRANCISCO ESCALANTE IS GRANTED.

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¿                               REQUEST FOR SANCTIONS IS GRANTED.

 

 

Background 

 

On September 19, 2022, Plaintiff filed the present case, alleging Defendant Francisco Escalante's negligent operation of a forklift caused Plaintiff injuries. On March 10, 2023, Plaintiff first requested Defendant Francisco Escalante's availability, then noticed his deposition on March 24, 2023, after not hearing from defense counsel. Defendant did not serve a written objection to the notice of deposition. On March 29, 2023, Defendant’s counsel emailed Plaintiff's counsel stating Escalante is unavailable. When asked by Plaintiff about Defendant Escalante's availability, Defendant’s counsel ignored Plaintiff's requests. On May 25, 2023, Plaintiff filed the present motion to compel Escalante’s deposition.

 

Defendant argues that since Plaintiff filed his motion, Defendant attempted to meet and confer with Plaintiff and even tried to produce Defendant Escalante for a deposition in November 2023 on a Saturday, but Plaintiff refused.  Since then, Defendant’s counsel has apparently lost contact with Defendant, but counsel has made no affirmative efforts to address the issue, such as through a motion to withdraw.

 

Legal Standard 

 

Any party may obtain any discovery of information, documents, land, property, or electronically stored information so long as the discoverable matter is not privileged, is relevant to the subject matter and can lead one to admissible evidence.¿(Code Civ. Proc. § 2017.010.)¿¿¿ 

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Code Civ. Proc., § 2025.450¿provides in pertinent part the following:¿¿¿¿ 

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“(a) If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed with it, or to produce for inspection any document, electronically stored information, or tangible thing described in the deposition notice, the party giving the notice may move for an order compelling the deponent's attendance and testimony, and the production for inspection of any document, electronically stored information, or tangible thing described in the deposition notice.¿¿¿ 

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

 

(1) The motion shall set forth specific facts showing good cause justifying the production for inspection of any document, electronically stored information, or tangible thing described in the deposition notice.¿¿¿ 

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

 

 

Analysis 

 

Defendant does not dispute that on March 24, 2023, Plaintiff noticed Escalante's deposition for April 18, 2024, or that no written objection was served to the notice of deposition, or that Escalante did not attend the deposition on April 18, 2024. Defendant's argument is that its counsel was not able to establish contact with Escalante and when he did in November of 2023, he made Escalante's availability known, but Plaintiff refused to conduct the deposition. In reply, Plaintiff argues that while Defendant offered Escalante's availability for a deposition, Defendant also offered to stipulate to liability, thereby making the deposition unnecessary. However, Defendant thereafter refused to fully stipulate after Escalante was no longer available.

 

Plaintiff has met all the requirements to move the court to compel deposition under § 2025.450, which provides for an order to compel attendance and testimony when a party to the action notices a deposition and, without having served a valid objection under Section 2025.410, the other party fails to appear for examination, or to proceed with it.  Furthermore, Defendant does not dispute that good cause is shown under § 2025.450(b)(1) as Escalante is allegedly the individual that caused Plaintiff's injuries. Defendant's argument might be relevant to § 2025.450(b)(2), as Defendant calls Plaintiff's good faith meet and confer efforts into question. Both parties presented evidence that neither side is now meeting and conferring in good faith, but the fact is that the parties have been meeting and conferring for over a year through various mediums since the notice was served in March 2023. A deposition still has not been scheduled a year later when the trial date is set for June 10, 2024. It is clear that whatever method the parties are using to resolve the issue of deposition, it has been ineffective and, at this point, it is appropriate for the Court to intervene and order the deposition, with potential contempt implications for witness Escalante. 

The Court finds that Plaintiff fulfilled the necessary requirements of § 2025.450 for a motion to compel. Therefore, the motion is GRANTED and Escalante is ordered to appear for deposition within 20 days of today's date or such later date as agreed by the parties.

Sanctions

Plaintiff was required to incur attorney’s fees in bringing forth the present motion. Plaintiff requests $6947.50 in sanctions. The Court exercises its discretion and lowers the sanction to $2000 given the issues raised in the Opposition. Defendant Escalante and his  counsel are ORDERED, jointly and severally, to pay sanctions of $2000 to Plaintiff within 20 days of today’s date.

 

¿PLEASE TAKE NOTICE:¿¿¿¿¿¿¿ 

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If a party intends to submit on this tentative ruling,¿the party must send an email to the court at¿sscdept27@lacourt.org¿with the Subject line “SUBMIT” followed by the case number.¿ The body of the email must include the hearing date and time, counsel’s contact information, and the identity of the party submitting.¿¿¿¿¿¿¿¿¿ 

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Unless¿all¿parties submit by email to this tentative ruling, the parties should arrange to appear remotely (encouraged) or in person for oral argument.¿ You should assume that others may appear at the hearing to argue.¿¿¿¿¿¿¿¿¿ 

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If the parties neither submit nor appear at hearing, the Court may take the motion off calendar or adopt the tentative ruling as the order of the Court.¿ After the Court has issued a tentative ruling, the Court may prohibit the withdrawal of the subject motion without leave.¿¿¿¿¿¿¿¿