TENTATIVE RULING

Plaintiff Jonathan Shapiro’s Motion to Compel Responses to Special Interrogatories, Set One [as to Defendant Danyel Benhaghnazar] is GRANTED. Defendant Danyel Benhaghnazar shall provide code-complaint responses to Plaintiff Jonathan Shapiro’s Special Interrogatories, Set One, without objections, within thirty (30) days of entry of this order.

Plaintiff Jonathan Shapiro’s Request for Monetary Sanctions [as to Defendant Danyel Benhaghnazar] is GRANTED in the reduced amount of $510, payable by Defendant Danyel Benhaghnazar to Plaintiff Jonathan Shapiro and Plaintiff’s counsel within thirty (30) days of entry of this order.

Plaintiff Jonathan Shapiro’s Motion to Compel Responses to Special Interrogatories, Set One [as to Defendant Stella Yaghoubzadeh] is GRANTED. Defendant Stella Yaghoubzadeh shall provide code-complaint responses to Plaintiff Jonathan Shapiro’s Special Interrogatories, Set One, without objections, within thirty (30) days of entry of this order.

Plaintiff Jonathan Shapiro’s Plaintiff Jonathan Shapiro’s Request for Monetary Sanctions [as to Defendant Stella Yaghoubzadeh] is GRANTED in the reduced amount of $510, payable by Defendant Stella Yaghoubzadeh to Plaintiff Jonathan Shapiro and Plaintiff’s counsel within thirty (30) days of entry of this order.

Plaintiff Jonathan Shapiro to give notice.

REASONING

If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. (Code Civ. Proc., § 2030.290, subds. (b), (c).) Failure to timely respond waives all objections, including privilege and work product, unless “[t]he party has subsequently served a response that is in substantial compliance” and “[t]he party’s failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect.” (Code Civ. Proc., § 2030.290, subd. (a).) The statute contains no time limit for a motion to compel where no responses have been served. All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. (Leach v. Superior Court (1980) 111 Cal.App.3d 902, 905-906.)

Plaintiff Jonathan Shapiro (“Plaintiff”) served Defendants Danyel Benhaghnazar and Stella Yaghoubzadeh (“Defendants”) with his Special Interrogatories, Set One on October 31, 2024. (Mots., Keeler Decls. ¶ 2.) Responses were due on or before December 5, 2024. (Mots., Keeler Decls. ¶ 3.) To date, no responses have been received. (Mots., Keeler Decls. ¶ 4.) Accordingly, Plaintiff Jonathan Shapiro’s Motions to Compel Responses to Special Interrogatories, Set One are GRANTED. Defendants Danyel Benhaghnazar and Stella Yaghoubzadeh shall provide code-complaint responses to Plaintiff Jonathan Shapiro’s Special Interrogatories, Set One, without objections, within thirty (30) days of entry of this order.

If a motion to compel responses to interrogatories is filed, the Court may impose a monetary sanction against the losing party “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, subd. (c).) Further, “[t]he court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed.” (Cal. Rules of Court, rule 3.1348(a).)

Plaintiff requests $660 in monetary sanctions for each motion. The Court finds that monetary sanctions are proper, but the Court reduces the amount to $510, representing one hour spent preparing each motion and one half-hour spent appearing at the hearing as to each motion, totaling one-and-a-half hours at the rate of $300 per hour, as well as one $60 filing fee. Thus, Plaintiff Jonathan Shapiro’s Requests for Monetary Sanctions are GRANTED in the reduced amount of $510 as to each motion, with $510 payable by Defendant Danyel Benhaghnazar and $510 payable by Defendant Stella Yaghoubzadeh to Plaintiff Jonathan Shapiro and Plaintiff’s counsel within thirty (30) days of entry of this order.