Judge: Margaret L. Oldendorf, Case: 21GDCV00782, Date: 2023-03-21 Tentative Ruling
Case Number: 21GDCV00782 Hearing Date: March 21, 2023 Dept: P
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
NORTHEAST DISTRICT
I. INTRODUCTION
This lemon law case concerns
Plaintiff’s purchase of a 2019 Chevrolet Silverado. The pleading alleges
defects concerning the tire pressure monitoring system, display system, audio
system, engine system, and electrical system.
Prior to the transfer of this case,
Judge Rosen (Dept. E, Glendale Courthouse) issued an extensive order on Plaintiff’s
motion to compel further responses to Requests for Production, Set Two. (The July
22, 2022 Order.)
Plaintiff now seeks an order
compelling compliance with the July 22, 2022 Order. Plaintiff also requests
$500 daily sanctions for every day the order is not complied with following a
10-day compliance period.
There is no authority for compelling compliance with
a discovery order. If a discovery order is disobeyed the next step is to seek
issue, evidence, or terminating sanctions. The motion is therefore denied.
II. LEGAL
STANDARD
The motion cites Code Civ. Proc. §2031.310 in support of
the relief requested. That statute provides the following:
(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.
. . .
(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.
. . .
(i) Except as provided in
subdivision (j), if a party fails to obey an order compelling further
response, 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).
III. ANALYSIS
As the statute makes clear, when a party fails to comply
with an order to compel further responses to demands for production, the
propounding party may seek issue, evidence, or terminating sanctions. None of
those are sought by this motion. There is no provision in the Discovery Act for
an order compelling compliance with a discovery order.
Plaintiff cites a few cases in support of his motion. None
are directly applicable. In Lopez v.
Watchtower Bible & Tract Society of New York, Inc. (2016) 246
Cal.App.4th 566, the trial court granted a terminating sanction when the
defendant failed to comply with a discovery order. In reversing, the appellate
court noted that the imposition of discovery sanctions should be incremental
and that when faced with willful disobedience such as was exhibited by the
defendant (steadfastly refusing to produce documents and continuing to assert
objections that had been overruled), the trial court could have imposed
significant monetary damages for each day the defendant refused to look for or
produce documents. Here, there is no
evidence that Defendant refused to look for and produce documents. If there had
been evidence of such willful disobedience, Plaintiff could potentially have
sought daily sanctions at that time. But that is not what happened. Instead,
the evidence is that Defendant GM did provide supplemental responses,
albeit late. (Supplemental responses
were due September 5, 2022 and were served September 7, 2022, and verified
September 8, 2022.)
It
is the view of Plaintiff’s counsel that the supplemental responses were not
code-compliant and that the document production was incomplete. Counsel
expressed this view in a meet and confer letter following receipt of the
supplemental responses. Declaration of Alessandro Manno, ¶7 and Exhibit 3
thereto. If those meet and confer efforts were unsuccessful a motion to compel
further responses could have been filed as to the supplemental responses.
However, the 45-day period for doing so has long ago expired. Further, neither
the meet and confer letter nor this motion make clear in what way the
supplemental responses are not code-compliant. As for the production itself (which
is not directly at issue on a motion to compel further responses), Plaintiff
seems to assume that emails exist and have not been produced. It is not clear how
Plaintiff, or this Court, could know that.
Plaintiff has not presented any evidence to support his assertion in
this regard.
In sum, Lopez does not provide legal authority for
an order compelling Defendant to comply with the July 22, 2022 Order; nor does
it provide authority for the imposition of daily sanctions five months after
Defendant provided supplemental responses.
Stephen Slessinger, Inc. v. Walt Disney Company
(2007) 155 Cal.App.4th 736 involves outrageous discovery conduct. There, the
plaintiff hired a private investigator who, over the course of a few years,
pilfered thousands of documents by breaking into Disney buildings and taking
confidential papers from secure trash receptacles. The trial court issued a
terminating sanction, which was affirmed on appeal. This case is
distinguishable factually as there is no such egregious discovery abuse here. Further, this case does not support the imposition
of a daily monetary sanction.
The other case Plaintiff relies on is a federal action
and thus is not controlling here. See
Grimes v. City and County of San Francisco (1991) 951 F.2d 236.
IV. CONCLUSION
AND ORDER
Code Civ. Proc. §2031.310 does not provide for an order
compelling Defendant to comply with the July 22, 2022 Order. It also does it
provide authority for the imposition of $500 daily sanctions. Lopez does
not provide authority for an order compelling compliance with the July 22, 2022
Order; at most, it provides support for daily monetary sanctions where willful
disobedience of a court order has been established.
Plaintiff’s motion to compel compliance with the July 22,
2022 Order is denied.
Defendant is ordered to give notice of this ruling.
Dated: _______________________________
MARGARET L. OLDENDORF
JUDGE
OF THE SUPERIOR COURT