Judge: Michael P. Linfield, Case: 20STCV49110, Date: 2023-08-14 Tentative Ruling

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Case Number: 20STCV49110    Hearing Date: August 14, 2023    Dept: 34

SUBJECT:         Motion to Compel Responses to Special Interrogatories Propounded

 

Moving Party:  Defendant/Cross-Complainant The Berman Law Group, APC

Resp. Party:    None

                                     

 

The SROGs Motion is GRANTED. Plaintiff/Cross-Defendant is ORDERED to serve answers, without objections, to these discovery requests within 14 days of the issuance of this Order.

 

The Request for Sanctions is DENIED.

 

BACKGROUND:

 

On December 23, 2020, Plaintiff Michael Waddington, in propria persona, filed his Complaint against Defendants The Berman Law Group, APC, Brett A. Berman, and Seri Kattan-Wright on causes of action arising from Plaintiff’s prior use of Defendants’ legal services.

 

On February 9, 2021, Plaintiff filed his First Amended Complaint.

 

On January 24, 2022, Defendant/Cross-Complainant The Berman Law Group, APC filed its Cross-Complaint against Plaintiff/Cross-Defendant Michael Waddington.

 

On July 12, 2022, pursuant to the Parties’ Stipulation, Plaintiff/Cross-Defendant filed his Second Amended Complaint.

 

On July 21, 2022, Plaintiff/Cross-Defendant amended his Second Amended Complaint to substitute Doe 1 with Nigro Karlin Segal Feldstein LLC (“NKSF”).

 

On January 13, 2023, the Court granted Defendants NKSF’s and Irwin Nachimson’s Motion to Compel Arbitration and Stay Proceedings. The Court ordered Plaintiff and Defendants NKSF and Irwin Nachimson to arbitrate and stayed the proceeding as to those parties.

 

On July 19, 2023, Defendant/Cross-Complainant filed its Motion to Compel Responses to Special Interrogatories Propounded (“SROGs Motion”). 

 

No opposition or other response has been filed to the SROGs Motion.

 

ANALYSIS:

 

I.           Legal Standard

 

California Code of Civil Procedure requires a response from the party to whom form interrogatories, special interrogatories, and demand requests are propounded within 30 days after service of the requests, unless the time is extended by agreement of the parties. (Code Civ. Proc., §§ 2030.260, subd. (a), 2030.270, subd. (a), 2031.260, subd. (a), 2031.270, subd. (a).) If a party fails to serve timely responses, "the party making the demand may move for an order compelling response to the demand.” (Code Civ. Proc., § 2030.300, subd. (b).) By failing to respond, the offending party waives any objection to the demand. (Code Civ. Proc., § 2030.290, subd. (a).)

 

For a motion to compel, all a propounding party must show is that it properly served its discovery requests, that the time to respond has expired, and that the party to whom the requests were directed failed to provide a timely response. (See Leach v. Super. Ct. (1980) 111 Cal.App.3d 902, 905, 906.) Indeed, "[o]nce [a party] 'fail[ed] to serve a timely response,' the trial court had authority to grant [opposing party's] motion to compel responses." (Sinaiko Healthcare Counseling, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 405.)

 

The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel motions for interrogatories or requests for production, 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. If a party then fails to obey an order compelling answers, 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). (Code Civ. Proc., §§ 2030.290, subd. (c), 2031.300, subd. (c).)¿ 

 

II.        Discussion

 

a.          Motion

 

On March 20, 2023, Defendant/Cross-Complainant served Plaintiff/Cross-Defendant with special interrogatories (“SROGs”). (SROGs Motion, Exh. A, Proof of Service.)

 

        Counsel for Defendant/Cross-Complainant declares that no response has been served to the SROGs, despite multiple extensions given. There is no evidence before the Court that would indicate responses to the SROGs have been served.

 

The Court finds that Plaintiff/Cross-Defendant failed to timely respond to the SROGs.

 

The Court GRANTS the SROGs Motion. The Court ORDERS Plaintiff/Cross-Defendant to serve answers, without objections, to these discovery requests within 14 days of the issuance of this Order.

 

b.          Sanctions

 

Given that Plaintiff/Cross-Defendant is pursuing this matter in propria persona, monetary sanctions would not be appropriate here. “Providing access to justice for self-represented litigants is a priority for California courts.”¿¿(Cal. Rules of Court, rule 10.960(b).)  further, to the pro per litigant, “interrogatories, requests for admissions, law and motion proceedings, and the like” are “baffling devices.”¿¿(Bruno v. Super. Ct. (1990) 219 Cal.App.3d 1359, 1363, quoting¿Burley v. Stein¿(1974) 40 Cal.App.3d 752, 755, fn. 3.)

 

In addition, the argument section of this motion is one-page long.  The only citation is to CCP §2030.290.  (See Motion, p. 4.)  Defense counsel was admitted to the bar 21 years ago.  (See https://apps.calbar.ca.gov/attorney/Licensee/Detail/219626.)  The Court does not believe that an experienced attorney would need 2.5 hours to prepare this routine motion as stated in his declaration.  (See Rinka Declaration, ¶ 10.)

 

The Court DENIES the Request for Sanctions.

 

 

III.     Conclusion

 

The SROGs Motion is GRANTED. Plaintiff/Cross-Defendant is ORDERED to serve answers, without objections, to these discovery requests within 14 days of the issuance of this Order.

 

The Request for Sanctions is DENIED.