Judge: Michael Shultz, Case: 23STCV25758, Date: 2025-04-25 Tentative Ruling

Case Number: 23STCV25758    Hearing Date: April 25, 2025    Dept: 40

23STCV25758 MARK A. SPIEGEL, et al. vs JEFFREY SELTZER, et al.

Friday, April 25, 2025

[TENTATIVE] ORDER GRANTING DEFENDANT/CROSS-COMPLAINANT JEFFREY SELTZER’S MOTION TO COMPEL DEPOSITIONS OF PLAINTIFFS/CROSS-DEFENDANTS MARK SPEIGEL AND LINDA SPIEGEL [Res. No. -7991]

 

                                                                                         I.         BACKGROUND

      This action is a dispute between neighbors concerning whether Civil Code §841, the “Good Neighbor Fence Act,” is applicable at all, and whether either neighbor has one or more easements by prescription or by implication over the property of the other. Plaintiffs Mark Spiegel and Linda Spiegel (collectively, “Plaintiffs”) filed the Complaint on October 23, 2023, against Defendants Jeffrey Seltzer, individually and as Trustee of the Seltzer Family Trust dated June 13, 2011; Mortgage Electronic Registration Systems, Inc.; Old Republic Title Company; and DOES 1 through 20 (collectively, “Defendants”) seeking quiet title, declaratory relief, and injunctive relief.

      On August 26, 2024, Cross-Complainant Jeffrey Seltzer filed a Cross-Complaint against Plaintiffs and Roes 1 through 5 alleging trespass and seeking declaratory relief.

                                                                                          II.        ARGUMENTS

A.     Motion filed April 01, 2025.

       Defendant/Cross-Complainant Jeffrey Seltzer (“Seltzer”) move for an order from the Court compelling the depositions of Plaintiffs/Cross-Defendants Mark Spiegel and Linda Spiegel, pursuant to Civil Procedure Code §§2024.050(a) and 2025.450(a), and further ordering Plaintiffs to appear for deposition by Seltzer’s counsel during the week beginning on Monday, April 28, 2025, and ending on Friday, May 2, 2025. (Not. of Mot. 1:4-10.) Seltzer further argues that good cause exists for the order even though the initial discovery cut-off was March 8, 2025, because Plaintiff’s counsel agreed to waive the discovery cut-off for those depositions. (Id. at 2:11-15.) Moreover, the Plaintiffs’ depositions were stonewalled on five different occasions prior to the discovery cutoff date. (Id. at 2:15-21.) Also, when settlement efforts did not succeed, the Plaintiffs’ counsel objected to the notice of deposition served immediately afterward on the ground that the depositions were set for dates after the discovery cutoff. (Id.)

B.     Opposition filed April 16, 2025.

      The Court notes that the opposition is untimely as it was not filed within nine court days before the hearing. (See Cal. Code of Proc. § 1005.)

      Plaintiffs argue that the motion is untimely because there was no agreement for a discovery motion extension. (Opp. 2:4-7.) Plaintiffs further argue that Defendant’s counsel did not make a meaningful meet and confer effort. (Id. at 2:9-10.) Plaintiffs further argue that Defendant Seltzer would not authorize his counsel to enter into the written stipulation required by the code to extend the discovery cutoff date which was to be made in conjunction with a trial continuance. (Id. at 2:11-14; Garcia Decl. ¶¶ 9-12.) Plaintiffs also argue that even if the Court were to find an agreement existed for a discovery extension, it was conditioned on the taking of deposition of Seltzer between the depositions of Plaintiffs. (Id. at 2:15-18.) Lastly, Plaintiffs argue that Plaintiff Mark Spiegel’s health issues prevent him from being deposed. (Id. at 2:18-20.)

C.     No Reply Filed As of April 23, 2025

                                                                                       III.       LEGAL STANDARDS

      California Code of Civil Procedure § 2025.450(a) provides the following: “If, after service of a deposition notice, a party to the action . . . without having served a valid objection . . .fails to appear for examination, or to proceed with it, . . . the party giving notice may move for an order compelling the deponent’s attendance and testimony. . ..” (California Code of Civil Procedure § 2025.450(a).)

                                                                                                IV.       DISCUSSION

      A. Timeliness

      The motion is timely. Here, the Court notes that the initial discovery cut off was March 8, 2025, as trial was set for April 8, 2025. On March 26, 2025, upon Plaintiffs’ counsel orally requested a trial continuance which the Court granted. Trial is now set for May 12, 2025. The Court notes that it did not extend the discovery cut-off, however, on February 27, 2025, Plaintiffs’ counsel agreed to an extension. (Yates Decl. ¶12; Ex. 9 [February 27, 2025, Email Correspondence].) Specifically, Defendant’s counsel asked “I noted this morning that the Spiegel depositions are currently set for March 3 and March 4. Given that we are meeting on March 7 to try to resolve this dispute, it seems to me that these depositions should be continued in the hope that they will not be needed. The only problem is that the discovery cutoff in this case is March 8. Will you agree to waive the discovery cutoff as to these depositions, in case we are unable to resolve the matter next Friday?” (Id.) Plaintiffs’ counsel responded “I would agree to that. Mary, we have more written discovery responses due next week. Would you be willing to agree to continue them as well? We may need to submit a stipulation to the Court to continue the trial for a short time, although both sides have been resistant to that until now.” (Id.) Therefore, Plaintiffs’ Counsel’s argument that this agreement was a conditional offer based on a trial continuance is unpersuasive. Counsel fails to provide evidence showing that his written response on February 27, 2025, was conditional upon a Stipulation for a trial continuance. Rather his response, “I would agree to that” shows that he was explicitly agreeing to the cutoff date extension because in the next sentence he requests an extension for discovery responses and asks whether Defendant’s counsel would be willing to “continue them as well.” (Id.) Plaintiffs argument that no cut-off waiver exists because Defendant Seltzer did not authorize his counsel to waive the discovery cut-off date is without merit. (Opp. 3:21-23.) The Court is unable to locate any legal authority requiring a personal waiver and Plaintiffs failed to provide any legal authority for such claim. Therefore, the motion is timely.

      B. Meet and Confer

      The motion shall be accompanied by a meet and confer declaration under Section 2016.040, or, when the deponent fails to attend the deposition and produce the documents, electronically stored information, or things described in the deposition notice, by a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Here, Defendant’s counsel submits his declaration showing that he emailed Plaintiffs’ counsel after reserving a hearing date for the motion reminding him about the discovery extension. (Yates Decl. ¶5.) Although Plaintiff argues that the meet and confer efforts were not meaningful because Defendant’s counsel was aware that he was in trial, he fails to provide any authority showing that being in trial prevents a meaningful meet and confer from taking place. Thus, the Court finds the meet and confer efforts were sufficient.

      C. Good Cause Exists to Compel Depositions of Plaintiffs Mark Spiegel and Linda Spiegel

      Defendant has shown good cause to compel the depositions of both Plaintiffs Mark Spiegel and Linda Spiegel. Here, Defendant’s Counsel submitted copies of the six deposition notices served from November 2024 to March 2025 for both Plaintiffs. (Yates Dec. ¶¶ 7- 13, Ex. 1, 4 – 9.) Further, Defendant’s Counsel presented evidence showing that Plaintiffs’ Counsel waived the discovery cut-off so that Plaintiffs could be deposed in case the settlement negotiations were unsuccessful. (Yates Decl. ¶12; Ex. 9 [February 27, 2025, Email Correspondence].) The Court further notes that Plaintiffs have not submitted any evidence showing that Plaintiff Mark Spiegel is currently unable to attend a deposition due to his illness. Moreover, Plaintiffs fail to provide any evidence showing that Linda Spiegel is also unavailable for the deposition. Based on the foregoing, Defendant is entitled to take Plaintiffs’ depositions.

                                                                                          V.        CONCLUSION

      The Court GRANTS Defendant’s Motion to Compel Plaintiffs Mark Spiegel and Linda Spiegel’s Depositions.

 





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