Judge: Michael Shultz, Case: 24STCV14631, Date: 2025-01-14 Tentative Ruling

Case Number: 24STCV14631    Hearing Date: January 14, 2025    Dept: 40

24STCV14631 Charles Lee, dba Master Group v. The Estate of Wayne Nelson, et al.

Tuesday, January 14, 2025 at 8:30

 

[TENTATIVE] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL DEFENDANT, ESTATE OF WAYNE NELSON’S RESPONSES TO FORM INTERROGATORIES, SET ONE, AND REQUEST FOR IMPOSITION OF MONETARY SANCTIONS

 

[TENTATIVE] ORDER GRANTING PLAINTIFF’S MOTION TO DEEM ADMITTED DEFENDANT, ESTATE OF WAYNE NELSON’S RESPONSES TO REQUESTS FOR ADMISSION AND REQUEST FOR IMPOSITION OF MONETARY SANCTIONS

 

                                                                                        I.          BACKGROUND

The complaint alleges Plaintiff agreed to make upgrades and repairs to Defendant’s property. Defendant subsequently died causing Plaintiff to send invoices to the parties responsible for Defendant’s estate.  As the Estate of Wayne Nelson failed to pay for services, Plaintiff filed a mechanics lien against the property. Plaintiff alleges claims for breach of contract, foreclosure of mechanics lien, quantum meruit, and declaratory relief for the recovery of $232,000 owed to Plaintiff.

On September 13, 2024, Plaintiff served form interrogatories and requests for admission on Defendant, Estate of Wayne Nelson, (“Estate”). Defendant failed to respond.  Plaintiff requests an order compelling responses to the form interrogatories, for a deemed admitted order, and for imposition of sanctions.

Defendant argues that there has been a problem receiving email communications from Plaintiff beginning October 9, 2024. Defendant timely served responses, but Plaintiff did not receive them.  Defendant offered to re-send them. Defendant was not aware this motion had been served until conducting an audit of this matter on January 2, 2025. Defendant served responses by email and U.S. Mail. Defendant acted in good faith and the request for monetary sanctions should be denied.

In reply, Plaintiff argues that responses, due on October 18, 2024, have never been received. Defendant’s oppositions are untimely filed. Defendant did not provide the court with any proof that responses were sent to Plaintiff.  

                                                                                         II.          DISCUSSION

Where a party fails to timely respond to interrogatories, the court has authority to compel a response. (Code Civ. Proc., §2030.290(b).)  Untimely responses result in a waiver of objections. (Code Civ. Proc., § 2030.290(a).)  Defendant has not provided any proof that responses were timely served and re-served upon discovery of the email communication problems.

Where a party fails to respond to requests for admission, the court can deem the requests admitted against the non-responding party unless it finds that the non-responding party has subsequently served, before the hearing, a proposed response to the requests that substantially complies with statutory requirements. (Code Civ. Proc., § 2033.280 subd. (c).) There is no evidence that Defendant served responses prior to the hearing.

Imposition of sanctions is mandatory where a party’s failure to respond to the requests necessitates the motion. (Code Civ. Proc., § 2033.280 subd. (c).)   

While Plaintiff’s counsel charges an hourly rate of $475 per hour, the Court finds that $400 per hour is a reasonable rate for routine, non-complex discovery motions. The Court finds that three hours to prepare each motion and reply brief and to appear are reasonable.

                                                                                      III.          CONCLUSION

For the foregoing reasons the Court GRANTS both motions. Defendant, Estate of Wayne Nelson, is ordered to serve within 10 days, verified responses to form interrogatories, set one, without objection. The requests for admission served on Defendant, Estate of Wayne Nelson, are deemed admitted. The court imposes total sanctions against Defendant, Estate of Wayne Nelson, and counsel Law Offices of Loyst Fletcher, jointly and severally in the total amount for both motions of $2,925.00 (3 hours to prepare each motion and reply for a total of 6 hours, and 1 hour to appear for a total of 7 hours x $400) plus total costs of $125 ($62.50 in filing fees for each motion). Sanctions are payable to Plaintiff’s counsel within 10 days.