Judge: Nathan R. Scott, Case: Uzunyan v. Kingsley, Date: 2022-11-18 Tentative Ruling

Plaintiff Grigor Uzunyan’s motion to compel is granted in part.

Defendant Margo Kingsley shall serve complete, code-compliant, verified further responses without objection to plaintiff’s special interrogatories (set one) #3-8 within 15 days.

Defendant shall pay $1060 in discovery sanctions to plaintiff.

Plaintiff made an adequate effort to meet and confer.  (See Azoian decl. ¶¶ 4-5 & Ex. C.) 

Parties may use interrogatories to ascertain the other parties’ contentions and “the facts, witnesses, and writings” on which they are based.  (Code Civ. Proc., § 2030.010, subd. (b).)  Contention interrogatories are “formidable” and “effective” discovery tools.  (Weil & Brown, Cal. Practice Guide:  Civ. Proc. Before Trial (The Rutter Group 2020) ¶ 8:990.)

Defendant has not shown it lacked a reasonable time to obtain sufficient information to respond to the interrogatories about the auto accident’s cause.  Defendant knows whether she was involved in the accident.  Defendant’s insurer accepted liability for the accident two years ago.  (See Reply Ex. A.)

On the other hand, the motion is denied as to special interrogatories #15-19.  Those request defendant’s contentions about the causes of plaintiff’s injuries.  As defendant notes, it has not had a reasonable chance to depose plaintiff or conduct a physical examination to pin down what those injuries are.

The sanctions amount is modest and adequately supported, even given the mixed results on the motion.

Plaintiff shall give notice.