Judge: Peter A. Hernandez, Case: 23STCV16078, Date: 2024-09-06 Tentative Ruling

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Case Number: 23STCV16078    Hearing Date: September 6, 2024    Dept: 34

The Motions for Terminating Sanctions are GRANTED in part.

 

The Answers of Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez are STRICKEN.

 

Default is ENTERED on Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez.

 

The Motions for Terminating Sanctions are DENIED as to all else.

 

BACKGROUND:

 

            On July 10, 2023, Plaintiff Hector Gonzalez filed his Complaint against Defendant Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, Filipe Rodriguez, and First Choice Interlock, Inc. on causes of action arising from the Parties’ business contracts and interactions.

 

            On September 13, 2023, by request of the Plaintiff, the Clerk’s Office entered default on Defendant First Choice Interlock, Inc.

 

            On December 22, 2023, Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez filed their respective Answers to the Complaint.

 

            On April 23, 2024, the Court granted Plaintiff’s discovery motions as to Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez.

 

            On May 10, 2024, Plaintiff filed three substantively-identical motions, each titled “Motion for Terminating Sanctions for Failure to Respond to Form Interrogatories and Request for Production After Being Ordered to Do So, and for Attorney’s Fees and Costs” (“Motion for Terminating Sanctions”).

 

            On June 4, 2024, Plaintiff filed Declaration of Mark Henry Shafron Regarding Non-Receipt of Opposition.

 

            No oppositions or other responses have been filed regarding the Motions for Terminating Sanctions.

 

ANALYSIS:

 

I.                Legal Standard

 

 

 

 

 

Code of Civil Procedure section 2023.030 gives the court the discretion to impose sanctions against anyone engaging in a misuse of the discovery process. A court may impose terminating sanctions by striking pleadings of the party engaged in misuse of discovery or entering default judgment. (Code Civ. Proc., § 2023.030, subd. (d).) A violation of a discovery order is sufficient for the imposition of terminating sanctions. (Collison & Kaplan v. Hartunian (1994) 21 Cal.App.4th 1611, 1620.) Terminating sanctions are appropriate when a party persists in disobeying the court's orders. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 795–796.)

 

A terminating sanction is a "drastic measure which should be employed with caution." (Deyo, supra, at p. 793.)

 

"A decision to order terminating sanctions should not be made lightly. But where a violation is willful, preceded by a history of abuse, and the evidence shows that less severe sanctions would not produce compliance with the discovery rules, the trial court is justified in imposing the ultimate sanction." (Mileikowsky v. Tenet Healthsystem (2005) 128 Cal.App.4th 262, 279–280.)

 

While the court has discretion to impose terminating sanctions, these sanctions "should be appropriate to the dereliction and should not exceed that which is required to protect the interests of the party entitled to but denied discovery." (Deyo, supra, 84 Cal.App.3d at p. 793.) "[A] court is empowered to apply the ultimate sanction against a litigant who persists in the outright refusal to comply with his discovery obligations." (Id.) Discovery sanctions are not to be imposed for punishment, but instead are used to encourage fair disclosure of discovery to prevent unfairness resulting for the lack of information. (See Midwife v. Bernal (1988) 203 Cal.App.3d 57, 64 [superseded on other grounds as stated in Kohan v. Cohan (1991) 229 Cal.App.3d 967, 971.)

 

"A trial court has broad discretion to impose discovery sanctions, but two facts are generally prerequisite to the imposition of nonmonetary sanctions . . . (1) absent unusual circumstances, there must be a failure to comply with a court order, and (2) the failure must be willful." (Biles v. Exxon Mobil Corp. (2004) 124 Cal.App.4th 1315, 1327; but see Reedy v. Bussell (2007) 148 Cal.App.4th 1272, 1291 ["willfulness is no longer a requirement for the imposition of discovery sanctions."].)

 

II.             Discussion

 

Plaintiff moves the Court to issue terminating sanctions by striking each of these three Defendants’ respective Answers, entering default on all of them, and ordering them to pay monetary sanctions. (Motions for Terminating Sanctions, pp. 6–7.)

 

Plaintiff argues that these sanctions are warranted because: (1) these Defendants have not fulfilled their discovery obligations; (2) these Defendants have not paid their prior monetary sanctions; and (3) these Defendants have not complied with the Court’s Minute Order dated April 23, 2024. (Motions for Terminating Sanctions, p. 6.)

 

According to Plaintiff’s Counsel, these Defendants have not provided Plaintiff with court-ordered discovery responses or paid court-ordered monetary sanctions. (Motions for Terminating Sanctions, Decl. Shafron, ¶ 6.)

 

There is no evidence before the Court that indicates these Defendants have served discovery responses, paid their monetary sanctions, or otherwise complied with the Court’s Minute Order dated April 23, 2024. There is also no indication that any sanction would result in these Defendants serving responses to Plaintiff’s outstanding discovery requests. Rather, considering that these Defendants have repeatedly failed to serve timely responses, have repeatedly chosen not to respond to motions, and have not even responded to this motion for terminating sanctions, it appears that these Defendants have ceased participating in this case.

 

            The Court GRANTS in part the motions and ISSUES terminating sanctions. However, monetary sanctions are not required here, and given the boilerplate nature of these motions, it does not seem appropriate to also issue monetary sanctions. The Court DENIES the request for monetary sanctions.

 

III.           Conclusion

 

The Motions for Terminating Sanctions are GRANTED in part.

 

The Answers of Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez are STRICKEN.

 

Plaintiff is ordered to file a Request for Entry of Default as to Defendants Ivan Alberto Rodriguez, Rodjach Investment Properties LLC, and Filipe Rodriguez within 10 days.

 

The Motions for Terminating Sanctions are DENIED as to all else.