TENTATIVE RULING

Calendar: 7

Date: 04/11/2025

Case No:  EC 068370 Trial Date: September 8, 2025 

Case Name: Grigorian v. Megeredchian, et al.  

MOTIONS TO COMPEL FURTHER RESPONSES TO DISCOVERY (3 Motions)

Moving Party: Defendant Megeredchian Law  

Responding Party: Plaintiff Vehanoosh Grigorian  

RELIEF REQUESTED:

Further Responses to Form Interrogatories, Set One 

Further Responses to  Special Interrogatories, Set One 

Further Responses to Requests for Production of Documents, Set One 

FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff Vehanoosh Grigorian brings this legal malpractice action against her former attorneys, defendants Alex Megeredchian and his law practice entities, alleging that during their  representation of plaintiff and other partners in a real estate investment joint venture transaction, defendants failed to appropriately advise the parties, and continued representation despite conflicts of interests arising between the partners, ultimately resulting in plaintiff funding the entire real estate purchase, with no written contract to protect plaintiff from the circumstance that two of the other partners’ names remained as purchasers in whom title would vest at closing, and could fail to pay their share of the funding after closing.  The partners failed to pay, and the complaint also alleges that although the partners agreed to execute and executed a notarized  Reconveyance Grant Deed to plaintiff to facilitate a potential sale of the property, defendant falsely claimed that the deed had been forged, and sent a false letter making such allegations to escrow, and other involved parties, clouding title and derailing plaintiff’s efforts to sell the property and mitigate her damages.   

Plaintiff also alleges that in breach of their duties and ethical obligations to plaintiff, their client, and plaintiff’s spouse, also their client, defendants have filed a civil suit against plaintiff and her spouse on behalf of the other two partners, seeking to quiet title to the property in favor of the other partners according to their purported 50% interest.  Plaintiff also alleges that in the course of that lawsuit, defendants are improperly using confidential information derived from plaintiff in the course of defendants’ representation of plaintiff. 

The file shows that on December 5, 2018, the parties filed, and the Court signed a Stipulation and Order Staying Action, staying this matter for all purposes pending resolution of the other action between the partners, which was pending in Van Nuys. 

The docket in the Van Nuys case shows that the parties participated in a non-jury trial in October and November of 2021, and filed written closing argument briefs in February of 2022.  Following supplemental briefing and oral argument as ordered by the court, and the issuance of a Tentative Statement of Decision in September of 2022, followed by the filing of objections, responses and requests for clarification, on November 17, 2022, the Van Nuys court filed its Statement of Decision and Findings of Fact in the matter.  

In the Van Nuys action, plaintiff in this action, Vehanoosh Grigorian, had been sued as a defendant by plaintiffs in that action, Robert Ter-Oganesyan and Meghedy Bandary, along with Zaven Grigorian as defendant.   Defendants in that action, the Grigorians, filed a cross-complaint to quiet title to the Skytop property as against plaintiffs in that action as cross-defendants. 

Notice of entry of judgment was filed by the clerk on December 5, 2022, and was served by mail the same date. 

Judgment was entered in favor of defendants in the Van Nuys action, the Grigorians, on the Second Amended Complaint, with plaintiffs in that action, Ter-Oganesyan and Bandary to take nothing by their complaint.  Defendants were deemed the prevailing parties, with costs to defendants pursuant to memorandum of costs and attorney fees to defendants, if allowed by statute or contract, by noticed motion.

Judgment was entered in favor of cross-complainants in the Van Nuys action, the Grigorians, on the First Amended Cross-Complaint, the Van Nuys court declaring that cross-complainants were the 100% owners of the Skytop property, quieting title in favor of cross-complainants, and declaring that cross-defendants in that action, Ter-Oganesyan and Bandary, have no rights, legal or equitable interest in, or title to the Skytop property.  The Van Nuys court granted rescission and restitution on cross-complainant’s breach of contract claim. The Van Nuys court awarded monetary damages in favor of cross-complainants in that case, the Grigorians, against cross-defendants Ter-Oganesyan and Bandary, jointly and severally, in the sum of economic damages in the amount of $751,489.29 plus $129,026.22 prejudgment interest (tort claims) plus $195,200.10 (breach of contract claims), for a total of $1,075,715.61.    

Cross-complainants were deemed the prevailing parties, with costs to cross-complainants pursuant to memorandum of costs and attorney fees to cross-complainants, if allowed by statute or contract, by noticed motion.

The file shows that the Van Nuys action was proceeding through briefing on a post-trial motion for attorneys’ fees, which was set to be argued on January 18, 2023.  On January 17, 2023, plaintiffs in that action filed a Notice of Stay of Proceedings, indicating that the matter was stayed pursuant to an automatic stay caused by the filing in another court of a bankruptcy petition filed in the United States Bankruptcy Court by Robert Ter-Oganesyan and Meghedy Bandary.   

On January 18, 2023, the motion for attorney fees was called for hearing in the Van Nuys action, and the minute order indicates that the case had been stayed by filing of bankruptcy proceedings by plaintiffs. The hearing on the motion for attorney fees was continued to July 17, 2023, and the action was also set for a Status Conference Re: Status of Bankruptcy the same date.  The July 17, 2023, the matters were taken off calendar by the Van Nuys court.

The Van Nuys action file also shows that on May 22, 2023, defendants and cross-complainants the Grigorians filed an “Acknowledgment of Satisfaction of Monetary Judgment,” which indicates that the Grigorians acknowledge “full satisfaction of the monetary obligations in the December 5, 2022 Judgment” in that action as follows:

“the Judgment Creditors have accepted payment other than that specified in the Judgment in full satisfaction of the monetary obligations in the Judgment owed to them by Plaintiffs and Cross-Defendants Robert TerOganesyan and Meghedy Bandary (“Judgment Debtors”). For the sake of clarity, this Acknowledgement of Satisfaction of Judgment only applies to monetary aspects of the Judgment and does not serve to extinguish aspects of the Judgment relating to the Judgment Creditors’ sole ownership of the ‘Skytop Property’ including but not limited to Paragraph A on page 2 of the Judgment; those portions of the Judgment shall remain active and in full force and effect.”

[Acknowledgment, LASC Case No. LC106885, filed 05/22/2023, p. 2]. 

The Acknowledgment also indicates:

“Judgment Creditors have not recorded any abstracts of judgment in any county or filed any judgment liens in the Office of the California Secretary of State. There have been no renewals of the Judgment.

[Id].   

The judgment debtors in the Van Nuys case, and bankruptcy petitioners, Ter-Oganesyan and Bandary, are not parties to this Glendale action, but third parties.  This Glendale action does not appear to be subject to any automatic bankruptcy stay.  

Accordingly, on October 27, 2023, the court in this matter ordered, “Unopposed request to lift the Stay today is granted.”  

ANALYSIS:

Under CCP § 2017.010, “any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action...if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.”  The section specifically provides that “Discovery may relate to the claim or defense of the party seeking discovery or of any other party to the action,” and that discovery may be obtained “of the identity and location of persons having knowledge of any discoverable matter, as well as of the existence, description, nature, custody, condition and location of any document, electronically stored information, tangible thing, or land or other property.”

Interrogatories

CCP § 2030.300(a) provides that if the party propounding interrogatories deems that an objection “is without merit or too general” or that “an answer to a particular interrogatory is evasive or incomplete…the propounding party may move for an order compelling a further response...”

If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure to fully respond to discovery.  Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221.  The granting or denial of a motion to compel is in the discretion of the trial court.  Coy, at 221-222.   A court should generally consider the following factors:

The relationship of the information sought to the issues framed in the pleadings;

The likelihood that disclosure will be of practical benefit to the party seeking discovery;

The burden or expense likely to be encountered by the responding party in furnishing the information sought.

Columbia Broadcast System, Inc. v. Superior Court (1968) 263 Cal.App.2d 12, 19.

Form Interrogatories

Form Interrogatory No. 17.1 requests that for each request for admission which is not an unqualified admission, the responding party state the number of the request, the facts upon which the response is based, and the persons who have knowledge of those facts, and identify all documents and tangible things supporting the response, along with information concerning any person who has the document or thing. 

Requests for Admissions  Nos. 9, 12, 23, and 24

As to the other three RFAs, the responses all consist of a narrative of plaintiff’s allegations in this matter, along with statements that, “Discovery and investigation are continuing.  Responding party reserves the right to supplement this response without assuming any obligation to do so.”   The responses then identify the same ten witnesses, and with respect to documents, state, “See documents previously produced by Responding Party, Bates Nos. 000001-001303, in accordance with Code of Civil Procedure section 2031.280 (d)(1).” 

Defendant argues that despite the length of each of these responses, they fail to address the actual requests for admissions, mentioning no privileged information, or any facts concerning the vesting of the Grant Deed or advice given by the Law Office in that regard.  

Under CCP § 2030.220:

“(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”

The responses are not complete and straightforward, and fail to provide the information requested.  The facts are nonresponsive to the RFAs, which is improper, and such responses also make it difficult to understand which of the identified witnesses have knowledge concerning the subject matter of the RFA.  Moreover, with respect to the reference to documents already produced, this is also an improper response, as it has long been recognized that reference to other discovery is not a proper response to an interrogatory.  See Coy v. Superior Court (1962) 58 Cal.2d 210, 217-219; see also Deyo v. Kilbourne (1978, 2nd Dist..) 84 Cal.App.3d 771, 783-784 (“it is not proper to answer [an interrogatory] by stating ‘See my deposition,’ ‘See my pleading,’ or ‘See the financial statement.’”).   As argued by defendant, this approach is merely pointing to every document which has been produced by plaintiff in the lawsuit, without specifying which documents are responsive to the subpart of this interrogatory.    

Plaintiff in opposition argues that these responses comply with the Code and objections are clearly specified.  This showing fails to meet plaintiff’s burden on this motion to justify any failure to fully respond, comply with the Code, or the validity of any objections.  There is no argument pointing to where the information called for in connection with the RFAs is provided in the responses, and no attempt to justify any objections.  

The motion accordingly is granted. Further responses are ordered to be served which provide all information called for directed to each RFA which was not admitted.  The specific witnesses and documents responsive to the interrogatory will be identified.  The further responses will be without objections, as objections have not been justified, and have been otherwise waived.  The further responses will also not include any language suggesting that discovery is continuing or reserving the right to supplement discovery responses, as such responses are not acceptable.  Particularly given the obligation of responding party to make a reasonable and good faith effort to obtain information by inquiry to others under CCP § 2030.220(c), set forth above, defendant is entitled to the information requested now. 

Requests for Admissions Nos.  26, 28, 29, 30, 34, 36, and 37

These requests ask plaintiff to admit that the Law Office never acted as attorney for Skytop LLC, that Skytop LLC never entered into an oral agreement with the Law Office for legal services, that the Law Office never agreed to represent Skytop LLC, was never authorized to act as Skytop LLC’s attorney, and that the Law Office did not improperly use privileged information of Skytop LLC, or advise it as to the vesting of the Grant Deed, and that Skytop LLC suffered no damages as a result of any action of inaction of the Law Offices. 

The responses are the same as discussed above, and improperly do not address each of the admissions.  

Defendant then evidently served a supplemental response stating:

“Skytop LLC is not a party to this action.  The complaint does not allege that Alex represented Skytop LLC or that Skytop LLC was Alex’s client.  Vehan testified in her deposition that Skytop LLC is a shell entity that was created for possible future investments that never transpired, and that the LLC is no longer active.”

Defendant argues in connection with this motion that plaintiff’s refusals to admit these requests are not in good faith, and it is apparent from the meet and confer between the parties that these requests should have been admitted.   

This pleading is not a motion to compel further responses to the RFAs, but a motion to compel further responses to Form Interrogatory No. 17.1.   In the absence of a motion to compel further responses to the RFAs, the court cannot compel further direct responses to those RFAs, and will not do so. 

However, the responses, including the supplemental responses that Skytop is not a party to this action are not proper or complete, and to the extent the supplemental responses are intended to be some sort of objections, they are not clearly stated as such.   Moreover, such objections were not stated in the original responses to the interrogatory, and so are untimely and have been waived. 

The opposition argues that the requests exceed the scope of the action and are irrelevant, but plaintiff provided responses nonetheless and there is no basis for further responses.  Plaintiff essentially concedes that the responses provided do not address the RFAs at issue, and if plaintiff is taking the position that there are no allegations concerning Skytop LLC being pursued in this lawsuit, plaintiff should include this information in its responses to the interrogatory and subparts for each of the subject RFAs.  

Defendant argues in the reply that it is of no consequence that Skytop LLC is not a party to this action, as it was a party involved in the underlying transaction and defendant is entitled to discover information relative to it.  This response appears to defeat any objection that the information exceeds the scope of permissible discovery here, when the scope of discovery is quite broad, as set forth above.  The motion is granted and further verified responses, without objections, are ordered to be served. 

Special Interrogatories

Special Interrogatories Nos. 1 and 2 

“1. Identify every telephone conversation YOU were involved in with DEFENDANTS between January 1, 2014 and April 5, 2018 by Date, Time, Persons who were on the call, and the subject matter of the call.”

“2. Identify every in-person meeting YOU were involved in with DEFENDANTS between January 1, 2014 and April 5, 2018 by Date, Time, Persons who were present, and the subject matter of each meeting.”

The responses include objections that the interrogatories are vague and ambiguous, conjunctive and disjunctive in the use of the term defendants, seeks attorney client and work product or other privileged information, that the information is public record or equally available to the requesting party.   Subject to those objections, the responses are that:

“1. Responding Party had several telephone conversations with Alex Megeredchian during escrow for the purchase of the Skytop property, but does not recall the exact dates of those calls.”

2. Responding Party met with Alex Megeredchian at Mr. Megeredchian’s office on two separate occasions during escrow for the purchase of the Skytop property. Responding Party does not recall the exact dates of those meetings.”

Defendant argues that whether or not there was an attorney-client relationship is a core contested issue in this action, and plaintiff has alleged that telephone calls with defendants support her contention that there was an attorney-client relationship.  Defendant argues that plaintiff is required to make a diligent inquiry to sources within her control, such as her own telephone records, to confirm if and when she had a telephone conversation with plaintiff and that seeking to identify the call by reasonable key elements of the call, such as who participated in the call and what was discussed, is reasonable.

“(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”

This situation appears to be a situation where the function of making reasonable and good faith inquiry included in the responsibility in responding to interrogatories is of particular importance, as the details of the dates and times and attendees might not be readily within the party’s recollection at a deposition.  The interrogatories do not appear to be objectionable on the grounds asserted, and because these events occurred so long ago, it would make sense to expect the responding party to consult other sources of information, such as calendars or phone records, to provide more exact answers.  The motion is granted. The plaintiff is required to provide responses with statements showing compliance with CCP § 2030.220 (c), and explaining what steps plaintiff took to obtain responsive information.  While the responses include an objection based on this subdivision that the information is “equally available” to the propounding party, such an objection usually applies when a propounding party seeks to force another party to search public records equally available to both, which is not the case here.  Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App.2d 45, 53. There is no recognized objection that the information is already known to the other party.  Coy v. Superior Court (1962) 58 Cal.2d 210, 218 (“’no rule or authority is cited which authorizes refusal to answer an interrogatory simply on the ground that the answer is known to the party seeking the information,’” quotation citation omitted). 

The opposition argues that the interrogatories ask for information regarding events dating from seven to eleven years ago and it is not unreasonable to answer that the responding party does not recall, and responding party is only required to provide the information available at the time of answering the interrogatories.  The argument also seems to refer to supplemental responses which inform defendant of deposition answers.  Again, depositions do not include the inquiry requirement imposed with respect to interrogatories, and this circumstance underscores the need to make such an independent inquiry within the time to respond to interrogatories, rather than on the spot at a deposition.   Further responses are ordered to be served. 

Special Interrogatories Nos. 4, 13 and 15

These interrogatories ask plaintiff to identify all facts that support her contention that defendants “engaged others, on behalf of the Joint Venture Buyers,” that defendants facilitated the vesting of title to the Skytop Property, and to identify all documents that plaintiff contends contained privileged information that defendants used improperly.   

The responses are the same objections, an objection that the requests are not complete in and of themselves, and responses that “unknown at this time,” the general narrative provided to the form interrogatory, above, and that “Responding Party provided defendants with confidential information concerning Responding Party’s business and financial dealings.”   No documents are identified. 

These are clearly contention interrogatories based on the contentions that plaintiff is making in this action.  The opposition argues briefly that there is no reference to where these contentions are being made, so the interrogatories are not full and complete in themselves, but the questions are clear, reference contentions, and if plaintiff is claiming she is not making such contentions, her response may so state.  

“An interrogatory may relate to whether another party is making a certain contention, or to the facts, witnesses, and writings on which a contention is based.   An interrogatory is not objectionable because an answer to it involves an opinion or a contention that relates to fact or the application of law to facts, or would be based on information obtained or legal theories developed in anticipation of litigation.” 

It is apparent that plaintiff is making these contentions, and the opposition is able to go through the narrative response and identify the specific facts which would respond, for example, to Interrogatory No. 13.  This method should be done with all of the responses. 

Document Requests

CCP § 2031.310 provides that a party demanding a document inspection may move for an order compelling further responses to the demand if the demanding party deems that:

“(1)   A statement of compliance with the demand is incomplete.

  (2)   A representation of inability to comply is inadequate, incomplete, or evasive.

  (3)   An objection in the response is without merit or too general.”  

Under CCP § 2031.310 (b)(1), “The motion shall set forth specific facts showing good cause justifying the discovery sought by the demand.”  

The burden is on the moving party to show both relevance to the subject matter and specific facts justifying discovery.   Glenfed Develop. Corp. v. Superior Court (1997, 2nd Dist.) 53 Cal.App.4th 1113, 1117.   Once good cause is established by the moving party, the burden then shifts to the responding party to justify any objections made to document disclosure.   See Hartbrodt v. Burke (1996, 2nd Dist.) 42 Cal.App.4th 168, 172-174.

Defendant’s notice of motion seeks further responses to Requests Nos. 5, 6, 7, 9, 10, 11, 12 and 13. 

Defendant’s separate statement addresses Requests Nos. 5, 6, 7, 9, 10, 11, 12 and 13, but by incorrect numbers.  The opposition indicates that plaintiff addresses only those Requests in the separate statement.   However, they appear to be the same requests.  The reply also addresses Requests Nos. 5, 6, 7, 9, 10, 11, 12 and 13.  The court considers the motion as to the Requests in the separate statement, which appear to be all requests at issue in the notice and reply as well.  

However, defendant’s separate statement is confusing because it refers to Requests by the wrong numbers.  This presentation is not appropriate.   CRC Rule 3.1345(c) provides that a separate statement is a “separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue.  This separate statement  “must include” for each discovery request to which a further response is requested, “(1) The text of the request, interrogatory, question or inspection demand” in addition to “(2) The text of each response, answer or objection, and any further responses or answers, ...”  and “(3)  A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute.”   The subdivision further states that “The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response.”   Here, the statement in fact required persons to review other documents to determine the request and response because the numbers are off, to great inconvenience.   

The court would be within its discretion to disregard the separate statement, but because the opposition and reply have provided the appropriate Request Nos., the court does consider the separate statement in support of the motion.  

Requests Nos. 5, 6, 7, 9 and 10

These requests seek documents supporting plaintiff’s contention that plaintiff suffered damages caused by defendants, plaintiff’s contention that she hired defendants as her attorney, plaintiff’s contention that Skytop JV hired defendants as its attorney, plaintiff’s contention that defendants agreed to represent plaintiff as plaintiff’s attorney, and plaintiff’s contention that defendants agreed to represent Skytop JV as its attorney.  

These requests appear to seek discoverable information, concerning plaintiff’s contentions in this matter, and the memorandum explains that in this legal malpractice action, all elements of legal malpractice are in dispute, starting with whether plaintiff was ever actually represented by any defendant, and that these issues are complicated by the fact that there is uncertainty about the distinction between plaintiff, Skytop JV, and Skytop LLC with respect to which party, if any, was being represented.    The requests appear to go to the heart of the issues raised in this matter by this transaction among various parties, and any resulting breach of professional duties.  Good cause is established for compelling responses to the requests. 

The most recent responses to these requests, the further supplemental responses, assert the same boilerplate objections asserted in connection with the interrogatories above, and then state some variation of:

“Subject to and without waiving any of the foregoing objections, Responding Party responds as follows: 

 See documents previously produced by Responding Party, Bates Nos. 16 – 50.”

In any case, the motion correctly argues that the responses are incomplete.  Under CCP section 2031.210, a response shall either be a statement of compliance, a representation that the party lacks the ability to comply, or an objection. 

With respect to a statement of compliance, CCP section 2031.220 requires:

“A statement that a party to whom an inspection demand has been directed will comply with the particular demand shall state that the production, inspection, and related activity demanded will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being make will be included in the production.”

Requests Nos. 11, 12, and 13

Again, these requests seek discoverable information directly relevant to the claims being made by plaintiff against moving defendant, and good cause appears for compelling that plaintiff respond. 

The further supplemental responses to each include the same boilerplate objections as above, and then state:

“Subject to and without waiving any of the foregoing objections, Responding Party responds as follows:

After diligent search and reasonable inquiry Responding Party has no documents in her possession, custody and control responsive to this request.”

“A representation of inability to comply with the particular demand for inspection shall affirm that a diligent search and a reasonable inquiry has been made in an effort to comply with that demand.   This statement shall also specify whether the inability to comply is because the particular item or category has never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been , or is no longer, in the possession, custody, or control of the responding party.   The statement shall set forth the name and address of any natural person or organization known or believed by that party to have possession, custody, or control of that item or category of item.”

(Emphasis added). 

The motion accordingly is granted, and further Code-compliant responses are ordered to be served.  Again, the opposition fails to justify the objections, just arguing that “Objections are clearly specified.”  This statement is insufficient to justify any particular objection. 

 

Sanctions 

Moving party seeks monetary sanctions for having had to incur the expense of bringing these motions.  

CCP § 2030.300 (d) provides that the court “shall impose a monetary sanction...against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.”   A similar provision applies to motions to compel further responses to document demands.  CCP § 2031.310 (h).   

  Under CCP § 2023.010, misuse of the discovery process includes “(e) making, without substantial justification, an unmeritorious objection to discovery”; and “(f) making an evasive response to discovery.”  Where there has been a misuse of the discovery process, under Section 2023.030(a), the court “may impose a monetary sanction ordering that one engaging in the misuse of the discovery process, or any attorney advising that conduct, or both pay the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct.”

The burden is on the party subject to sanctions to show substantial justification or injustice.  Mattco Forge, Inc. v. Arthur Young & Co. (1990, 2nd Dist.) 223 Cal.App.3d 1429, 1436. 

Special Interrogatories: 5 hours at $550.00 per hour equals: $2,750.00

Document Requests: 6 hours at $550.00 per hour equals: $3,300.00

RULING:

Defendant’s Motion to Compel Further Responses to Form Interrogatories, Set One, is GRANTED.

Plaintiff Vehanoosh Grigorian is ordered to serve further verified responses to Form Interrogatories, Set No. One, Interrogatory No. 17.1 as it relates to Requests for Admissions Nos. 9, 12, 23, 24, 26, 28, 29, 30, 34, 36, and 37, without objections.  The further responses must provide all information requested and respond to all subparts.  All further responses are to respond directly to each Request for Admission topic and fully comply with the requirements under the Discovery Act, including, under CCP § 2030.210 (a)(1) answers “containing the information sought to be discovered.”  The responding party must also comply fully with CCP § 2030.220:

“(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”

The Court has reviewed the objections asserted, and finds that responding party has failed to justify them, and that the objections are without merit, and objections are OVERRULED.  The Court does not find acceptable a response to discovery which states that discovery is continuing or reserves the right to supplement a response at a later date, given the duty imposed by CCP section 2030.220(c) to make reasonable inquiry before responding to an interrogatory.  

Monetary sanctions requested by moving party: Utilizing a lodestar approach, and in view of the

totality of the circumstances, the Court finds that the total and reasonable amount of attorney’s

fees and costs incurred for the work performed in connection with the pending motion is $1,650.00

(3 hours @ $550/hour) [5 hours requested] along with filing fees in the sum of $60.00 [Amount Requested $2,810], which sum is to be awarded in favor of defendant Megeredchian Law, and against plaintiff Vehanoosh Grigorian, and plaintiff’s counsel of record, jointly and severally, payable within 30 days. CCP §§ 2030.300(c), 2023.010 (e) and (f), and 2023.030(a).

Defendant’s Motion to Compel Further Responses to Special Interrogatories, Set One, is GRANTED.

Plaintiff Vehanoosh Grigorian is ordered to serve further verified responses to Special Interrogatories, Set One, Special Interrogatories Nos. Interrogatories Nos. 1, 2, 4, 13 and 15, without objections. 

The further responses must provide all information requested, and fully comply with the requirements under the Discovery Act, including, under CCP § 2030.210 (a)(1) answers “containing the information sought to be discovered.”  The responding party must also comply fully with CCP § 2030.220:

“(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”

With respect to Special Interrogatories Nos. 1 and 2, the Court will expect responses which not only state that a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations has been made, but also explain what reasonable and good faith efforts were made. 

The Court has reviewed the objections asserted, and finds that responding party has failed to justify them, and that the objections are without merit, and objections are OVERRULED.  The Court does not find acceptable a response to discovery which states that discovery is continuing or reserves the right to supplement a response at a later date, given the duty imposed by CCP section 2030.220(c) to make reasonable inquiry before responding to an interrogatory.  

Monetary sanctions requested by moving party: Utilizing a lodestar approach, and in view of the

totality of the circumstances, the Court finds that the total and reasonable amount of attorney’s

fees and costs incurred for the work performed in connection with the pending motion is $2,750.00

(5 hours @ $550/hour) [8 hours requested] along with filing fees in the sum of $60.00 [Amount Requested $4,460.00], which sum is to be awarded in favor of defendant Megeredchian Law, and against plaintiff Vehanoosh Grigorian, and plaintiff’s counsel of record, jointly and severally, payable within 30 days. CCP §§ 2030.300(c), 2023.010 (e) and (f), and 2023.030(a).

Defendant’s Motion to Compel Further Responses to Requests for Production of Documents, Set One is GRANTED. The Court notes that it has considered the motion despite the fact that the separate statement submitted required this Court to consult other documents to understand the separate statement and dispute.  See CRC Rule 3.1345(c).     

Plaintiff Vehanoosh Grigorian is ordered to serve further responses to Requests for Production of Documents, Set One, without objections, to Requests Nos. 5, 6, 7, 9 and 10, and to permit inspection and copying of all responsive documents within ten days.  The further responses must fully comply with CCP § 2031.220, providing a Code-compliant statement of compliance, including for each request a statement that responding party will comply with the particular demand, including a statement that the production, inspection, and related activity demanded will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of plaintiff will be included in the production.

Plaintiff Vehanoosh Grigorian is ordered to serve further responses to Requests for Production of Documents, Set One, without objection, to Requests Nos. 11, 12 and 13.  The further responses must fully comply with CCP § 2031.230, providing a Code-compliant statement of inability to comply, which statement shall specify whether any inability to comply is because the particular item or category has never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in the possession, custody, or control of the responding party, and which sets forth the name and address of any natural person or organization known or believed by that party to have possession, custody, or control of that item or category of item.  Further responses are to be without objection, as plaintiff has failed to justify objections, and the Court finds the objections asserted to be without merit.   

Monetary sanctions requested by moving party: Utilizing a lodestar approach, and in view of the

totality of the circumstances, the Court finds that the total and reasonable amount of attorney’s

fees and costs incurred for the work performed in connection with the pending motion is $3,300.00

(6  hours @ $550/hour) [10 hours requested] along with filing fees in the sum of $60.00 [Amount Requested $5,560.00], which sum is to be awarded in favor of defendant Megeredchian Law, and against plaintiff Vehanoosh Grigorian, and plaintiff’s counsel of record, jointly and severally, payable within 30 days. CCP §§ 2031.310(h), 2023.010 (e) and (f), and 2023.030(a).

DEPARTMENT D IS CONTINUING TO CONDUCT AND ENCOURAGE 

VIDEO APPEARANCES

Please make arrangement in advance if you wish to appear via LACourtConnect by visiting www.lacourt.org to schedule a remote appearance.  Please note that LACourtConnect offers free audio and video appearances.  Department D is now requiring either live or VIDEO appearances, not audio appearances.  Please note that in the case of video appearances, ADVANCE REGISTRATION IS REQUIRED.