Judge: Ronald F. Frank, Case: 23TRCV03964, Date: 2024-11-08 Tentative Ruling



Case Number: 23TRCV03964    Hearing Date: November 8, 2024    Dept: 8

Tentative Ruling¿

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HEARING DATE:                    November 8, 2024

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CASE NUMBER:                   23TRCV03964

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CASE NAME:                        Steven J. Saporito v. William J. Martin, et al.

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MOVING PARTY:                Plaintiff and Cross-Defendant, Steven J. Saporito, individually and Trustee of the Steven J. Saporito Revocable Trust dated April 23, 2003

 

RESPONDING PARTY:       Defendant and Cross-Complainant, William J. Martin

 

TRIAL DATE:                           Not Set. 

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MOTION:¿                                  (1) Motion to Compel William J. Martin’s Responses to Request for Production, Set One.   

                                                (2) Motion Establishing Admissions of Requests for Admission, Set One of William J. Martin’s

(3) Motion Establishing Admissions of Requests for Admission, Set Two of William J. Martin’s

(4) Request for Monetary Sanctions

 

Tentative Rulings:                  (1) Motion to Compel William J. Martin’s Responses to Request for Production, Set One is GRANTED

                                                (2) Motion Establishing Admissions of Requests for Admission, Set One of William J. Martin’s is GRANTED

(3) Motion Establishing Admissions of Requests for Admission, Set Two of William J. Martin’s is GRANTED

(4) Request for Monetary Sanctions is DENIED without prejudice.

 

 

I. BACKGROUND¿¿ 

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A. Factual¿¿ 

On November 29, 2023, Plaintiff, Steven J. Saporito, individually and as Trustee of The Steven J. Saporito Revocable Trust dated April 23, 2003 (“Plaintiff”) filed a complaint against Defendants, William J. Martin, an individual Flagstar Bank, FSB, a business entity form unknown, New York Community Bancorp, Inc., and DOES 1 through 25. The complaint alleges causes of action for: (1) Partition by Sale of Real Property; (2) Accounting; (3) Constructive Trust; and (4) Declaratory Relief.

 

On February 20, 2024, Defendant and Cross-Complainant, William J. Martin, filed a cross-complaint alleging claims for: (1) Breach of Express Contract; (2) Breach of Implied Contract; (3) Intentional Infliction of Emotional Distress; (4) Negligent Infliction of Emotional Distress; and (5) Declaratory Relief.

 

On June 14, 2024, Plaintiff propounded Requests for Production of Documents, Set One, Requests for Admission, Set One, and Request for Admission, Set Two on Defendant Martin. Responses were due by July 17, 2024. Despite Plaintiff’s counsel requesting responses from Defendant Martin’s counsel, Steven Stolar (“Stolar” on August 7, 2024, September 9, 2024, and September 16, 2024, Defendant Martin has failed to respond to discovery. Plaintiff states that although Defendant Martin’s counsel, Stolar, addressed other issues raised in Plaintiff’s counsel’s September 9, 2024 email, Stolar has yet to address any of the requests that discovery responses be provided or otherwise promise discovery responses. Therefore, Plaintiff has brought this motion to compel initial responses to Request for Production, Set One, and Motion to Deem Requests for Admission, Set One and Set Two as Admitted.

 

B. Procedural¿¿ 

            On October 10, 2024, Plaintiff filed his Motion to Compel Responses to Requests for Production of Documents, Set One and Motion to Deem Requests for Admission, Set One and Set Two as Admitted. To date, no opposition briefs have been filed. On November 1, 2024, Plaintiff filed notices of non-opposition.

 

II. ANALYSIS

 

A.    Motions to Compel Initial Responses

 

                          i.          Legal Standard

 

Where there has been no timely response to a Code of Civil Procedure section  2031.010 demand, the demanding party must seek an order compelling a response. (Code Civ. Proc., § 2031.300.) Failure to timely respond waives all objections, including privilege and work product. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. There is no deadline for a motion to compel responses. Likewise, for failure to respond, the moving party need not attempt to resolve the matter outside court before filing the motion. Where the motion seeks only a response to the inspection demand, no showing of "good cause" is required. 

 

                        ii.          Discussion

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Here, because Defendant Martin has failed to comply with discovery by failing to serve timely responses to Plaintiff’s propounded discovery, Plaintiff’s Motion to Compel Initial Responses, without objection to Request for Production of Documents, Set One, is GRANTED.

                      iii.          Sanctions

Code of Civil Procedure section 2023.030, subdivision (a) provides, in pertinent part, that the court may impose a monetary sanction on a party engaging in the misuse of the discovery process to pay the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct. A misuse of the discovery process includes failing to respond or submit to an authorized method of discovery. (Code Civ. Proc., § 2023.010, subd. (d).)¿¿ 

 

Here, because this court has GRANTED Plaintiff’s Motion to Compel Initial Responses to Requests for Production of Documents, Set One, this court notes that it will not be granting discovery sanctions as to this specific motion without prejudice to be brought again if Defendant Martin seeks relief from waiver of objections.

B.    Motion to Deem Requests for Admission as Admitted

 

                          i.          Legal Standard

Under Code of Civil Procedure § 2033.280(c), the court shall make the order deeming the truth of the matters admitted unless the responding party serves before the hearing a proposed response to the requests for admission that is in substantial compliance with Code Civ. Proc § 2033.220. Code of Civil Procedure § 2033.220 requires that each answer either admits, denies or specifies that the responding party lacks sufficient information or knowledge. As stated in Demyer v. Costa Mesa Mobile Home Estates, the moving party is not required to meet and confer before bringing this action. (Demyer v. Costa Mesa Mobile Home Estates, 36 Cal.App.4th 393, 395.)¿¿ Code of Civil Procedure section 2023.030, subdivision (a) provides, in pertinent part, that the court may impose a monetary sanction on a party engaging in the misuse of the discovery process to pay the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct. A misuse of the discovery process includes failing to respond or submit to an authorized method of discovery. (Code Civ. Proc., § 2023.010, subd. (d).)¿¿ 

                        ii.          Discussion

Again, as noted above, due to Defendant Martin’s failure to timely respond to either of Plaintiff’s Requests for Admission, Set One and Set Two, this court GRANTS both of Plaintiff’s Motions for Orders Deeming Requests for Admission as Admitted.

                      iii.          Sanctions       

Under Code of Civil Procedure section 2033.280(c), the court shall make the order deeming the truth of the matters admitted unless the responding party serves before the hearing a proposed response to the requests for admission that is in substantial compliance with Code Civ. Proc § 2033.220. Code of Civil Procedure section 2033.220 requires that each answer either admits, denies or specifies that the responding party lacks sufficient information or knowledge. As stated in Demyer v. Costa Mesa Mobile Home Estates, the moving party is not required to meet and confer before bringing this action. (Demyer v. Costa Mesa Mobile Home Estates, 36 Cal.App.4th 393, 395.)¿¿ 

 

Although sanctions are mandatory when a responding party untimely, but prior to the hearing, files verified, code-complaint responses (Code Civ. Proc., § 2033.280(c)), they are discretionary when responding party fails entirely to respond. Here, because this court’s granting of both of Plaintiff’s motions regarding set one and set two of Requests for Admission, such a ruling is so detrimental to Defendant Martin’s defense of this case, that also awarding sanctions may be too harsh a ruling. Thus, like with the above ruling, this court DENIES sanctions at this time, without prejudice, to be asserted again if Defendant Martin seeks relief from waiver.

III. CONCLUSION

 

            For the foregoing reasons, this court GRANTS Plaintiff’s motions. Plaintiff’s requests for monetary sanctions are DENIED without prejudice, to be asserted again if Defendant Martin seeks relief from waiver.  

 

            Plaintiff is ordered to provide notice.