Judge: Serena R. Murillo, Case: 20STCV29601, Date: 2022-12-08 Tentative Ruling

Case Number: 20STCV29601    Hearing Date: December 8, 2022    Dept: 29

TENTATIVE

Defendant’s motion to compel Plaintiff’s deposition and to produce documents is GRANTED.  The Court declines to impose monetary sanctions. 


Legal Standard

 

Compel Deposition and Produce Documents

 

Any party may obtain discovery, subject to restrictions, by taking the oral deposition of any person, including any party to the action.  (Code Civ. Proc., § 2025.010.)  A properly served deposition notice is effective to require a party or party-affiliated deponent to attend and to testify, as well as to produce documents for inspection and copying.  (Code Civ. Proc., § 2025.280(a).)

 

The party served with a deposition notice waives any error or irregularity unless that party promptly serves a written objection at least three calendar days prior to the date for which the deposition is scheduled.  (Code Civ. Proc., § 2025.410(a).)

 

“If, after service of a deposition notice, a party . . . without having served a valid objection . . . fails to appear for examination, or to proceed with it, or to produce for inspection any document . . . described in the deposition notice, the party giving notice may move for an order compelling deponent’s attendance and testimony, and the production . . . of any document . . . described in the deposition notice.”  (Code Civ. Proc., § 2025.450(a).)  The motion must be supported by a meet and confer declaration with facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.  (Code Civ. Proc., § 2016.040.)

 

Monetary Sanctions

 

Under Code of Civil Procedure section 2023.010(d), misuse of the discovery process includes “[f]ailing to respond or to submit to an authorized method of discovery.”  The court may order sanctions to cover “the reasonable expenses, including attorney’s fees, incurred by anyone as a result of” the misuse of the discovery by the party being sanctioned.  (Code Civ. Proc. § 2023.030(a).)

 

But “sections 2023.010 and 2023.030 do not independently authorize the trial court to impose monetary sanctions for misuse of discovery.  (City of Los Angeles v. PricewaterhouseCoopers, LLC (2022) 84 Cal.App.5th 466, ___ [300 Cal.Rptr.3d 432], this newly-newly published case does not yet have page numbers in the official reporter.)  The award of monetary sanction must be based on another provision of the Discovery Act, Code of Civil Procedure section 2016.010 et seq.

 

Discussion

 

Compel Deposition and Produce Documents

 

As a preliminary matter, Defendant sent Plaintiff’s counsel a meet and confer letter, which was left unanswered.  (Motion p. 3; Randall Decl. 2; Exh. C.)  This satisfies the meet and confer requirement

 

Since June 2021, Defendant repeatedly tried to obtain the deposition of the Plaintiff and to discuss this issue with Plaintiff and Carpenter.  (Motion, Exh. C.)  According to Defendant, Carpenter advised Defendant that Plaintiff would be available in late September or early October for the deposition.  (Motion p. 3.)

 

On November 5, 2021, Defendant noticed the deposition of the Plaintiff for November 24, 2021, with a Request for Production of Documents.  (Motion, Exh. A.)  According to Defendant, Carpenter objected and provided December 23, 2021, and January 6 and 12, 2022, as alternate dates, though the January dates were beyond the discovery cut-off.  (Motion p. 3.)  Defendant’s counsel requested alternate dates and a stipulation to continue the trial.  Defendant’s counsel further indicated that if the alternate dates and the stipulation to continue the trial were not provided, the November 24, 2021, date for the Plaintiff’s deposition would stay on calendar.  Carpenter failed to acknowledge this communication and failed to provide any further alternate dates.  (Motion, Exh. C.)

 

Defendant’s counsel and a court reporter were prepared to continue with the deposition on November 24, 2021, but Plaintiff failed to appear.  (Motion p. 3; Motion, Exh. B.)  Defendant did not take a statement of non-appearance.  (Motion, Exh. B.)  Carpenter later proposed a deposition date of December 23, 2021, then again suggested the dates of January 6 and 12, 2022.  (Motion p. 3.)

 

Defendant’s motion is appropriate in light of Plaintiff’s repeated failure to schedule and appear at her deposition and produce documents.  Defendant contacted Plaintiff’s counsel and scheduled the deposition around Plaintiff’s stated unavailability.  (Motion, Exh. C.)  Plaintiff failed to appear at the noticed date, and Plaintiff’s counsel failed to propose alternate dates before discovery cut-off.  (Motion, Exh. B; Motion p. 3.)  Therefore, the motion to compel Plaintiff’s deposition and to produce documents is granted.

 

Monetary Sanctions

 

Defendant only cites to Code of Civil Procedure section 2023.030 in support of its request for monetary sanctions.  As discussed above, section 2023.030 does not independently authorize the Court to impose monetary sanctions.  Therefore, the Court declines to impose monetary sanctions. 

 

Conclusion

 

Accordingly, Defendant’s motion to compel Plaintiff’s deposition and to produce documents is GRANTED.

 

The Court declines to impose monetary sanctions. 

 

Moving party is ordered to give notice.