Judge: Shirley K. Watkins, Case: 20STCV27754, Date: 2023-04-04 Tentative Ruling
If ALL parties submit on the tentative, then no appearance is necessary unless some other matter (i.e., Case Management Conference) is on calendar. It is not necessary to call the court to request oral argument. Oral argument is permitted on all tentative rulings.
Case Number: 20STCV27754 Hearing Date: April 4, 2023 Dept: T
20STCV27754 LAURA OSTROM vs MARIOS TRUCKING, et al.
Monetary sanctions in the sum of $1,800 assessed against defendant Supriano Sanchez Lopez and his counsel of record, Manning & Kass, Ellrod, Ramirez, Trester, LLP, jointly and severally, representing $600 for each of the 3 motions. Basis of the sanctions is discovery abuse, persisting in frivolous objections, failure to submit proper responses requiring a court order, all without substantial justification. Payment to be made to the Client Trust Account of Sommer and Bear, 15840 Ventura Blvd., Suite 201, Encino, CA 91436 by 4/28/2023.
Monetary sanctions in the sum of $1,800 assessed against defendant MARIO FLORES RAMOS dba MARIOS TRUCKING [erroneously sued as "MARIOS TRUCKING aka MARCOS TRUCKING" and MARIO H. FLORES RAMOS dba MARIOS TRUCKING"]and his counsel of record, Manning & Kass, Ellrod, Ramirez, Trester, LLP, jointly and severally, representing $600 for each of the 3 motions. Basis of the sanctions is discovery abuse, persisting in frivolous objections, failure to submit proper responses requiring a court order, all without substantial justification. Payment to be made to the Client Trust Account of Sommer and Bear, 15840 Ventura Blvd., Suite 201, Encino, CA 91436 by 4/28/2023.
AS TO PLAINTIFF'S WRITTEN DISCOVERY TO DEFENDANT SUPRIANO SANCHEZ LOPEZ
Request For Admission :
10 and 11: There is no pending motion on RFA's.
Form Interrogatories:
General Objections Deny
15.1 Grant. Verified answer without objections within 10 days. If you do not have facts, or do not know of any witnesses or documents supporting the affirmative defense at this time, you should so state.
17.1 Grant. Verified answer without objections within 10 days. Each RFA in which there was not an unqualified ADMIT shall be separately stated. All subparts must be answered for each RFA.
20.1, 20.2, 20.3, 20.4: There is no pending motion on these interrogatories.
Special Interrogatories:
General Objections Deny.
6 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
7 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
8 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
10 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
11 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
12 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
13 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
14 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
15 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
16 Grant. This question asks for his percipient knowledge. The question does not ask for attorney work product or expert opinion. Verified answer without objections within 10 days.
Demand For Production:
General Objections: Denied.
16 Grant. Code Compliant verified response due within 10 days. If there are any responsive documents which are not being produced, a privilege log is required.
AS TO PLAINTIFF'S WRITTEN DISCOVERY TO DEFENDANT MARIOS TRUCKING
Request For Admissions:
12 There is no pending RFA motion.
Form Interrogatories:
General Objections: Denied.
2.11 Grant, objections are stricken, verified answer within 10 days without objection. Must answer separately to each subpart.
15.1 Grant, must separately provide verified response as to each affirmative defense (a), (b) and (c) within 10 days without objection.
Demand For Production:
General Objections: Denied.
19 Denied. The request is overbroad and vague.
IT IS SO ORDERED, CLERK TO GIVE NOTICE.