Judge: Stephen Morgan, Case: 20AVCV00471, Date: 2023-11-14 Tentative Ruling

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Case Number: 20AVCV00471    Hearing Date: November 14, 2023    Dept: A14

Background

 

This is a motor vehicle – personal injury action. Plaintiff Erica Joan Walling (“Plaintiff”) alleges that on or around November 06, 2019 on or around 40th Street West near Avenue J-8 in Lancaster, County of Los Angeles, California, Defendant Sherryl Lynn Hammond (“Hammond”) was operating a motor vehicle while employed by Defendant Antelope Valley Schools Transportation Agency (“AVSTA” and collectively “Defendants”) and operated the motor vehicle negligently so as to be the legal cause of injuries and damages to Plaintiff.

 

On July 14, 2020, Plaintiff filed her Complaint alleging one cause of action for Motor Vehicle.

 

On December 29, 2021, AVSTA filed its Answer.

 

On March 11, 2022, Hammond filed her Answer.

 

On October 18, 2023, Defendants filed this Motion to Compel the Deposition of Plaintiff (“Motion to Compel”).

 

On November 06, 2023, Defendants filed a Notice of Non-Receipt of Opposition.

 

On November 07, 2023, Plaintiff filed a document titled “Declaration of E. Forstrom in Opposition to Defendant's MTC Deposition.” “All papers opposing a motion so noticed shall be filed with the court and a copy served on each party at least nine court days. . .before the hearing.” (Cal. Code Civ. Proc. § 1005(b).) “Section 1013, which extends the time within which a right may be exercised or an act may be done, does not apply to a notice of motion, papers opposing a motion, or reply papers governed by this section.” (Ibid.) The hearing is scheduled for November 14, 2023. November 10, 2023 is a national holiday. Accordingly, an Opposition was due by October 31, 2023. “No paper may be rejected for filing on the ground that it was untimely submitted for filing. If the court, in its discretion, refuses to consider a late filed paper, the minutes or order must so indicate.” (Cal. Rules of Court, Rule 3.1300(d).) The Court, in its discretion, does not consider the late-filed Opposition.

 

 

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Legal Standard

 

Standard for Motion to Compel Deposition “Any party may obtain discovery . . . by taking in California the oral deposition of any person, including any party to the action. The person deposed may be a natural person, an organization such as a public or private corporation, a partnership, an association, or a governmental agency.”¿ (Cal. Code Civ. Proc. §2025.010.)¿¿¿ 

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“If, after service of a deposition notice, a party . . ., without having served a proper 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.”¿¿(Cal. Code Civ. Proc., §2025.450(a).)¿The motion must set forth both facts showing good cause justifying the demand for any documents and a meet and confer declaration or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance.¿(Cal. Code Civ. Proc., §2025.450(b)(1) – (b)(2).)¿¿¿¿ 

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A court shall impose monetary sanctions if the motion to compel is granted, unless the one subject to sanction acted with substantial justification or other circumstances would make the imposition of the sanction unjust. (Cal. Code Civ. Proc.,¿§2025.450(g)(1).)¿¿ 

 

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Meet and Confer Requirement – Cal. Code Civ. Proc. § 2025.450(b) states: “[t]he motion shall be accompanied by a meet and confer declaration under Section 2016.040, or, when the deponent fails to attend the deposition and produce the documents, electronically stored information, or things described in the deposition notice, by a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance.” It does not appear that a meet and confer occurred. Instead, what is presented is that Defendants noticed two depositions to which Plaintiff failed to appear and Defendants noticed two other depositions, one on a mutually agreed upon date, to which Plaintiff’s counsel’s firm, First Law Group, stated that they could not attend due to scheduling conflicts. (See Decl. Quiller [generally].)

 

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Discussion

 

Application – Defendants move to compel Plaintiff’s deposition. Defendants present that they served four notices of depositions and Plaintiff has objected each time.

 

Defendants present that Plaintiff’s deposition should be compelled under Cal. Code Civ. Proc. § 2023.540(a) and that, as Plaintiff has alleged significant injuries and damages causes by Defendants, a deposition is needed to obtain detailed information about the Plaintiff in order for Defendants to defend itself.

 

Exhibits 1 through 6 detail the notices for Plaintiff’s deposition and the communications that Defendants have had with First Law Group regarding them. Plaintiff has claimed a scheduling conflict for two of deposition notices. (Exh. 4 [“Please be advised that due to scheduling conflict, we are unable to move forward with plaintiff’s unilaterally noticed deposition set for 8/25 at 10:00 a.m.”]; Exh. 6 [“Unfortunately, due to schedule conflict, we will be unable to move forward with plaintiff’s deposition set for Friday, 10/6 at 11:00 a.m. We are gathering dates of availability for November and will forward them once in receipt.”].) Quiller presents that, as to the other two depositions, Plaintiff failed to appear. (Decl. Quiller ¶ 3.)

 

The Court notes that the Memorandum of Points and Authorities does not begin until after approximately 43 pages of exhibits. The Court requests that the parties file their documents with the Memorandum of Points of Authorities prior to the exhibits.

 

The Court further notes, as this is a motion to compel, the parties were required an Informal Discovery Conference (“IDC”) prior to filing this motion under Department A14’s Courtroom Rules.

 

The Court, however, exercises its discretion to rule on this matter despite the failure to meet and confer under Cal. Code Civ. Proc. § 2025.450(b) and the failure to schedule an IDC under Department A14’s Courtroom rules.

 

There has been no reason presented for Plaintiff’s failure to appear for two out of the four depositions. It is also unclear as to why First Law Group would agree to a date for a deposition that they and/or Plaintiff could not attend.

 

Accordingly, the Motion to Compel is GRANTED.

 

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Sanctions

 

Defendants request sanctions in the amount of $1,000.00 [4 hrs @ $250.00/hr].

 

Cal. Code Civ. Proc. § 2025.450(g)(1) provides:

 

If a motion under subdivision (a) is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.

 

There has been no presentation as to the reasoning behind Plaintiff’s failure to appear to two scheduled depositions. There has been a presentation by First Law Group that, as to two depositions, including the one to which First Law Group agreed upon, there were scheduling conflicts.

 

As such, the Court imposes a sanction of $1,000.00.

 

 

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Conclusion

 

Defendants Antelope Valley Schools Transportation Agency and Sherryl Lynn Hammond’s Motion to Compel Deposition of Plaintiff Erica Joan Walling is GRANTED.

 

A sanction of $1,000.00 is imposed upon Plaintiff Erica Joan Walling and her counsel, Dean Hakkak, jointly and severally.