Judge: Steven A. Ellis, Case: 22STCV10651, Date: 2023-08-24 Tentative Ruling

Case Number: 22STCV10651    Hearing Date: September 8, 2023    Dept: 29

TENTATIVE

The Court GRANTS the motions to compel and GRANTS in part the requests for sanctions.

Background

On March 28, 2022, Plaintiff Norma Oneida Moran Solares (hereafter “Plaintiff”) filed a complaint against Big Lots Stores, Inc., and DOES 1 through 50, inclusive, asserting a cause of action for premises liability stemming from an injury allegedly sustained on or about October 2, 2019, on Defendant’s premises.

On January 3, 2023, Defendant Big Lots Stores – PNS, LLC (erroneously sued as Big Lots Stores, Inc.) (“Defendant”) filed an answer to the complaint.

The same day, Defendant served Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production (Set One) on Plaintiff. (Mathis Decls., ¶ 3 & Exs. A.) Defendant granted Plaintiff two extensions of time to respond to the discovery. (Id., ¶¶ 5-6.) Nonetheless, Plaintiff never responded. (Id., ¶ 7.)

On April 3, 2023, Defendant filed these motions to compel initial responses to the discovery. On August 24, 2023, a hearing was held on Defendant’s motions to compel initial responses to the discovery. At the request of Plaintiff’s counsel, the hearing was continued to September 8, 2023; Plaintiff was ordered to file oppositions by August 31, 2023, and Defendant was ordered to file any replies by September 6, 2023. (Minute Order (8/24/2023).) Plaintiff still did not file any opposition.

Legal Standard

 

              A responding party has 30 days after service of interrogatories and an inspection demand to serve their responses on the propounding party and/or party making the demand. (Code of Civ. Proc., §§ 2030.260(a), 2031.260(a).)

If the responding party fails to timely respond to the interrogatories, “The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030.230, as well as any objection to the interrogatories, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018.010).” (Code of Civ. Proc., § 2030.290(a).)

If a responding party fails to timely respond to the inspection demand, “The party to whom a demand for inspection, copying, testing, or sampling is directed waives any objection to the demand, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018.010).” (Code of Civ. Proc., § 2031.300.)

Furthermore, the party propounding the interrogatories and/or making the demand may move for an order compelling response to the interrogatories and inspection demand. (Code of Civ. Proc., §§ 2030.290(b), 2031.300(b).) And “Unlike a motion to compel further responses, a motion to compel responses is not subject to a 45-day time limit, and the propounding party does not have to demonstrate either good cause or that it satisfied a ‘meet and confer’ requirement.” (Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.)

Discussion

On January 3, 2023, Defendant served Plaintiff with discovery that included Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production (Set One). (Mathis Decls., ¶ 3 & Exs. A.) Plaintiff never responded to this discovery. (Id., ¶ 7.)

Defendant need show no more. Defendant’s motions to compel responses to Form Interrogatories (Set One), Special Interrogatories (Set One), and Request for Production of Documents (Set One) is granted.

Defendant’s requests for monetary sanctions are also granted. Given the relatively straightforward nature of a motion to compel initial responses, and the economies of scale associated with filing two parallel motions at the same time, the Court sets the amount of sanctions as $382.50 per motion (1.5 hours of attorney time multiplied by the billing rate of $255 per hour). (See Mathis Decl., ¶ 8.) The total amount of the monetary sanctions awarded is $765.

Conclusion

The Court GRANTS the motions to compel. Plaintiff is ORDERED to serve code compliant, verified written responses, without objection to Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production (Set One) within 30 days of notice of this order.

The Court GRANTS in part Defendant’s requests for sanctions. Plaintiff and her attorney of record, the Alpine Law Group, are ORDERED, jointly and severally, to pay monetary sanctions in the amount of $765 ($382.50 per motion, multiplied by two motions) to Defendant within 30 days of notice of this order.

              Defendant to give notice.