Judge: Steven A. Ellis, Case: 22STCV13335, Date: 2024-08-05 Tentative Ruling

Case Number: 22STCV13335    Hearing Date: August 5, 2024    Dept: 29

Motion to Compel Plaintiff to Respond to Supplemental Interrogatories.

Motion to Compel Plaintiff to Respond to Supplemental Demand for Production.

Tentative

The motions are granted.

The requests for sanctions are denied.

Background

On April 21, 2022, Terrion Taylor, by and through his Guardian Ad Litem, Terri Walker, Terri Walker, and Tiray Taylor (collectively “Plaintiffs”) filed a complaint against Rampart Investment Corp., Reshma Family Trust, Adam’s Fuel Inc., and Does 1 through 50 for (1) Negligence, (2) Premises Liability, and (3) Negligent Infliction of Emotional Distress, arising out of an incident in which Terrion Taylor was allegedly burnt by scalding water.

On June 16, 2023, Reshma Family Trust (“Defendant”) filed an answer to the complaint.

Plaintiffs served Defendant with discovery on January 16, 2024, including Supplemental Interrogatories (Set One), and Supplemental Demand for Production (Set One). (Curry Decls., ¶ 3 & Exhs. A.)  Defendant has not responded. (Id., ¶ 5.)

On June 6, 2024, Plaintiffs filed these two motions: (1) motion to compel Plaintiff to respond to Supplemental Interrogatories; and (2) motion to compel Plaintiff to respond to Supplemental Demand for Production.  In each motion, Defendant also seeks sanctions.

No opposition has been filed.

Legal Standard

A party must respond to interrogatories within 30 days after service. (Code Civ. Proc., § 2030.260, subd.(a).) If a party to whom interrogatories are directed does not provide a timely response, the propounding party may move for an order compelling response to the interrogatories. (Id., § 2030.290, subd. (b).) There is no time limit for a motion to compel initial responses, and no meet and confer efforts are required. (See id., § 2030.290; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.) Nor must a separate statement be filed. (Cal. Rules of Court, rule 3.1345(b)(1).)  In addition, a party who fails to provide a timely response generally waives all objections.  (Code Civ. Proc., § 2030.290, subd. (a).)

“In addition to the number of interrogatories permitted by Sections 2030.030 and 2030.040, a party may propound a supplemental interrogatory to elicit any later acquired information bearing on all answers previously made by any party in response to interrogatories.” (Code Civ. Proc., § 2030.070, subd. (a).)

When a party moves to compel initial responses to interrogatories, “the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes [the motion], unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.”  (Code Civ. Proc., § 2030.290, subd. (c).)

A party must respond to requests for production of documents within 30 days after service. (Code Civ. Proc., § 2031.260, subd.(a).) If a party to whom requests for production of documents are directed does not provide timely responses, the requesting party may move for an order compelling response to the demand. (Id., § 2031.300, subd. (b).) There is no time limit for a motion to compel initial responses, and no meet and confer efforts are required. (See id., § 2031.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.) Nor must a separate statement be filed. (Cal. Rules of Court, rule 3.1345(b)(1).)  In addition, a party who fails to provide a timely response generally waives all objections.  (Code Civ. Proc., § 2031.300, subd. (a).)

“In addition to the demands for inspection, copying, testing, or sampling permitted by this chapter, a party may propound a supplemental demand to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other property, or electronically stored information in the possession, custody, or control of the party on whom the demand is made.” (Code Civ. Proc., § 2031.050, subd. (a).)

When a party moves to compel initial responses to requests for production, “the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes [the motion], unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.”  (Code Civ. Proc., § 2031.300, subd. (c).)

In Chapter 7 of the Civil Discovery Act, Code of Civil Procedure section 2023.010, subdivision (d), defines “[m]isuses of the discovery process” to include “[f]ailing to respond to or to submit to an authorized method of discovery.”  Where a party or attorney has engaged in misuse of the discovery process, the court may impose a monetary sanction in the amount of “the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct.”  (Code Civ. Proc., § 2023.020, subd. (a).)

Discussion

On January 16, 2024, Plaintiffs served Defendant with discovery including Supplemental Interrogatories, and Supplemental Demand for Production. (Curry Decls., ¶ 3 & Exhs. A.)  Defendant has not responded. (Id., ¶ 5.)

Plaintiffs need not show anything more.  The motions to compel Plaintiff to respond to the supplemental interrogatories and the supplemental demand for production are GRANTED. 

The requests for sanctions in connection with the motions to compel responses to the interrogatories and requests for production are DENIED. 

Code of Civil Procedure section 2023.010, subdivision (d), defines “[m]isuses of the discovery process” to include “[f]ailing to respond or to submit to an authorized method of discovery” but does not independently authorize sanctions for such conduct.

Code of Civil Procedure section 2023.030 provides for the imposition of sanctions against any party or attorney who engages in conduct that is a misuse of the discovery process “[t]o the extent authorized by the chapter governing any particular discovery method or any other provision of this title [the Civil Discovery Act].”  This section, itself, does not independently authorize sanctions.

In the chapters of the Civil Discovery Act governing interrogatories and requests for production, the Legislature has authorized sanctions in the context of a motion to compel initial responses “against any party, person, or attorney who unsuccessfully makes or opposes” the motion to compel.  (Code Civ. Proc., §§ 2030.290, subd. (c) & 2031.300, subd. (c).)  Here, however, Defendant has not opposed the motion.  Accordingly, no sanctions are authorized.

Conclusion

The Court GRANTS the Motions to Compel Defendant Reshma Family Trust to Respond to Supplemental Interrogatories (Set One) and Supplemental Demand for Production (Set One).

The Court ORDERS Defendant to serve code compliant, written, verified responses, without objection, to Plaintiffs’ Supplemental Interrogatories within 10 days of notice.

The Court ORDERS Defendant to serve code compliant, written, verified responses, without objection, to Plaintiffs’ Supplemental Demand for Production within 10 days of notice.

The Court DENIES Plaintiffs’ requests for monetary sanctions.

Moving party is ORDERED to give notice.