Judge: Yolanda Orozco, Case: 19STCV43861, Date: 2022-10-18 Tentative Ruling

Case Number: 19STCV43861    Hearing Date: October 18, 2022    Dept: 31

MOTION TO COMPEL TESTIMONY AT DEPOSITION IS DENIED WITHOUT PREJUDICE 

Background 

On December 5, 2019, Plaintiffs Fred Stepen, Debra, Nussbaum, Chaim Stepen, Shimon, and Gloria Stepen commenced their action against Defendants Zion Vanounou (“Zion”), Moshe Vanounou, 2202 East Anderson Street, LLC and Does 1 through 50. The Complaint asserts causes of action for:  

 

1)     Breach of Written Contract;  

2)     Breach of Oral Contract;  

3)     Fraud;  

4)     Negligent Misrepresentation;  

5)     Constructive Fraud;  

6)     Breach of Covenant of Good Faith and Fair Dealing;  

7)     Declaratory Relief;  

8)     Breach of Fiduciary Duty;  

9)     Accounting;  

10) Transfer of Ownership of Company Assets;  

11) Compel Payment of Paid Distributions;  

12) Unjust Enrichment;  

13) Partition;  

14) Breach of Duty of Loyalty; and 

15) Conversion.

 

On May 5, 2022, Plaintiffs requested an Informal Discovery Conference to be conducted on July 15, 2022. On July 15, 2022, the Court did not conduct an IDC but instead, based on Plaintiffs’ Discovery Conference Statement, took the IDC off calendar and advised Plaintiffs to file a Motion to Compel. (See Min. Or. 07/15/22.)

 

On July 27, 2022, Plaintiff Fred Stepen filed a Motion to Compel Testimony at Deposition of Defendant Moshe Vanounou.

 

Defendant Vanounou filed Opposition papers on August 8, 2022. 

Legal Standard 

California Code of Civil Procedure section 2025.480, subdivision (a) states: “If a deponent fails to answer any question . . . the party seeking discovery may move the court for an order compelling that answer. . . .”  “A motion to compel further is the appropriate motion when the responding party provides a response to the propounded discovery.  (See Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 788.)

 

A motion to compel a deponent to answer must be “made no later than 60 days after the completion of the record of the deposition, and shall be accompanied by a meet and confer declaration under Section 2016.040.” (Code Civ. Proc., § 2025.480(b).)  “If the court determines that the answer production sought is subject to discovery, it shall order that the answer be given or the production be made on the resumption of the deposition.” (Id., § 2025.480(i).) 

“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 a motion to compel an answer or production, 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.” (Id., § 2025.480(j).)

 Meet and Confer 

Plaintiffs’ counsel, Moses S. Bardavid, declares that he attempted to resolve discovery issues via emails and calls with Moshe Vanounou’s counsel. (Bardavid ¶ 6.) According to Plaintiffs’ counsel, Vanounou’s counsel stated that because he was not involved in the criminal matter, he could do nothing about Vanounou’s asserting his 5th Amendment right to not answer certain questions at the deposition. (Id.) The Court is satisfied that the meet and confer requirement is met. 

Discussion 

The suit pertains to ownership interest of a property (“Santa Fe Property”), located in South Santa Fe Avenue in Vernon, CA. Plaintiffs move for an Order compelling Defendant Moshe Vanounou (“Moshe”) to provide testimony at deposition relating to the Santa Fe Property and sanctions in the amount of $7,260.00.

On April 14, 2022, Plaintiffs conducted the deposition of Defendant Moshe Vanounou, who refused to answer questions pertaining to the ownership of the subject property by asserting his 5th Amendment right against self-incrimination and attorney-client privilege. Defendant Vanounou’s refusal to answer questions stemmed from a contempt motion brought in a divorce proceeding by Vanounou’s ex-wife and a different unrelated criminal matter. (Mot. Ex. B, C.)

On August 19, 2022, the request for sanctions was denied as Moshe acted with substantial justification and the hearing was continued until after Moshe’s contempt hearing was held.

Counsel for Defendant Moshe asserts that the contempt hearing has been held, and that he has provided Plaintiffs’ counsel with dates for the deposition of Moshe but has not heard back from Plaintiffs’ counsel. (Brown Decl. ¶4-10, Ex. 1 - 5.)  Counsel for Moshe also asserts he received Plaintiffs’ reply in support of this Motion filed on October 11, 2022, however, no reply has been filed with this Court.

As it appears the motion may now be moot as Defendant has offered dates for the deposition and is waiting to hear back from Plaintiff. In addition, Plaintiff’s reply has not been filed with the court. Based on the foregoing, the motion is DENIED without prejudice. Plaintiff may renew his motion if it becomes necessary.   

Conclusion 

For the reasons stated, Plaintiffs’ Motion to Compel is DENIED without prejudice. 

Plaintiff is to give notice.