Judge: Yolanda Orozco, Case: 21STCV25741, Date: 2023-01-18 Tentative Ruling

Counsel may submit on the tentative ruling by emailing Dept. 31 before 8:30 the morning of the hearing. The email address is smcdept31@lacourt.org. Please do not call the court to submit on the tentative. Please do not submit to the tentative ruling on behalf of the opposing party. Please do not e-mail the Court if you plan to appear and argue.

In deciding whether to submit on the tentative ruling or attend the hearing and present oral argument, please keep the following in mind:

The tentative rulings authored by this court reflect that the court has read and considered all pleadings and evidence timely submitted to the court in connection with the motion, opposition, and reply (if any). Because the pleadings were filed, they are part of the public record.

Oral argument is not an opportunity to simply regurgitate that which a party set forth in its pleadings. Nor, is oral argument an opportunity to "make a record" when there is no court reporter present and the statements and arguments of counsel are already part of the record because they were set forth in the pleadings. Finally, simply because a party or attorney disagrees with the court's analysis and ruling or is not satisfied with it does not necessarily warrant oral argument when no new arguments will be articulated.

If you submit on the tentative, you must immediately notify all other parties email that you will not appear at the hearing. If you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the motions. If all parties to the motion submit, this tentative ruling will become the final ruling after the hearing date and it will be memorialized in a minute order. This tentative ruling is not an invitation, nor an opportunity, to file further documents relative to the hearing in question. No such document will be considered by the Court.

**Tentative rulings on Motions for Summary Judgment will only be available for review in the courtroom on the day of the hearing.



Case Number: 21STCV25741    Hearing Date: January 18, 2023    Dept: 31

MOTION TO COMPEL DISCOVERY 

TENTATIVE RULING 

plaintiff’s Motion to Compel is DENIED. 

Background 

On July 13, 2021, Plaintiff initiated the present action by filing a Complaint against Netflix, and two (2) of her supervisors, David B. McLean and Josephine Choy (collectively, “Defendants”).

 

The operative First Amended Complaint asserts causes of action for:

 

1)               Gender Discrimination in Violation of Government Code §12940(a);

2)               Race Discrimination in Violation of Government Code § 12940(a);

3)               Harassment in Violation of Government Code §§ 12923 and 12940(j);

4)               Violation of Government Code § 12940(k);

5)               Violation of Government Code § 12940(h);

6)               Retaliation in Violation of Labor Code § 1102.5;

7)               Violation of Labor Code §§ 1197.5, 1194.5;

8)               Wrongful Termination in Violation of Public Policy;

9)               Defamation; and

10)           Intentional Infliction of Emotional Distress (IIED).

 

On September 22, 2023, Plaintiff filed a Motion to Compel Discovery.

 

Defendant filed opposing papers on January 04, 2023.

 

Plaintiff filed a reply on January 11, 2023. 

Legal Standard 

Where a party fails to serve timely responses to discovery requests, the court may make an order compelling responses.  (Code Civ. Proc., §§ 2030.290, 2031.300; Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 403.)  A party that fails to serve timely responses waives any objections to the request, including ones based on privilege or the protection of attorney work product.  (Code Civ. Proc., §§ 2030.290, subd. (a), 2031.300, subd. (a).)  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 has no meet and confer obligations.¿ (Sinaiko Healthcare Consulting, Inc. v. Pac. Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.)¿¿ 

¿ 

¿If a propounding party moves for and obtains a court order compelling a response, the court shall impose monetary sanctions against the party failing to timely respond to interrogatories and demands for inspection unless that party acted with substantial justification or the sanction would otherwise be unjust. (Code Civ. Proc., §§ 2030.010, 2030.290, 2031.300, 2033.28;¿Sinaiko¿Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 404.)¿ 

Request for Judicial Notice

 Defendant’s Request for Judicial Notice is DENIED as it is irrelevant to the disposition of this Motion. (See American Cemwood Corp. v. American Home Assurance Co. (2001) 87 Cal.App.4th 431, 441, fn. 7 [“Although a court may judicially notice a variety of matters (Evid. Code, §¿450 et seq.), only relevant material may be noticed.”].) 

Discussion 

Plaintiff seeks an Order compelling Defendants Netflix, Inc. (“Netflix”); David B. McLean a/k/a Ben McLean (“McLean”); and Josephine Choy (“Choy’) (collectively “Defendants”) to respond to Plaintiff’s Second Request for Production on Documents.

 

Specifically, Plaintiff wants an order compelling Defendants to search for and produce responsive electronically stored information (“ESI”) utilizing the search terms and custodians propounded by Plaintiff and entering Plaintiff’s Proposes Protective Order and other relief the Court deems just and proper.

 

Plaintiff asserts that Defendants have not produced a single document responsive to Plaintiff’s Document Request. However, by Plaintiff’s own admission, Defendants did respond to Plaintiff’s Second Request for Production of Documents with objections and responses to the Documents request. (Ostrowski Decl. ¶ 7; Lawson Decl. ¶ 6.) 

A motion to compel initial discovery is appropriate when no answer or objections are filed. (See Vidal Sassoon, Inc. v. Superior Court (1983) 147 Cal.App.3d 681, 684.) Since Defendants responded to Plaintiff’s propounded discovery with responses and objections, Plaintiff’s Motion is a motion seeking to compel further responses. It is immaterial that no responsive documents were produced. This Court’s Standing Order requires that an Informal Discovery Conference (“IDC”) be held prior to the hearing on Plaintiff’s motion to compel further. The IDC is not scheduled to be heard until February 06, 2023. 

Moreover, Plaintiff’s notice of sanctions is also deficient.

 

A request for a sanction shall, in the notice of motion, identify every person, party, and attorney against whom the sanction is sought, and specify the type of sanction sought. The notice of motion shall be supported by a memorandum of points and authorities and accompanied by a declaration setting forth facts supporting the amount of any monetary sanction sought.” 

 

(Code Civ. Proc., § 2023.040.) 

 

Here, Plaintiff’s Notice of Motion does not specify against whom the sanctions are sought or the amount of sanctions sought.

 

Since the IDC may resolve some of the discovery disputes at issue in this Motion, the Motion is DENIED. Plaintiff is ordered to refile the Motion after the IDC conference is held so that the moving papers accurately reflect the Parties remaining discovery disputes. The motion must be filed as a motion to compel further written responses, accompanied by a separate statement. 

Conclusion 

plaintiff’s Motion to Compel is DENIED. 

Plaintiff is to give notice.