Case Number: BC673635 Hearing Date: March 12, 2018 Dept: 92

MERCY NABAVI,

Plaintiff,

vs.

CITY OF LOS ANGELES, ET AL.

Defendants.

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CASE NO: BC673635

[TENTATIVE] ORDER GRANTING DEFENDANT CITY OF LOS ANGELES’ UNOPPOSED MOTIONS TO COMPEL

Dept. 92

1:30 p.m.

March 12, 2018

Defendant City of Los Angeles (”Defendant”) propounded form interrogatories, special interrogatories, and RPDs on Plaintiff on 10/13/17. To date, despite an attempt to meet and confer, Plaintiff has not served responses. Defendant therefore seeks an order compelling Plaintiff to respond, without objections, to the outstanding discovery and to pay sanctions.

Defendant’s motions are granted. Plaintiff is ordered to serve verified responses to form interrogatories, special interrogatories, and RPDs, without objections, within ten days. CCP §§2030.290(a),(b), 2031.300(a),(b).

Sanctions are mandatory. §§2030.290(c), 2031.300(c). Defendant seeks sanctions in the total amount of $700 –two hours to prepare the motion for order compelling responses to interrogatories and a half-hour to prepare the motion for order compelling responses to demand for production and inspection of documents and one hour to appear at the hearing, all at $200/hour. The Court determines that the sanctions requested are reasonable. Sanctions in the amount of $100 are sought against Plaintiff only on the motion for order compelling responses to demand for production and inspection of documents, whereas sanctions in the amount of $600 are sought against Plaintiff and her attorneys of record[1], jointly and severally, on the motion for order compelling responses to interrogatories. Plaintiff is ordered to pay sanctions to Defendant, by and through his attorney of record, in the total amount of $700, within twenty days. Plaintiff’s attorneys of record are jointly and severally liable in the amount of $600.

Dated this 12th day of March, 2018

Hon. Marc Gross

Judge of the Superior Court

[1] Plaintiff’s attorneys of record as of the date these motions were filed were Raymond Ghermezian (“Ghermezian”) of Raymond Ghermezian, a Professional Law Corporation, in association with David Azizi of the Law Offices of David Azizi (“Azizi”). On 2/9/18, a Substitution of Attorney was filed, wherein Victor H. Jaime of Brown Associates, APLC substituted in as Plaintiff’s counsel in Ghermezian’s stead. Ghermezian and Azizi are jointly and severally liable for the $600 in sanctions herein imposed.