Case Number: BC645064 Hearing Date: June 11, 2018 Dept: 51

Plaintiff Celena King has filed as a single motion three motions to compel: form interrogatories, special interrogatories, and request for production.

The motions will be GRANTED upon proof of payment to courtroom staff of two additional motion fees.

This discovery was served on May 23, 2017. The initial responses came on November 3, 2017. They were almost all entirely objections and many are absurd. For instance, it appears that every single *form* interrogatory was objected to without a substantive response, and many are objected to as (among other things) “vague ambiguous, and overbroad” although they are interrogatories that are routinely answered throughout the state. In dozens of pages of these discovery responses, it appears that there was no information actually produced (or very little information). These responses were obviously not a serious effort to respond to the discovery requests.

Various extensions were agreed upon following that, and defendant failed to provide responses as promised by January 26, 2018; then failed to provide responses as promised by February 9, 2018; and then provided supplemental responses on February 21, 2018. There were substantively responses provided, but other responses were unwarranted objections.

Ultimately, defendant’s counsel gave plaintiff until April 26, 2018 to file these motions. Defendant did not supplement by that date. Plaintiff did so on that day, the last day permitted, after defendant did not respond to an April 19, 2018, email. If these motions were not filed on that day, jurisdiction to do so would be lost. Plaintiff was warranted in filing these motions at the time she did.

Defendant did ultimately supplement discovery on April 27, 2018. For these to render this motion premature they needed to be served before April 26 or (alternatively) defendant needed to respond to the April 19 email and provide an extension in writing to file these motions to compel.

It is unclear that the April 27 responses add anything of substance.

Supplemental responses are ordered within 14 days.

Sanctions are imposed on defendant and defendant’s counsel in the amount of $3,780 (6 hours of work at $600 per hour plus $180 in filing fees) ordered to be paid to plaintiff within 21 days.

Plaintiff to give notice.