Case Number: BC639818 Hearing Date: August 31, 2018 Dept: 3

RICCI ROSEN,

Plaintiff(s),

vs.

MARK ROTHMAN, ET AL.,

Defendant(s).

CASE NO: BC639818

[TENTATIVE] ORDER GRANTING DEFENDANT’S UNOPPOSED MOTIONS TO COMPEL

Dept. 3

1:30 p.m.

August 31, 2018

Defendant propounded form interrogatories, special interrogatories, and RPDs on Plaintiff on 5/03/18. 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 amount of $572/motion. Defense Counsel bills at the rate of $133/hour. The Court awards one hour per motion to prepare these form discovery motions. The Court therefore awards the requested two hours of appearance time, but only awards the time once. The Court therefore awards a total of five hours of attorney time at the rate of $133/hour, for a total of $665 in attorneys’ fees. The Court also awards three filing fees of $60 each, or $180 in costs.

Sanctions are sought and imposed against Plaintiff and her attorney of record, jointly and severally; they are ordered to pay sanctions to Defendant, by and through counsel of record, in the total amount of $845, within twenty days.

Defendant is ordered to give notice.