There is no “reasonable and good faith meet and confer” requirement imposed upon the propounding party when the responding party has simply ignored the discovery requests. Sinaiko Healthcare Consulting v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.

With regard to the Form Rogs, defendant is ordered to provide complete, substantive responses, without objections, within 25 days. Since there was no opposition filed, sanctions are only proper per CCP §2023.030(a) and CRC 3.1348(a). Counsel’s billing rate is a very modest $175. Sanctions are awarded in the amount of $527.50 – payable within 30 days.

With regard to the Special Rogs, defendant is ordered to provide complete, substantive responses, without objections, within 25 days. Since there was no opposition filed, sanctions are only proper per CCP §2023.030(a) and CRC 3.1348(a). Counsel’s billing rate is a very modest $175. Sanctions are awarded in the amount of $497.50 – payable within 30 days. [The $30 court reporter fee should have only been charged once.]

With regard to the Request to Produce, they bear facially on a proper subject to this litigation and good cause exists therefor. Defendant is ordered to provide complete, substantive responses, without objections, within 25 days. Since there was no opposition filed, sanctions are only proper per CCP §2023.030(a) and CRC 3.1348(a). Counsel’s billing rate is a very modest $175. Sanctions are awarded in the amount of $497.50 – payable within 30 days. [The $30 court reporter fee should have only been charged once.]

With regard to the Requests For Admission, they bear facially on a proper subject to this litigation and good cause exists therefor. Unless a substantially compliant response has been served prior to the hearing, all matters contained therein are hereby deemed admitted by defendant. Sanctions are not provided for under CCP §2033.280 unless a delinquent response is served, and this Court elects not to exercise its discretion to award monetary sanctions under §2023.030. Sanction denied for this motion.