Lawzilla Additional Information:
Per the Santa Clara records we believe defendants are represented by attorney Matthew Webb

Case Name: Anne Holland Ventures, Inc. v. Kirsch, et al.
Case No.: 1-12-CV-223058

Plaintiff Anne Holland Ventures, Inc.’s (“Plaintiff”) motion to compel the depositions of defendants Aimen Taher Barma (“Barma”) and Zameer Minhas (“Minhas”) and to compel responses to requests for production of documents is GRANTED.

With respect to the depositions of Barma and Minhas (collectively, “Defendants”), Defendants identify no statutory provision or applicable case law suggesting that their purported unavailability allows them to disregard notices of deposition. They were obliged to either appear for their depositions or file a motion for a protective order, which they did not do. (See Code Civ. Proc., §§ 2025.450, subd. (a), 2025.420, subd. (b).) In addition, they have not justified their requests for further delay in taking their depositions. Accordingly, Defendants shall appear and be deposed within 20 calendar days, at a date and time that is mutually agreed upon by the parties. Barma shall be given reasonable breaks and the option of having the deposition at her home.

With respect to the requests for production of documents, Defendants served untimely and unverified responses, containing substantive responses and objections. Since some substantive responses were provided, the lack of verification means that the responses technically do not exist. (See Appleton v. Superior Court, supra, 206 Cal.App.3d 632 at pp. 635 -636.) Further, as Defendants’ responses were untimely, all of the objections are waived. (See Code Civ. Proc., § 2031.300, subd. (a).) Accordingly, within 20 calendar days, Defendants shall serve verified code-compliant responses to the requests for production of documents, without objections, and produce documents in accordance with the responses.

Plaintiff’s request for monetary sanctions against Defendants and their counsel is GRANTED IN PART in the amount of $1,125. Plaintiff prevailed on the matter, Defendants’ opposition was not substantially justified and no other circumstances make the imposition of sanctions unjust. (Code Civ. Proc., §§ 2025.450, subd. (g)(1); 2031.300, subd. (c).) Accordingly, within 20 calendar days, Defendants, and/or their counsel shall pay $1,125 to Plaintiff’s counsel.