Case Number: 19STCV13209 Hearing Date: February 19, 2020 Dept: 48

Plaintiff Guadalupe Rodriguez’ Motion To Compel Further Responses To Form Interrogatories

This motion was timely served and filed on November 18, 2019, which is prior to the November 19, 2019 deadline based upon Defendant’s mail service of responses on September 30, 2019.

Plaintiff’s counsel engaged in sufficient meet and confer efforts prior to bringing this motion. See Declaration of Daniel J. Friedman, ¶ 6; Exh. 5.

Form Interrogatories—Employment Law Nos. 200.1, 200.2, 200.3, 200.4, 200.5, 200.6, 201.1, 201.2, 201.3, 201.4, 201.5, 201.6, 201.7, 206.2, 206.3, 207.1, 207.2, 208.1, 208.2, 209.2, 211.1, 211.2, 211.3, 214.1, 214.2, 215.1, 215.2, 216.1, 217.1: GRANT.

The responses do not comply with CCP § 2030.220, which states:

(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.

Defendant’s objections are OVERRULED as without merit.

Further responses are due without objection within 20 days.

Plaintiff’s request for sanctions against Defendant Ray of Hope Home, Inc. is GRANTED in the requested amount of $1,063.32. Sanctions are to be paid to Plaintiff’s counsel within 20 days.

Plaintiff Guadalupe Rodriguez’Motion To Compel Further Responses To Requests For Admission

This motion was timely served and filed on November 18, 2019, which is prior to the November 19, 2019 deadline based upon Defendant’s mail service of responses on September 30, 2019.

Plaintiff’s counsel engaged in sufficient meet and confer efforts prior to bringing this motion. See Declaration of Daniel J. Friedman, ¶ 6; Exh. 5.

Requests For Admission Nos. 1 – 46: GRANT.

The responses do not comply with CCP § 2033.220, which states:

(a) Each answer in a response to requests for admission shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) Each answer shall:

(1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party.

(2) Deny so much of the matter involved in the request as is untrue.

(3) Specify so much of the matter involved in the request as to the truth of which the responding party lacks sufficient information or knowledge.

(c) If a responding party gives lack of information or knowledge as a reason for a failure to admit all or part of a request for admission, that party shall state in the answer that a reasonable inquiry concerning the matter in the particular request has been made, and that the information known or readily obtainable is insufficient to enable that party to admit the matter.

Defendant’s objections are OVERRULED as without merit.

Further responses are due without objection within 20 days.

Plaintiff’s request for sanctions against Defendant Ray of Hope Home, Inc. is GRANTED in the requested amount of $1,063.32. Sanctions are to be paid to Plaintiff’s counsel within 20 days.

Moving party is ordered to give notice.