Lawzilla Additional Information:
Per the Los Angeles court records plaintiff is represented by attorney Robert Mobasseri who is being sanctioned by the court.

Case Number: BC629749 Hearing Date: April 18, 2018 Dept: 3

CAYLA CARPENTER,

Plaintiff(s),

vs.

AB ACQUISITIONS, LLC, et al.,

Defendant(s).

Case No.: BC629749

[TENTATIVE] ORDER

· GRANTING MOTION TO COMPEL DEPOSITION

· GRANTING MOTIONS TO COMPEL RESPONSES TO DISCOVERY

· IMPOSING SANCTIONS

Dept. 3

1:30 p.m.

April 18, 2018

Defendant noticed Plaintiff’s deposition for January of 2018. At Plaintiff’s attorney’s request, the deposition was rescheduled for 3/01/18. Prior to the 3/01/18 deposition, Plaintiff’s attorney requested a continuance of the deposition, indicating that substantive discovery responses would be served by 3/09/18, and that the deposition would be ripe thereafter. However, Plaintiff has not provided substantive discovery responses, and has not provided new dates for deposition; indeed, Plaintiff’s attorney has a motion to be relieved as counsel pending. At this time, Defendant seeks an order compelling Plaintiff to attend her deposition.

The motion to compel is granted. CCP §2025.450(a). Within five days counsel are to meet and confer to attempt to agree on a date and time for the depo. If unable to agree, Defense Counsel may set the deposition on Defense Counsel’s terms with five days’ notice to Plaintiff (extended per Code if service is by other than personal service). The Court notes that the notice of deposition includes a demand for production of documents. The moving papers fail to show good cause for production of the documents sought, as required by §2025.450(b)(1). The Court therefore declines to enter an order compelling Plaintiff to produce documents, but urges the parties to work together to resolve any issues concerning documents without court intervention.

Defendant propounded form interrogatories, special interrogatories, and RPDs on Plaintiff on 12/20/17. To date, despite multiple extensions of time to respond and an additional meet and confer attempt, 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).

Defendant seeks sanctions against Plaintiff in the amount of $1060/motion. Sanctions are mandatory. §§2025.450(c), 2030.290(c), 2031.300(c). The Court awards one hour of attorney time per motion to draft these form motions to compel. No opposition was filed and therefore not reply was necessary. The Court awards three hours of time to appear; but only awards the time once. The Court therefore awards a total of seven attorney hours at the reasonable and requested rate of $250/hour, or $1750 in attorneys’ fees. The Court also awards four filing fees of $60 each, or $240 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 amount of $1990, within twenty days.

Defendant is ordered to give notice.