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

Case Number: BC621485 Hearing Date: April 10, 2018 Dept: 98

ORDER RE: DEFENDANT’S MOTION TO COMPEL PLAINTIFF’S RESPONSES TO DISCOVERY AND REQUEST FOR SANCTIONS; MOTIONS DENIED AS MOOT

On May 24, 2016, Plaintiff Cecilia Amezquita (“Plaintiff”) filed this action against Defendant WSP 1310 Wilton, LLC (“Defendant’) for premises liability and negligence. On August 31, 2017, Defendant served Form Interrogatories, Special Interrogatories, Request for Production of Documents, and Request for Admissions on Plaintiff. (Declaration of Maral I. Gasparian, ¶ 4; Exh. A.) Plaintiff failed to serve timely responses and Defendant’s counsel granted multiple extensions. (Gasparian Decl., ¶¶ 5-7.) Defendant received no responses and filed these Motions to compel responses and requested monetary sanctions on March 14, 2018.

Where a party fails to serve timely responses to discovery requests, the court may make an order compelling responses. (Code of Civ. Proc., §§ 2030.290, 2031.300; Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 403.) A party that fails to serve timely responses waives any objections to the request, including ones based on privilege or the protection of attorney work product. (Code of Civ. Proc., §§ 2030.290, subd. (a), 2031.300, subd. (a).) Unlike a motion to compel further responses, a motion to compel responses is not subject to a 45-day time limit and the propounding party has no meet and confer obligations. (Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at p. 404.)

Plaintiff’s counsel avers that responses to Defendant’s discovery requests were served on March 12, 2018 and therefore, these Motions are moot. (Declaration of Bob B. Khakshooy, ¶ 2; Exh. 1.) These Motions to compel are denied as MOOT.

However, the court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even where the requested discovery was provided to the moving party after the motion was filed. (Cal. Rules of Court, Rule 3.1348(a).)

Monetary sanctions are GRANTED and imposed against Plaintiff and Plaintiff’s counsel of record, jointly and severally, in the amount of $920.00, for three hours preparing these motions and one hour attending the hearing, at counsel’s rate of $185.00 per hour, plus $180.00 for filing fees. The sanctions are to be paid to Defendant’s counsel within twenty (20) days of the date of this Order.

Moving party to give notice.