Case Number: BC699767 Hearing Date: May 17, 2019 Dept: 3

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT

CHENG SAN,

Plaintiff(s),

vs.

ELISABETH SHEN, ET AL.,

Defendant(s).

CASE NO: BC699767

[TENTATIVE] ORDER GRANTING DEFENDANT’S UNOPPOSED MOTIONS TO COMPEL AND MOTION TO DEEM RFAS ADMITTED

Dept. 3

1:30 p.m.

May 17, 2019

Defendant propounded special interrogatories, set one, form interrogatories, set two, RFAs, set one, and RPDs, set two on Plaintiff on 11/29/18. To date, despite multiple meet and confer efforts, Plaintiff has not served responses. Defendant therefore seeks an order compelling Plaintiff to respond, without objections, to the outstanding interrogatories and RPDs, deeming the RFAs admitted, and imposing sanctions.

Defendant’s motions to compel are granted. Plaintiff is ordered to serve verified responses to form interrogatories, set two, special interrogatories, set one, and RPDs, set two, without objections, within ten days. CCP §§2030.290(a),(b), 2031.300(a),(b).

Defendant’s motion to deem RFAs, set one admitted is also granted. CCP §2033.280(b).

Sanctions are mandatory. §§2030.290(c), 2031.300(c), 2033.280(c). Defendant seeks sanctions in varying amounts in connection with each motion. The Court awards one hour to prepare each form discovery motion. The Court awards the requested three hours of time to appear, but only awards the time once. The Court awards a total of seven hours of attorney time at the requested rate of $185/hour, or $1295 in attorneys’ fees. The Court also awards the requested 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 her attorney of record, in the total amount of $1535, within twenty days. Defendant is ordered to give notice.