Case Number: BC709382 Hearing Date: October 30, 2019 Dept: 3

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT

GOORGEN HAROOTOONYAN,

Plaintiff(s),

vs.

RUIYAN WU, ET AL.,

Defendant(s).

CASE NO: BC709382

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

Dept. 3

1:30 p.m.

October 30, 2019

Cross-Complainant, Ricardo Fuentes propounded form interrogatories, RFAs, and RPDs on Cross-Defendant, Ruiyan Wu on 3/11/19. To date, despite multiple attempts to meet and confer, Cross-Defendant has not served responses. Cross-Complainant therefore seeks an order compelling Cross-Defendant to provide verified responses, without objections, to the outstanding discovery, deeming the RFAs admitted, and imposing sanctions.

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

The motion to deem RFAs admitted is also granted. §2033.280(a),(b).

Sanctions are mandatory. §§2030.290(c), 2031.300(c), 2033.280(c). Cross-Complainant seeks sanctions in the amount of $1180/motion. The Court reduces Counsel’s billing rate from $350/hour to $200/hour, which is more typical in the personal injury courts. The Court awards one hour to prepare each form discovery motion. No opposition was filed and therefore no reply was necessary. The Court awards the requested 1.8 hours to appear at the hearing. The Court therefore awards a total of 4.8 hours of attorney time at the rate of $200/hour, or $960 in attorneys’ fees. The Court awards three filing fees of $60 each, or $180 in costs.

Sanctions are sought and imposed against Cross-Defendant and her attorney of record, jointly and severally; they are ordered to pay sanctions to Cross-Complainant, by and through counsel of record, in the total amount of $1140, within twenty days.

Cross-Complainant is ordered to give notice.