Case Number: 19STCV14964 Hearing Date: November 14, 2019 Dept: 5

Superior Court of California
County of Los Angeles
Department 5

hilda sanchez,

Plaintiff,

v.

city of los angeles, et al.,

Defendants.

Case No.: 19STCV14964

Hearing Date: November 14, 2019

[TENTATIVE] order RE:

motions to compel discovery responses

Defendant Los Angeles County Metropolitan Transportation Authority (“Defendant”) moves to compel responses from Plaintiff Hilda Sanchez (“Plaintiff”) to: (1) Request for Production of Documents, Set One (“RPD”); (2) Form Interrogatories, Set One (“FROG”); and (3) Special Interrogatories, Set One (“SROG”).

Defendant served the discovery at issue on Plaintiff by mail on July 1, 2019. Defendant provided multiple extensions of time to respond to October 8, 2019. As of the filing date of these motions, Defendant has not received responses from Plaintiff. Plaintiff did not file an opposition prior to the statutory deadline (or any opposition at all), and there is nothing in the record to suggest that Plaintiff has complied with her discovery obligations. Accordingly, the motions to compel responses to the RPD, FROG, and SROG are granted per Code of Civil Procedure sections 2030.290 and 2031.300. Plaintiff is ordered to serve responses to Defendant’s RPD, FROG, and SROG, without objections, within 30 days of service of this order.

Defendant seeks sanctions in connection with the motions. The Court concludes that Plaintiff’s failure to respond to the discovery is an abuse of the discovery process. The Court awards sanctions against Plaintiff and her counsel of record, Raymond Ghermezian, Esq., jointly and severally, in the amount of $1,125 based upon five hours of attorney time at a rate of $225 per hour.

CONCLUSION AND ORDER

Defendant’s motions to compel responses to the RPD, FROG, and SROG are granted per Code of Civil Procedure sections 2030.290 and 2031.300. Plaintiff is ordered to serve verified responses, without objections, within (30) days of notice of this order.

Plaintiff and Plaintiff’s counsel, Raymond Ghermezian, Esq., jointly and severally, are ordered to pay monetary sanctions in the amount of $1,125 to Defendant, by and through counsel, within thirty (30) days of notice of this order.

Defendant is ordered to provide notice of this order and file proof of service of such.

DATED: November 14, 2019 ___________________________

Stephen I. Goorvitch

Judge of the Superior Court