Case Number: BC633431 Hearing Date: December 12, 2018 Dept: 3

NEREIDA AMMARI,

Plaintiff(s),

vs.

ELEANOR ROBINSON, ET AL.,

Defendant(s).

CASE NO: BC633431

[TENTATIVE] ORDER GRANTING DEFENDANT’S UNOPPOSED MOTIONS TO COMPEL

Dept. 3

1:30 p.m.

December 12, 2018

Defendant, Robert Cohen propounded form interrogatories, special interrogatories, and RPDs on Plaintiff on 7/06/18. To date, despite an attempt to meet and confer, 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).

Sanctions are mandatory. §§2030.290(c), 2031.300(c). Defendant seeks sanctions in the amount of $1330/motion. Defense Counsel bills at the rate of $250/hour. The Court awards the requested one hour to prepare each motion. No opposition was filed and therefore no reply was necessary. The Court awards the requested two hours of appearance time, but only awards the time once. The Court therefore awards a total of five hours of attorney time at the rate of $250/hour, for a total of $1250 in attorneys’ fees. The Court also awards one parking fee of $20 and three filing fees of $60 each, or $200 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 total amount of $1450, within twenty days.

Defendant is ordered to give notice.