Case Number: BC717190 Hearing Date: January 07, 2019 Dept: 3

BLANCA ROSALES,

Plaintiff(s),

vs.

BRENDA MARGARITA ALANIS, ET AL.,

Defendant(s).

Case No.: BC717190

[TENTATIVE] ORDER GRANTING UNOPPOSED MOTIONS TO COMPEL

Dept. 3

1:30 p.m.

January 7, 2019

Defendant propounded form interrogatories, special interrogatories, and RPDs on Plaintiff on 9/14/18. 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 15 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 $760/motion. Defense Counsel bills at the rate of $175/hour. The Court awards one hour to prepare each form discovery motion. 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 $175/hour, for a total of $875 in attorneys’ fees. The Court also awards three filing fees of $60 each, or $180 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, Jonathan M. Kashani, in the total amount of $1055, within twenty days.

Defendant is ordered to give notice.