Plaintiff’s Motion to Compel Further Discovery Responses
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Gayle Roderick v. Carmel Beauty Boutique, et al.
Plaintiff’s Motion to Compel Further Discovery Responses
Hearing Date: May 29, 2026 (continued from May 15, 2026)
PARTIES TO APPEAR. On May 15, 2026, the originally scheduled hearing date for this motion, Defendant Hanan Dahan (“Defendant”) appeared and contested the monetary sanctions part of the Tentative Ruling. Since counsel for Plaintiff Gayle Roderick (“Plaintiff”) was not present, the Court continued the matter to May 29, 2026. The Tentative Ruling below remains the same as the one posted on May 14, 2026.
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The remaining issues raised in Plaintiff’s motion concern whether an order should be issued to (1) compel Defendant to provide further responses to Form Interrogatory, Set One, Nos. 2.2, 2.5-2.7, and 50.1-50.6, and (2) grant her monetary sanctions for Defendant’s misuse of the discovery process. [Plaintiff’s Reply at 1:22-2:5.] As explained below, Plaintiff’s motion is GRANTED IN PART, regarding Nos. 2.2, 2.5, 2.6, and 2.7, and DENIED IN PART, concerning Nos. 50.1 through 50.6. Plaintiff’s request for monetary sanctions is GRANTED, but not for the full amount she requested. Defendant’s request for monetary sanctions is DENIED.
Background.
In her Complaint filed on September 26, 2022, Plaintiff alleges that she was the victim of overly aggressive and illegal sales tactics by representatives of Carmel Beauty Boutique (“Boutique”). Plaintiff claims that Defendant was the Boutique’s owner when the incident occurred on September 27, 2020.
To discover facts related to Defendant’s background and transactions between Plaintiff and the Boutique, Plaintiff served her first set of Form Interrogatories on March 31, 2025. On May 2, 2025, Defendant served objections-only responses to Form Interrogatory Nos. 2.2, 2.5- 2.7, and 50.1-50.6. Following meet-and-confer efforts and extensions, Defendant provided additional responses on April 21, 2026. Plaintiff argues these responses are inadequate and now seeks to compel more complete answers.
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Discussion.
1. Legal Standard.
“Unless otherwise limited by order of the court ... any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved ... if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” [
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A party serving interrogatories may file a motion for an order compelling further responses if that party believes an answer is, among other things, evasive or incomplete, or an objection lacks merit or is too broad. [Code Civ. Proc. § 2030.300, subd. (a).] If a timely motion to compel is filed, the responding party has the burden to justify any objection or failure to answer the interrogatories fully. [Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.]
In assessing the motion, a court should generally consider the following factors: (1) the relationship of the information sought to the issues framed in the pleadings; (2) the likelihood that disclosure will be of practical benefit to the party seeking discovery; and (3) the burden or expense likely to be encountered by the responding party in furnishing the information sought. [Columbia Broadcast System, Inc. v. Superior Court (1968) 263 Cal.App.2d 12, 19.]
Evasive discovery responses and objections lacking adequate justification are considered “misuses of the discovery process.” [Code Civ. Proc. § 2023.010, subds. (e)-(f).] The Court “shall” require the party receiving discovery to pay the propounding party’s reasonable expenses, such as attorney fees, for enforcing discovery unless it finds that the sanctioned party acted with “substantial justification” or that other circumstances make the sanction unjust. [Code Civ. Proc. § 2030.300, subd. (d).] “Our courts have interpreted the term ‘substantial justification’ to mean ‘well-grounded in both law and fact.’ Thus, to avoid sanctions, the deponent must show there were reasonable grounds to believe an objection was valid or that the answer given was adequate.” [City of Los Angeles v. Superior Court (2017) 9 Cal.App.5th 272, 291 (internal citations, bracketed text, and ellipsis omitted).]
2. Form Interrogatories.
Plaintiff’s motion is GRANTED, and Defendant shall fully respond to Nos. 2.2, 2.5, 2.6, and 2.7. Although they provided their date of birth in response to No. 2.2, Defendant did not specify their “place of birth.” Defendant’s relevance objection to Nos. 2.5, 2.6, and 2.7 is not well taken because the requested background information is relevant and necessary for a legitimate background investigation of Defendant in connection with this litigation. [Code Civ. Proc. § 2017.010.] Defendant’s remaining objections are equally unsupported because the atissue interrogatories are standard ones authored by the Judicial Council. They are not facially vague, nonsensical, or ambiguous.
The motion is DENIED as to Nos. 50.1 through 50.6. These interrogatories ask whether: (1) any alleged breach of the agreement in the Complaint occurred; (2) performance was
justified; and (3) any agreement was terminated, ambiguous, or unenforceable. However, Plaintiff in her Complaint does not claim that the items purchased from the Boutique were not delivered or that the transaction involved a breach of contract. Instead, her lawsuit focuses on fraud claims related to a retail sale, making these interrogatories less appropriate for this case.
3. Sanctions.
Defendant requests $10,125 in sanctions for opposing the motion and criticizes Plaintiff for not limiting the scope of the motion before Defendant filed their opposition. Plaintiff’s May 1, 2026, letter did inform Defendant of the remaining issues in the motion. However, the Court will not impose sanctions on Plaintiff, who had the right to seek additional responses to her Form Interrogatories. Therefore, the Court DENIES Defendant’s sanctions request.
On the other hand, Plaintiff’s request for sanctions is GRANTED IN PART. Monetary sanctions are appropriate, and Defendant lacked substantial justification for a different order. When the motion was filed, Plaintiff had a valid reason to seek further responses from Defendant because of their objections-only responses. Although the parties worked together to resolve most issues, the motion still persisted to some degree and was only partly successful. Since the motion, extensions, continuances, and cooperation left only a few issues for the Court to decide, and were only partly successful, the Court will award sanctions, but not the full amount requested by Plaintiff.
Instead, the Court will order monetary sanctions of $2,060 to Plaintiff and against Defendant and their attorney, jointly and severally. This covers five hours of Plaintiff’s counsel’s work at an hourly rate of $400, plus the $60 filing fee.
Conclusion.
As detailed above, Plaintiff’s motion to compel is GRANTED IN PART, and Defendant has 10 days from the date of service of the Court’s order to serve verified further responses to Form Interrogatory Nos. 2.2, 2.5, 2.6, and 2.7. Otherwise, the motion is DENIED IN PART, and Defendant need not further respond to Form Interrogatory Nos. 50.1 through 50.6.
Plaintiff’s request for monetary sanctions is GRANTED IN PART. Monetary sanctions of $2,060 are awarded to Plaintiff and against Defendant and their attorney of record, jointly and severally, payable within 30 days from the date of service of the Court’s order. Defendant’s sanctions request is DENIED.
Plaintiff shall prepare the Proposed Order consistent with this Tentative Ruling.
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