Motion to Compel Answers to Form Interrogatories; Motion to Compel Answers to Special Interrogatories; Motion to Compel Production; Motion to Deem Facts Admitted
The matters in the first set of requests for admissions are deemed unless defendant serves a verification to the previously served response at or before the hearing
A total monetary sanction of $2340 is imposed against defendant and his attorney of record, payable to plaintiff and her attorney of record within 30 days. 9 24-01445830 1) Motion to Compel Answers to Form Interrogatories 2) Motion to Compel Answers to Special Interrogatories Gharibian vs. 3) Motion to Compel Production Volkswagen Group of 4) Motion to Deem Facts Admitted America, Inc.
Motion No. 1 - Motion to Compel Responses to Form Interrogatories, Set One
Plaintiff Levon Joseph Gharibian’s Motion Compel Responses to Form Interrogatories, Set One as to Defendant Volkswagen Group of America, Inc. is CONTINUED to 12/17/26 at 10:00 a.m. in Department C33 to be heard together with Defendant’s Motion for Relief from Waiver of Objections.
The Court notes Defendant appears to have inadvertently filed two Oppositions to the Motion to Compel Responses to Special Interrogatories, Set One, rather than a separate Opposition to the Motion to Compel Responses to Form Interrogatories, Set One. (ROA 73 and 75.)
The Court ORDERS Defendant to file a corrected Opposition per code prior to the continued hearing date.
Motion No. 2 - Motion to Compel Responses to Special Interrogatories, Set One
Plaintiff Levon Joseph Gharibian’s Motion Compel Responses to Special Interrogatories, Set One as to Defendant Volkswagen Group of America, Inc. is CONTINUED to 12/17/26 at 10:00 a.m. in Department C33 to be heard together with Defendant’s Motion for Relief from Waiver of Objections.
Motion No. 3 - Motion to Compel Responses to Requests for Production, Set One
Plaintiff Levon Joseph Gharibian’s Motion Compel Responses to Requests for Production, Set One as to Defendant Volkswagen Group of America, Inc. is CONTINUED to 12/17/26 at 10:00 a.m. in Department C33 to be heard together with Defendant’s Motion for Relief from Waiver of Objections.
Motion No. 4 - Motion for an Order Deeming Truth of Matter in Requests for Admission, Set One, Admitted
Plaintiff Levon Joseph Gharibian’s Motion for an Order Deeming Truth of Matter in Requests for Admission, Set One, Admitted, as to Defendant Volkswagen Group of America, Inc. is CONTINUED to 12/17/26 at 10:00 a.m. in Department C33 to be heard together with Defendant’s Motion for Relief from Waiver of Objections. 10 24-01437581 Motion to Quash Subpoena
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Guzman vs. Gordon Plaintiff Itzel Britani Ortiz Guzman’s Motion to Quash Subpoenas for Business Records (ROA 39) is GRANTED.
Plaintiff seeks to quash Defendants’ subpoenas to the following third parties:
1. Anaheim Global Medical Center (Medical) 2. Patrick A. Black, D.C. (Medical, Billing & X-rays) 3. Kenneth R. Grabow, M.D. (Medical, Billing & X-rays) 4. Open Advantage MRI (Medical, Billing & X-rays) 5. Pegasus Surgery Center (Medical, Billing & X-rays) 6. Interinsurance Exchange of the Automobile Club (Insurance) 7. Anaheim Global Medical Center (Billing) 8. Anaheim Global Medical Center (X-ray)
Plaintiff also seeks sanctions of $3,435.00.
Upon a motion reasonably made by a party, the court may quash, modify or direct compliance with a subpoena for production of documents. The court “may make any other order as may be appropriate to protect the person from unreasonable or oppressive demands, including unreasonable violations of the right of privacy of the person.” (Code Civ. Proc. § 1987.1(a) & (b).)
Plaintiff asserts the foregoing subpoenas, issued in October 2025, are overbroad in that they broadly seek Plaintiff’s medical records for ten years prior to the date of the subject collision on 12/12/22. Plaintiff’s counsel served objections and sent a meet and confer letter to Defendant’s counsel on 11/18/25. Defendants’ counsel had not responded to the letter as of 11/25/25.
Defendants have not filed a timely opposition to the motion, which was served on 11/25/25.
The motion is granted. The Court finds the subpoenas broadly seeking medical records from 10 years prior to the date of the collision is overbroad. Defendants’ counsel is ordered to meet and confer with Plaintiff’s counsel before service of any amended subpoena to these providers.