Motion to Compel Defendant G.J. Farms, Inc. to Provide Responses to Plaintiff’s Special Interrogatories (Set One) and Request for Sanctions
202100561438CUOE: Ibarra vs. Chuy & Sons 06/24/2026 in Department 44 Motion to Compel Defendant GJ Farms Inc to Provide Responses to Plaintiffs Special Interrogatories Set One and Request for Monetary Sanctions of $4085
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Motion: Plaintiff’s Motion to Compel Defendant G.J. Farms, Inc. to Provide Responses to Plaintiff’s Special Interrogatories (Set One) and Request for Sanctions $4,085 (unopposed)
Tentative Ruling:
Plaintiff’s Unopposed Motion to Compel Defendant G.J. Farms, Inc. to Provide Responses to Plaintiff’s Special Interrogatories (Set One) and Request for Sanctions $4,085 is granted.
Defendant did not respond to properly served discovery that seeks information reasonably calculated to lead to the discovery of admissible evidence. (Code Civ. Proc., §§ 2017.010, 2030.260, subd. (a), 2030.290, subd. (a).) Such failure to respond constitutes a misuse of the discovery process. (Code Civ. Proc., § 2023.010
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Counsel’s hourly rate is $1,150 and she alleges she has spent “more than 2.5 hours” on this matter. Although sanctions of $4,085 are sought, the math does not add up: [$1,150 x 2.5=$2,875] + $60=$2,935. Additionally, the Court finds that the hourly rate is unreasonably
202100561438CUOE: Ibarra vs. Chuy & Sons
high based on the Court’s familiarity with reasonable rates approved in the local community. Counsel was admitted to practice in December 2003 and has 22 years’ experience. A reasonable hourly rate for a 22-year lawyer in Ventura County is $700. The Court also finds that one and a half hours is a reasonable amount of time to prepare the documents in a motion to compel initial responses. The motion is unopposed. Consequently, the Court orders Defendant and its counsel of record, William H. Schultz of Schultz Law Firm to pay $1,110 in sanctions, calculated as follows: [$700 x 1.5] + $60 (filing fee).
Defendant shall provide verified responses, without objections, within 20 days. Sanctions shall be paid within 20 days as well.
Counsel for Plaintiff is ordered to give notice of the Court’s ruling.
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