1. MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES; 2. MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION
# Case Name Tentative
1. TORKZADEH VS. ACCRDIA LIFE AND ANNUITY COMPANY 2025-01522348 MOTION TO APPEAR PRO HAC VICE
The application of attorney Matthew D. Kelly to appear pro hac vice as counsel for defendants Acrisure, LLC, Acrisure of California, LLC, and Nickola Vucurevic in this matter is hereby GRANTED pursuant to California Rules of Court, rule 9.40.
2. HERNANDEZ VS. AMERICAN HONDA MOTOR CO. INC 2025-01462311 MOTION TO COMPEL DEPOSITION (ORAL OR WRITTEN)
The Motion to Compel Deposition of Defendant’s Person Most Qualified and Custodian of Records by Plaintiffs Jose Garcia Hernandez and Laurie Espinoza is GRANTED.
Plaintiffs seek to compel Defendant to produce a witness pursuant to their deposition notice served on 7/16/25. Plaintiffs’ counsel declares they sent multiple emails but as of 2/2/26 Defendant’s counsel had not provided a deposition date.
Defendant is ordered to produce a witness within 30 days of this order. Any dispute regarding the specific production requests and categories of testimony may be resolved via a motion to compel further responses if necessary after diligent attempts to meet and confer.
Plaintiffs’ request for sanctions is granted in the amount of $2,265.00.
3. AMPCO CONTRACTING, INC. VS. MONZON & SON ENTERPRISES, INC. 2024-01381486 1. MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES
Plaintiff Ampco Contracting, Inc.’s unopposed Motion to Compel Responses to Form Interrogatories (Set One) and Request for Sanctions is DENIED, in part, and GRANTED, in part.
Plaintiff moves for an order compelling Defendant Rafael Solorio Jr. to serve responses to Plaintiff’s Form Interrogatories – General (Set One); and for an award of monetary sanctions against Defendant and Defendant’s counsel.
After the motion was filed, Plaintiff’s counsel filed a supplemental declaration on 7/7/26, indicating Defendant served verified responses on 6/2/26. Thus, the motion is moot as to the responses. Plaintiff’s counsel contends the tardy responses are “noncomplaint,” has attached the responses to the supplemental declaration and asks the Court to grant the motion and order Defendant to serve compliant responses. This request is improper. Plaintiff has not met and conferred with Defendant about the responses’ purported deficiencies and has not served Defendant with
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a motion to compel further responses accompanied by the required separate statement and meet and confer declaration.
Nevertheless, Plaintiff is entitled to sanctions concerning the instant motion. Plaintiff seeks an award of $1,141, which represents 2.4 hours at a rate of $450/hour, plus $60 filing fee. The Court finds the time spent preparing the motion and the hourly rate are reasonable. Thus, the request for sanctions in the amount of $1,141 is granted. Plaintiff’s supplemental request for sanctions in the amount of $450 for the hour counsel spent reviewing the tardy responses is denied. Those costs should be sought in connection with a motion to compel further responses.
Based on the foregoing, the motion is DENIED as moot, in part, regarding the responses and GRANTED, in part, regarding sanctions.
Defendant is ordered to pay Plaintiff sanctions in the amount of $1,141 within 10 days.
Plaintiff to give notice.
2. MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION
Plaintiff Ampco Contracting, Inc.’s unopposed Motion to Compel Responses to Request for Production of Documents (Set One) and Request for Sanctions is DENIED, in part, and GRANTED, in part.
Plaintiff moves for an order compelling Defendant Rafael Solorio Jr. to serve responses to Plaintiff’s Request for Production of Documents (Set One); and for an award of monetary sanctions against Defendant and Defendant’s counsel.
After the motion was filed, Plaintiff’s counsel filed a supplemental declaration on 7/7/26, indicating Defendant served unverified responses on 6/2/26, and the verification on 7/6/26. Thus, the motion is moot as to the responses. Plaintiff’s counsel contends the tardy responses are “non-complaint,” has attached the responses to the supplemental declaration and asks the Court to grant the motion and order Defendant to serve compliant responses. This request is improper for the reasons mentioned in the Court’s ruling concerning the interrogatory responses.
Nevertheless, Plaintiff is entitled to sanctions concerning the instant motion. Plaintiff seeks an award of $330, which represents 0.6 hours at a rate of $450/hour, plus $60 filing fee. The Court finds the time spent preparing the motion and the hourly rate are reasonable.
Based on the foregoing, the motion is DENIED as moot, in part, regarding the responses and GRANTED, in part, regarding sanctions.
Defendant is ordered to pay Plaintiff sanctions in the amount of $330 within 10 days.
To the extent Defendant has not served responsive documents, Defendant is ordered to do so within 10 days.
Plaintiff to give notice.
4. LAW OFFICES OF MARK B. PLUMMER, PC VS. NETWORKSOLUTIONS.COM 2020-01141868 1. Motion to Compel Further Responses to Requests for Admissions, Set One (ROA 711) 2. Motion to Compel Further Responses to Special Interrogatories, Set One (ROA 727) 3. Motion to Compel Further Responses to Form Interrogatories, Set One (ROA 732) 4. Motion to Compel Further Responses to Requests for Production, Set One (ROA 752)
The motions are CONTINUED to 9/1/26.
These motions involve written discovery served to Plaintiffs on 2/15/21 by Defendant’s former counsel, Ms. Juarez.
On 11/12/25, the Court granted Defendant’s motion to compel Plaintiffs to serve responses to the written discovery. The Court ordered Plaintiffs to serve verified responses within 30 days of the order. The order stated, “The Court declines to award sanctions to either side because both sides could have easily avoided this dispute by making a reasonable compromise rather than incurring attorney fees. The parties should engage in discovery cooperatively. The Court will not tolerate gamesmanship or delay tactics.” The order further stated, “In future, if any party files or opposes discovery motions on grounds that could have been resolved by diligent efforts to meet and confer, that party and their counsel will be subject to sanctions.”
In these motions, Defendant contends Plaintiffs’ Court-ordered responses were deficient.
Code of Civil Procedure section 2016.040(a), amended effective 1/1/26, provides, “A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion.”
On 2/2/26, Defendant’s counsel filed this motion after sending meet and confer emails on 1/27/26. Defendant’s counsel also requested an extension to file the present motions in order to arrange a telephonic conference regarding the dispute. (Lopez Decl., ¶ 3.) Mr. Plummer told the legal assistant at defense counsel’s office they had sent “50 pages of garbage” and declined to extend the motion deadline. (Lopez Decl., ¶ 4.)