LVNV FUNDING LLC vs MERRITT, REBECCA

compilation, abstract, audit, or summary presently exists and (3) the burden or expense of preparing or making a compilation, abstract, audit, or summary would be substantially the same for the propounding party as for the responding party. Civ. Proc. Code Sec.2030.230.

In addition, the sufficiency-of-detail requirement effectively demands a level of specificity that enables the propounding party to locate the responsive information without undue burden. Thus, a reference to a large volume of documents is inadequate and subject to challenge. Fuss v. Superior Ct. for Los Angeles Cnty.(1969) 273 Cal. App. 2d. 807, 816.

An objection based upon burden must be sustained by evidence showing the quantum of work required. Williams v. Superior Court (2017) 3 Cal. 5th 531, 549; West Pico Furniture Co. of Los Angeles v. Superior Court In and For Los Angeles County (1961) 56 Cal. 2d 407, 417. This means the responding party must come forward with specific, factual information demonstrating the actual scope and magnitude of the effort that compliance would entail.

A responding party may not unilaterally impose temporal limitations on a propounding party's discovery. That is the preserve of the court. Civ. Proc. Code Sec. 2017.010.

Based on the foregoing, the court finds that Defendant's responses to Plaintiff's Special Interrogatories are deficient, inadequate, and not code compliant. Accordingly, Defendant shall provide code compliant, objection free, verified responses to Defendants Special Interrogatories Set Two, Numbers 111,114 -117, 119, 123-128, 130 and 132 by no later than 4:00 p.m. on Monday, August 3, 2026. Given Defendant's complete reversal of its prior discovery responses, any responses that state that Defendant lacks sufficient information to respond shall detail Defendant's diligent good faith efforts in that regard. Civ. Proc. Code Sec.Sec. 2030.220; 2030.200; Deyo v Kilbourne, supra. Plaintiff shall submit a proposed order that conforms to this ruling no later than July 24, 2026.

CV-24-007631 - LVNV FUNDING LLC vs MERRITT, REBECCA - Plaintiff's Motion for Order that Matters in Request for Admissions be Deemed Admitted Pursuant to CCP 2033.280 - GRANTED, and unopposed. The Court finds that Defendant has failed to timely respond to the Requests for Admissions, Set One, served on her on December 2, 2025, or at all, without substantial justification. Plaintiff's motion is accordingly granted. Accordingly, all objections to said Requests for Admissions by Defendant are hereby waived. Code of Civil Procedure Sec.2033.280(a). Furthermore, said Request for Admissions, Set One, are hereby deemed admitted in this matter for all purposes including trial. Civ. Proc. Code Sec.Sec. 2033.250(a), 2033.280 and 2033.410;