ESTEVEZ VS ALVAREZ

likely to seek. That pattern reflects “a systematic effort to impose arbitration on the weaker party not simply as an alternative to litigation, but to secure a forum that works to the stronger party’s advantage.” (Id. at 516–17.) Severing the provisions would also create an incentive for employers to draft one-sided agreements knowing courts will simply redraft them to include the bilateral terms the employer should have included in the first place. (Id. at 517 [citing Mills v. Facility Solutions Grp., Inc. (2022) 84 Cal.App.5th 1035, 1045].)

Because the unconscionable provisions cannot be cured without augmentation, and because the interests of justice would not be furthered by severance, the Arbitration Agreement is permeated with unconscionability and is therefore void in its entirety.

4. CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION TO COMPEL ANSWERS TO SPECIAL INTERROGATORIES CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION FOR ORDER ESTABLISHING ADMISSIONS CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION FOR ORDER ESTABLISHING ADMISSIONS CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION TO COMPEL ANSWERS TO FORM INTERROGATORIES CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION TO COMPEL RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION TO COMPEL ANSWERS TO FORM INTERROGAOTIRES CASE # CASE NAME HEARING NAME CVRI2503822 ESTEVEZ VS ALVAREZ MOTION TO COMPEL ANSWERS TO SPECIAL INTERROGATORIES Tentative Ruling: Hearing is continued to 6/19/26, for Defendants to provide verifications.

Code of Civil Procedure sections 2030.290(b) and 2031.300(b) allow the propounding party to file a motion to compel responses to interrogatories and document demands if a response has not been received. If responses are untimely, responding party waives objections. (Id. at §§ 2030.290(a), 2031.300(a).)

For requests for admissions, failure to respond permits the propounding party to move for an order deeming the admissions admitted. (Id. at § 2033.280.) The court shall grant the motion “unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response...in substantial compliance with Section 2033.220.” (Id. at § 2033.280(c).) For requests for admission, they are taken in totality of the proposed response, rather than each individual response. (St. Mary v. Superior Court (2014) 223 Cal.App.4th 762, 782.)

Here however, Defendants’ responses are not verified. (Code Civ. Proc. §§ 2030.250, 2031.250, 2033.240.) An unverified response is ineffective as it is the equivalent of providing no response at all. (Appleton v. Superior Court (1988) 206 Cal.App.3d 632, 636 (applying to requests for admissions).) As Defendants have substantially provided their responses, court continues the hearings to allow Defendants to submit their verifications.

5. CASE # CASE NAME HEARING NAME MOTION TO SET ASIDE ON CVRI2301887 RAMIREZ VS WITHEROW COMPLAINT Tentative Ruling: