Anne Cho v. City of Alhambra

Plaintiffs must file a single Request for Court Judgment on CIV-100 and a single proposed judgment on JUD-100 specifying how much each Plaintiff is to recover.

The hearing is continued to __________ at 8:30 a.m. in Department 3 of the Alhambra Courthouse. Forms CIV-100 and JUD-100 must be filed no later than 5 court days before the date of the hearing.

Dated this 14th day of August 2026 | | | William A. Crowfoot Judge of the Superior Court |

OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT ANNE CHO, Plaintiff(s), vs. CITY OF ALHAMBRA, Defendant(s). |))))))))))) | CASE NO.: 25NNCV03013 [TENTATIVE] ORDER RE: MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES

Dept. 3 8:30 a.m. August 14, 2026 | |) | | Defendant City of Alhambra ("Defendant") moves for an order compelling further responses from plaintiff Anne Cho ("Plaintiff") to Special Interrogatories Nos. 19, 20, 21, and 22, which ask Plaintiff to identify the total number and date of motor vehicle accidents and slip and fall accidents since January 14, 2014.

Plaintiff opposes the motion on the grounds that verified, code-compliant responses have already been served and that Defendant's interrogatories request discovery of "non-injury incidents that are remote in time, and have no relevancy to the issues in this lawsuit, violate [sic] Plaintiff's constitutional right to privacy." (Opp., p. 1.)

Defendant takes issue with Plaintiff's responses because she states that she has not been injured in any accidents, which avoids the call of the question. Defendant also claims that Plaintiff cannot argue that the terms "motor vehicle accident" or "slip and fall accident" are vague because Plaintiff did not raise that issue when the parties met and conferred.

Plaintiff argues that a further response is unnecessary because accidents which produced no injuries are irrelevant. However, whether or not an accident produced an injury is something Defendant is entitled to question in order to determine whether those injuries impacted Plaintiff's current medical condition, especially when two of the motor vehicle accidents took place after the slip-and-fall incident underlying this action.

Accordingly, the motion is GRANTED and Plaintiff is ordered to serve further responses to Special Interrogatories - Set One, Nos. 19-22 within 20 days of the date of this order.

Plaintiff and counsel of record are sanctioned, jointly and severally, in the reduced amount of $1,380, consisting of 4.6 hours at defense counsel's hourly rate of $300, payable within 20 days of the date of this order. Although defense counsel's declaration states that he anticipated spending 2.5 hours reviewing the opposition brief, preparing the reply brief, and preparing for and appearing at the hearing, there is no supplemental declaration submitted with the reply brief stating how much time was actually incurred in doing so. Therefore, the Court only awards the time spent on meeting and conferring and preparing the instant motion.