Network Experts, Inc., v. Beverly Hills IT Services, et al.

CASE NO.: 23SMCV00517 MOTION: Motion to Compel Initial Discovery Responses (Post-Judgment) HEARING DATE: 8/20/2026

Legal Standard Code of Civil Procedure ("CCP") section 708 et seq. permits discovery aiding in the enforcement of a money judgment. CCP section 708.030 states in relevant part: (a) The judgment creditor may demand that any judgment debtor produce and permit the party making the demand, or someone acting on that party's behalf, to inspect and to copy a document that is in the possession, custody, or control of the party on whom the demand is made in the manner provided in Chapter 14 (commencing with Section 2031.010) of Title 4 of Part 4, if the demand requests information to aid in enforcement of the money judgment.

The judgment debtor shall respond and comply with the demand in the manner and within the time provided by Chapter 14 (commencing with Section 2031.010) of Title 4 of Part 4. [...] (c) Inspection demands served pursuant to this section may be enforced to the extent practicable, in the same manner as inspection demands in a civil action.

Where there has been no timely response to a CCP section 2031.010 inspection demand, the demanding party must seek an order compelling a response. (CCP Sec. 2031.300.) Failure to timely respond waives all objections, including privilege and work product. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. There is no deadline for a motion to compel responses. Likewise, for failure to respond, the moving party need not attempt to resolve the matter outside court before filing the motion. Where the motion seeks only a response to the inspection demand, no showing of "good cause" is required.

ANALYSIS Plaintiff/Judgment Creditor Network Experts Inc. ("JC") moves to compel Defendant/Judgment Debtor Beverly Hills IT ("JD") to serve verified responses, without objection, to JC's Requests for Production of Documents in Aid of Execution, Set One; (2) compelling JD to produce all documents responsive to the Requests; and (3) imposing monetary sanctions against JD in the amount of $2,370.00.

JC served JD, via counsel, with the subject RPDs on April 3, 2026. (Kandel Decl., P. 3, Ex. A.) The documents seek identification of Defendant's assets, income, bank and investment accounts, real and personal property, debts, transfers, and related financial information, in order to aid in JC's collection of its money judgment against JD.

JD has served no response to the Requests. (Id., P.P. 6-7, 10.) JD's counsel acknowledged that responses were due and requested additional time to respond. (Id., P. 8.) Mr. Ceja subsequently advised that he no longer represented JD and directed JC's counsel to communicate with JD's principal directly. (Id. P.9) JC counsel contacted JD's principal by email to discuss a proposed extension but JD's principal did not respond. (Id.)

Accordingly, the motion is GRANTED. JD is ordered to provide initial responses, without objection, to the subject RPDs within 10 days. Mandatory monetary sanctions are imposed in the reduced total amount of $1,447.50 against JD. Sanctions are payable to JC's counsel of record without 30 days.

Case Number: 24SMCV03001 Hearing Date: August 20, 2026 Dept: M CASE NAME: Newton, et al., v. Spillman