Blood vs. Huntington Beach Hospital

research[ing] the applicable law, and prepar[ing] this opposition.” (Mussen Dec., ¶ 7.) Mussen requests the maximum penalty of $1,000.

Mussen is a self-represented litigant. The only fees or costs Mussen may have incurred in connection with this motion was perhaps a fee for electronic filing, though Mussen does not provide any evidence of such a fee. Sanctions do not appear warranted at this juncture. Thus, the Court will not order Adjemian’s counsel to pay any sanctions.

Adjemian shall file the Answer to the Cross-Complaint attached to the motion within 7 days of this ruling.

Adjemian shall give notice of this ruling. 5 Blood vs. Huntington Beach Hospital’s Motion to Compel Further Responses to Form Huntington Beach Interrogatories (Set One) No. 17.1 is GRANTED. Hospital Plaintiff Heather Jeane Blood is ordered to serve a further, verified, code- compliant response, without objections, to Form Interrogatory no. 17.1, as it relates to Requests for Admission nos. 2, 3, 4, 7, 9, 10, 12, 13-41, 44, 46, and 47-73, within 20 days of the notice of ruling.

Defendant’s request for monetary sanctions is GRANTED.

Legal Standard

A response to interrogatories is due within 30 days after service. (Code Civ. Proc., §§ 2030.260, subd. (a), 1010.6, subd. (a)(3)(B).) A party who fails to serve a timely response “waives any right to exercise the option to produce writings under Section 2030.230, as well as any objection to the interrogatories, including one based on privilege or on the protection for work product.” (Code Civ. Proc., § 2030.290, subd. (a); Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.)

Each answer must be as complete and straightforward as the information reasonably available to the responding party permits. (Code Civ. Proc., § 2030.220, subd. (a).) “Where the question is specific and explicit, an answer which supplies only a portion of the information sought is wholly insufficient. Likewise, a party may not provide deftly worded conclusionary answers designed to evade a series of explicit questions. [Citation.]” (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783.)

Upon receipt of the responses, the propounding party may move for an order compelling further responses if it deems an answer to be evasive or incomplete, or an objection to be without merit or too general. (Code Civ. Proc., § 2030.300, subd. (a).) The motion must be accompanied by a meet and confer declaration and a separate statement, and notice of the motion generally must be given within 45 days of the service of the verified response. (Code Civ. Proc., § 2030.300, subds. (b)(1), (c); Cal. Rules of Court, rule 3.1345(a)(2).)

Defendant served its Form Interrogatories, Set One, on Plaintiff by electronic service on February 20, 2026, making Plaintiff’s responses due March 24, 2026. (Code Civ. Proc., §§ 2030.260, subd. (a), 1010.6, subd. (a)(3)(B).) At Plaintiff’s request, the parties agreed in writing to extend her deadline to 5:00 p.m. on March 27, 2026. (Code Civ. Proc., § 2030.270.) That agreed date was not further extended by section 1010.6, which applies only to a time period or date prescribed by statute or rule of court. (Code Civ.

Proc., § 1010.6, subd. (a)(3)(B).) Plaintiff did not serve her verified responses until March 30, 2026. The responses were untimely, and, accordingly, Plaintiff has waived her objections to the interrogatories, including the “General Objections” asserted in her responses, as well as any right to respond by reference to documents under section 2030.230. (Code Civ. Proc., § 2030.290, subd. (a).) Plaintiff has not sought relief from the waiver.

Defendant has satisfied the requirements for bringing its Motion. The Motion was filed within 45 days of the service of the verified responses, and it is accompanied by a separate statement and by a meet and confer declaration describing defense counsel’s April 3, 2026 letter, which requested codecompliant supplemental responses by April 17, 2026, and counsel’s May 6, 2026 reminder to Plaintiff, at her deposition, of her obligation to respond. (Code Civ. Proc., § 2030.300, subds. (b)(1), (c); Cal. Rules of Court, rule 3.1345(a)(2).) Plaintiff never supplemented her responses. The request for sanctions is properly made in the notice of motion. (Code Civ. Proc., § 2023.040.)

The Court further finds Plaintiff’s response to Form Interrogatory no. 17.1 is evasive and incomplete. The interrogatory required Plaintiff, for each response to Defendant’s Requests for Admission that was not an unqualified admission, to state the number of the request, state all supporting facts, identify all persons with knowledge of those facts, and identify all supporting documents and the person who has each. Plaintiff asserted no objection to the interrogatory, and her answer does none of these things: it does not identify a single request by number; it states no facts, instead incorporating her responses to the requests for admission by reference; it identifies no witnesses; and it refers generally to three categories of documents without identifying who has them.

Monetary sanctions against the party who unsuccessfully makes or opposes the motion are mandatory, unless the Court finds that party acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. Proc., § 2030.300, subd. (d).) Sanctions may be awarded even though no opposition to the motion was filed. (Cal. Rules of Court, rule 3.1348(a).)

Because the Court grants the Motion, and because Plaintiff has not shown substantial justification for her position or that a sanction would otherwise be unjust, monetary sanctions are mandatory. (Code Civ. Proc., § 2030.300, subd. (d).) Plaintiff served untimely and evasive responses, did not respond to Defendant’s April 3, 2026 meet-and-confer letter, and did not supplement 6

her responses after being reminded of her obligations at her May 6, 2026 deposition. Her self-represented status does not exempt her from compliance with the Civil Discovery Act. (Rappleyea v. Campbell (1994) 8 Cal.4th 975, 984-985.) Plaintiff was served with Defendant’s notice of motion on May 8, 2026, which expressly stated that Defendant seeks $500 in monetary sanctions against her (Code Civ. Proc., § 2023.040), and she never opposed the request. The $500 requested is reasonable relative to the expenses Defendant incurred in preparing and bringing the Motion. (Bocker Decl., ¶ 19.)

Moving party to give notice by mail. 6 Dodson Motion to Seal vs. Lacilento Defendant Arthur J. LaCilento’s unopposed motion to seal certain excerpts from the Memorandum of Points and Authorities in Support of Defendant LaCilento’s Demurrer is GRANTED.

Under current law, certain court records are presumptively confidential, including paternity case files in actions filed before January 1, 2023. (See Family Code, § 7643, subd. (a).) Family Code section 7643, subdivision (a) provides, in pertinent part: “ all papers and records, other than the final judgment, pertaining to the action or proceeding, whether part of the permanent record of the court or of a file in a public agency or elsewhere, are subject to inspection and copying only in exceptional cases upon an order of the court for good cause shown.”

Here, the action underlying this legal malpractice case (“Underlying Action”) commenced in 2015. (Notice of Lodging, Exh. 1). As a designated paternity case, the record in the Underlying Action is confidential. The motion to seal the portions in the Memorandum of Points and Authorities in Support of Defendant referring to this record is granted.

Defendant LaCilento to give notice.

Demurrer to First Amended Complaint

Defendant Arthur J. LaCilento’s demurrer to the first through six causes of action asserted in Plaintiff Nicole Dodson’s First Amended Complaint (“FAC”) is SUSTAINED. LaCilento’s unopposed request for judicial notice is granted.

In ruling on a demurrer, a court must accept as true all allegations of fact contained in the complaint. Blank v. Kirwan, 39 Cal.3d 311, 318 (1985). A demurrer challenges only the legal sufficiency of the affected pleading, not the truth of the factual allegations in the pleading or the pleader’s ability to prove those allegations. (Cundiff v. GTE Cal., Inc. (2002) 101 Cal.App.4th 1395, 1404-05.)

As an initial matter, Plaintiff concedes that her first cause of action for beach of the covenant of good faith and fair dealing and her sixth cause of 7