Dorothy Caronna v. Déjà Vu Services, Inc.

Dated: August 20, 2026 | | | Brock T. Hammond Judge of the Superior Court |

Judge Brock T. Hammond, Department 407 HEARING DATE: August 20, 2026 TRIAL DATE: Not set CASE: Dorothy Caronna v. Déjà Vu Services, Inc. CASE NO.: 25STLC04848 MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) AND REQUESTS FOR PRODUCTION OF DOCUMENTS (SET ONE) MOVING PARTY: Plaintiff Dorothy Caronna, in pro per RESPONDING PARTY: Defendant Déjà Vu Services, Inc.

I. BACKGROUND On June 23, 2026, Plaintiff, Dorothy Caronna, filed this motion to compel Defendant, Déjà Vu Services, Inc., to provide further responses to Plaintiff's first set of Request for Production of Document Nos. 10 and 11, Special Interrogatory Nos. 7 and 10, and Form Interrogatory No. 4.1. Plaintiff requests sanctions against Defendant and its counsel of record.

On August 7, 2026, Defendant filed an opposition. Defendant requests sanctions against Plaintiff. On August 12, 2026, Plaintiff filed a reply.

II. DISCUSSION Plaintiff's motion is riddled with procedural and substantive defects. First, Plaintiff did not meet and confer in good faith prior to filing this motion. A motion to compel further responses to discovery must be accompanied by a meet and confer declaration.¿ (Code Civ. Proc., Sec.Sec. 2030.300(b)(1), 2031.310(b)(2).)¿" A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion." (Code Civ. Proc., Sec. 2016.040(a).)

Here, Plaintiff sent a meet and confer letter to Defense counsel on Friday, June 20, 2026 demanding further verified responses within 24 hours. (See Caronna Decl., P. 3; Critchlow Decl., P. 5, Ex. E.) On its face, Plaintiff made no real attempt to informally resolve this dispute.

Second, Plaintiff fails to set forth in her separate statement Defendant's entire responses to the at-issue discovery requests, and omits entirely the text of other discovery requests relevant to understanding the issues.

Third, Plaintiff's notice of motion does not indicate that she seeks a further response to Form Interrogatory No. 4.1.

Fourth, Defendant provided Code-compliant responses, including objections, to the at-issue discovery. Plaintiff makes no attempt to explain why or how those objections lack merit.

Fifth, Plaintiff improperly attempts to compel further responses to distinct discovery sets. Plaintiff should have filed separate motions as to each discovery set. ¿ For these reasons, the motion is DENIED.

Monetary Sanctions ¿¿¿ ¿¿¿ ¿¿ Sanctions shall be awarded against any party, person or attorney who unsuccessfully makes or opposes a motion to compel further responses, unless the Court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of sanctions unjust.¿ (Code Civ. Proc., Sec.Sec. 2030.300(d); 2031.310(h).)¿¿ Based on the deficiencies discussed above, the court finds sanctions against Plaintiff are warranted. Accordingly, Defendant's request for sanctions is GRANTED. However, the court orders Plaintiff to pay the reduced sum of $1,200.

III. CONCLUSION The motion is Denied. Plaintiff is ordered to pay sanctions in the sum of $1,200 within 30 days of this order. Defendant is ordered to give notice. Dated: August 20, 2026 | | | | Brock T. Hammond Judge of the Superior Court | |