FELTON VS. AI’S NEW YORK CAFÉ

# Case Name Tentative

1. NAJAFI VS. VINCI 2025-01451991 MOTION TO BE RELIEVED AS COUNSEL

Stacey Joel Safion’s Motion to be Relieved as Counsel for Plaintiff David Najafi is DENIED as moot considering the substitution of attorney filed on 5/21/26 substituting Rebekah Thomas as counsel. (ROA 45.)

2. LOKES VS. LOUIS 2023-01367818 1. MOTION TO COMPEL ANSWERS TO SPECIAL INTERROGATORIES

Defendant Karl George Louis’ motion to compel a response from plaintiff Samanta Lokes’s to Defendant’s Supplemental Interrogatories is DENIED.

The proof of service shows Defendant served the Supplemental Interrogatories and the instant Motion on Plaintiff who is appearing in pro per via email. There is no proof that Plaintiff consented to being served by electronic mail. Without express consent as required by Code of Civil Procedure section 1010.6, subdivision (c), service of the Supplemental Interrogatories and this Motion by electronic mail on Plaintiff was insufficient.

Moving Defendant to give notice.

2. MOTION TO COMPEL PRODUCTION

Defendant Karl George Louis’ motion to compel a response from Plaintiff Samanta Lokes’s to Defendant’s Supplemental Request for Production of Documents and Things is DENIED.

The proof of service shows Defendant served the Supplemental Request for Production of Documents and Things and the instant Motion on Plaintiff who is appearing in pro per via email. There is no proof that Plaintiff consented to being served by electronic mail. Without express consent as required by Code of Civil Procedure section 1010.6, subdivision (c), service of the Supplemental Request for Production of Documents and Things and this Motion by electronic mail on Plaintiff was insufficient.

Moving Defendant to give notice.

3. FELTON VS. AI’S NEW YORK CAFÉ 2024-01423563 1. MOTION TO COMPEL ANSWERS TO SPECIAL INTERROGATORIES Plaintiff Michael Felton’s motion to compel defendant Al’s New York CafØ to serve further responses to Special Interrogatories, Set One, Interrogatory Nos. 2, 9, 10, 12, 13, 14, 15, 16, 17, 18, 28, and 35 is GRANTED.

Special Interrogatory Nos. 2, 9, 10 and 16:

Code of Civil Procedure section 2030.220, subdivision (a), requires that answers be “as complete and straightforward as the information reasonably available to the responding party permits.”

Defendant’s response to these interrogatories failed to provide all requested information. Specifically, Interrogatory No. 2 asked for job positions and the dates Plaintiff worked in each; Defendant responded with job titles only, omitting all dates. Similarly, interrogatory Nos. 9, 10, and 16 each required Defendant to identify specific persons by providing, in addition to their names and job titles, complete contact information and dates of employment with Defendant. Defendant responded to each of these interro gatories by stating “Ali Amirghahari, President” but failed to provide the contact information and dates of employment with Defendant.

Therefore, the request to compel a further response to Special Interrogatory Nos. 2, 9, 10 and 16 is GRANTED.

Special Interrogatory Nos. 13, 14, 15, 17 and 18:

Defendant’s response to these interrogatories failed to provide all requested information. In response to each of these interrogatories which asks Defendant to state, identify, or describe facts, reasons, policies, or witness knowledge related to Plaintiff ’s termination, Defendant provided an identical boilerplate answer reciting a single fact that when Plaintiff took a vacation in July 2022 and Al filled in as cashier, the cash receipts were higher than when Plaintiff was cashier. Each of the responses also states discovery is continuing. The responses are not complete since they fail to provide all requested information,

Therefore, the request to compel a further response to Special Interrogatory Nos. 13, 14, 15, 17 and 18 is GRANTED.

Special Interrogatory Nos. 12 and 28:

Defendant objected to Interrogatory Nos. 12 and 28 on the grounds that they violate Code of Civil Procedure section 2030.060 as compound, conjunctive, or containing subparts. Although both interrogatories contain subparts, they are logically connected to a single injury and thus permissible. Further, responses were not timely served, as such, Plaintiff waived objections. (Cojocnean Decl., ¶ 4; Exhibit B.)

Therefore, the request to compel a further response to Special Interrogatory Nos. 12 and 28 is GRANTED.

Special Interrogatory No. 35:

Defendant’s response labels the answer to Interrogatory No. 35 as “RESPONSE TO SPECIAL INTERROGATORY NO. 19.” As such, it is unclear whether the response is to interrogatory No. 35 or 19.

Therefore, the request to compel a further response to Special Interrogatory No. 35 is GRANTED.

Defendant is ORDERED to provide a further response to Interrogatory Nos. 2, 9, 10, 12, 13, 14, 15, 16, 17, 18, 28, and 35 within 20 days of notice of this ruling.

Plaintiff’s request for sanctions is granted in the amount of $1,200.00, reflecting three hours of counsel’s time at $400/hour, payable within 30 days.

Plaintiff to give notice.

2. MOTION TO COMPEL RESPONSE TO REQUESTS FOR ADMISSIONS Plaintiff Michael Felton’s motion to compel defendant Al’s New York CafØ to serve further responses to Requests for Admission, Set One, Request Nos. 4, 5, 6, 7, and 8 is GRANTED.

Defendant objected to each of the Requests at issue in this Motion. However, Defendant failed to serve timely responses and therefore waived all objections. Specifically, Defendant’s responses were due on or before August 14, 2025. (Cojocnean Decl., ¶ 2.) On August 14, 2025, defense counsel requested a one-week extension which Plaintiff granted, extending the deadline to August 22, 2025. (Cojocnean Decl., ¶ 3; Exhibit A.) On August 22, 2025, the date responses were due, Defendant’s counsel unilaterally re quested a further extension to August 25, 2025, without Plaintiff’s prior agreement. (Cojocnean Decl., ¶ 3.) Defendant served responses on August 25, 2025 —three days after the agreed deadline. (Cojocnean Decl., ¶ 4; Exhibit B.) Therefore, the responses were not timely served and Defendant waived all objections. (Code Civ. Proc., § 2033.280, subd. (a).)

Defendant is ORDERED to provide a further response, without objections, to Request Nos. 4, 5, 6, 7, and 8 within 20 days of notice of this ruling.

Plaintiff’s request for sanctions is granted in the amount of $1,200.00, reflecting three hours of counsel’s time at $400/hour, payable within 30 days.

Plaintiff to give notice.