William Chun v. Pacific Asian Consortium in Employment

(Stanley Mosk Courthouse: Dept. 400) August 26, 2026 DEPARTMENT 400 LAW AND MOTION RULINGS

FURTHER The Court tenders the following tentative decision in the matter William Chun v. Pacific Asian Consortium in Employment, Los Angeles County Superior Court case number 25STCV33803, set for hearing on August 26, 2026.

William Chun (Plaintiff) moves for orders compelling further responses to the following discovery requests propounded on Pacific Asian Consortium in Employment (Defendant): (1) form interrogatories, set one (FROGs); (2) requests for production of documents, set one (RFPs); (3) special interrogatories, set one (SPROGs); and (4) requests for admissions, set one (RFAs). Plaintiff also requests a total $28,412 in monetary sanctions. Defendant opposes the present motions. Plaintiff's motions to compel discovery are granted in part. The Court awards $5,940 in sanctions.

A.

Legal Standard

A party may move for an order compelling further responses to a request for production of documents if the propounding party deems that responses are incomplete, evasive, or contain meritless objections. (Code Civ. Proc., Sec. 2031.310, subd. (a).)

A motion to compel further responses to requests for production "shall set forth specific facts showing good cause justifying the discovery sought by the inspection demand." (Id., Sec. 2031.310, subd. (b)(1).)

A party may also move for an order compelling further responses to interrogatories if the propounding party deems that responses are incomplete, evasive, contain meritless objections, or improperly exercise the option to produce documents under section 2030.230. (Id., Sec. 2030.300, subd. (a).)

And a party may move for an order compelling further responses to requests for admissions if it shows that an answer is evasive or incomplete or an objection is meritless. (Id., Sec. 2033.290, subd. (a).)

"For discovery purposes, information is relevant if it 'might reasonably assist a party in evaluating the case, preparing for trial, or facilitating settlement.' [Citation]. Admissibility is not the test and information, unless privileged, is discoverable if it might reasonably lead to admissible evidence. [Citation] These rules are applied liberally in favor of discovery." (Gonzales v. Superior Court (1995) 33 Cal.App.4th 1539, 1546.)

"If the court determines that the answer or production sought is subject to discovery, it shall order that the answer be given, or the production be made on the resumption of the deposition." (Code Civ. Proc., Sec. 2025.480, subd. (i).)

B.

Discussion

As a threshold matter, Defendant argues that Plaintiff's motions are moot.

Plaintiff filed the present action on November 18, 2025. (Ibarra Decl. P. 3.)

Plaintiff propounded the relevant discovery requests on January 16, 2026. (Id. P. 5.)

After the parties agreed to an extension, Defendant provided initial responses on March 12, 2026. (Id. P. 8.)

The parties then met and conferred regarding alleged deficiencies in the initial responses on April 24, after having extended the motion to compel deadline due to scheduling difficulties. (Id. P.P. 9-16.)

The parties agreed that Defendant's amended responses would be provided by May 26, but they did not arrive on that date. (Id. P.P. 16-17.)

Eventually, unverified amended responses were received on June 10. (Id. P.P. 18-20.)

Further meet and confer efforts failed, and Plaintiff filed the present motions on July 1, 2026. (Id. P.P. 21-24.)

On August 4, Defendant served further verified responses. (Lowry Decl. P. 17.)

Defendant sought to have the present motions taken off calendar through discussions with Plaintiff's counsel on August 5 and 6. (Id. P.P. 18-20.)

The Court finds that Plaintiff's motions are partially moot.

Defendant has provided further verified responses to Plaintiff's discovery requests since the filing of the present motion, and Plaintiff does not point to any specific deficiencies remaining in those responses.

But through the provision of further responses, Defendant tacitly admits to the merit of Plaintiff's present motions.

Thus, the Court does not find it appropriate to order further responses, but sanctions may still be warranted.

Plaintiff requests sanctions in the total amount of $28,412.

Sanctions may be awarded where a party unsuccessfully opposes a motion to compel further responses to RFAs, RFPs, SPROGs, or FROGs, provided that the party does so without substantial justification. (Code Civ. Proc., Sec.Sec. 2030.300, 2031.310, 2033.290.)

Here, Defendant opposed Plaintiff's motions without substantial justification, as it provided further responses demonstrating the necessity of Plaintiff's motion.

Thus, sanctions are warranted pursuant to sections 2030.300, 2031.310, and 2033.290.

Counsel testifies to an hourly rate of $495, which the Court credits. (Ibarra Decl. P. 25.)

Counsel alleges the following time spent working on the present matter: (1) 0.6 hours drafting the declaration in support of the interrogatory motion; (2) 2.4 hours drafting the declaration in support of the RFPs motion; (3) 2.4 hours drafting the declaration in support of the RFAs motion; (4) 8.7 hours drafting the interrogatory separate statement and motion; (5) 7.5 hours drafting the RFPs separate statement and motion; (6) 8.8 hours drafting the RFAs separate statement and motion; (7) 24 hours drafting the three replies; and (3) hours attending the hearing on this matter. (Ibid.)

Because of the similarity between the three declarations drafted, the Court credits counsel with 2 hours total for drafting them all.

Similarly, the relevant motions are also somewhat duplicative: the Court credits only 1.5 hours for each and 0.5 hours for each separate statement.

Plaintiff's three replies are nearly identical; thus, the Court credits only 3 hours for the drafting of all of them.

Finally, the Court credits counsel with 1 hour for attending the hearing on this matter.

Accordingly, the Court awards Plaintiff sanctions in the amount of $5,940 ([$495 per hour] x [12 hours] = $5,940).

C.

Conclusion

The Court grants Plaintiff's motions in part.

Plaintiff is awarded $5,940 in sanctions, payable by Defendant's counsel to Plaintiff's counsel within 30 days.

Case Number: 26STCV00470 Hearing Date: August 26, 2026 Dept: 400 MOTION TO STRIKE WITHOUT DEMURRER The Court tenders the following