Clorinda Russo v. MV Transportation, Inc., et al.

TENTATIVE RULINGS Clorinda Russo, by and through her Guardian Ad Litem Gina Mineo v. MV Transportation, Inc., et al.

Plaintiff’s Motion to Compel Defendant to Serve Further Responses to the Following Written Discovery and Request for Monetary Sanctions:

1. Form Interrogatories, Set One;

2. Special Interrogatories, Set One; and

3. Requests for Production, Set One.

Hearing Date: August 28, 2026

NOTE RE TENTATIVE RULINGS

Each of these tentative rulings becomes the court’s order, and no hearing shall be held unless one of the parties contests it by following Rule 3.1308 of the California Rules of Court and Monterey County Local Rule 7.9. Those parties wishing to present an oral argument must notify all other parties and the Court no later than 4:00 p.m. on the court day before the hearing; otherwise, NO ORAL ARGUMENT WILL BE PERMITTED, AND EACH TENTATIVE RULING WILL BECOME THE ORDER OF THE COURT AND THE RELATED HEARING VACATED. You must notify the court by email or by calling the Calendar Department at 831-647-5800, extension 3040, before 4:00 p.m. on the court day before the hearing.

Tentative Ruling: Form Interrogatories

Plaintiff’s Motion to Compel Defendant’s Further Responses to Form Interrogatories

Plaintiff Clorinda Russo (“Plaintiff”) moves for an order compelling Defendant MV Transportation, Inc. (“Defendant”) to further respond to her first set of Form Interrogatories. Plaintiff contends that after “two rounds of extensions, three rounds of responses spanning three months, and a detailed meet-and-confer letter,” Defendant did not supplement her amended objection-only responses to Nos. 15.1, 16.1, 16.2, 16.4, 16.5, 16.6, and 20.2. [Motion at 2-3; Gladin-Kramer Decl. at ¶ 9 and Exhs. I and J.]

After considering the parties’ papers and arguments, Plaintiff’s motion and request for monetary sanctions are GRANTED. Within 20 days of the Notice of Entry of the signed order, Defendant shall serve verified, objection-free, and Code-compliant further responses as detailed below. Further, within 20 days of the order, Defendant and its counsel, jointly and severally, shall pay a total of $1,460 in reasonable sanctions, payable to the law firm of Mercado Kramer.

Defendant’s request for sanctions against Plaintiff is DENIED.

Plaintiff shall prepare the Proposed Order consistent with this Tentative Ruling.

Legal Standard.

“Unless otherwise limited by order of the court ... any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved ... if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” [Code Civ. Proc. § 2017.010.]

A party serving interrogatories may file a motion for an order compelling further responses if that party believes an answer is, among other things, evasive or incomplete, or an objection lacks merit or is too broad. [Code Civ. Proc. § 2030.300, subd. (a).] If a timely motion to compel is filed, the responding party has the burden to justify any objection or failure to answer the interrogatories fully. [Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.]

In assessing the motion, a court should generally consider the following factors: (1) the relationship of the information sought to the issues framed in the pleadings; (2) the likelihood that disclosure will be of practical benefit to the party seeking discovery; and (3) the burden or expense likely to be encountered by the responding party in furnishing the information sought. [Columbia Broadcast System, Inc. v. Superior Court (1968) 263 Cal.App.2d 12, 19.]

Evasive discovery responses and objections lacking adequate justification are considered “misuses of the discovery process.” [Code Civ. Proc. § 2023.010, subds. (e)-(f).] The Court “shall” require the party receiving discovery to pay the propounding party’s reasonable expenses, such as attorney fees, for enforcing discovery unless it finds that the sanctioned party acted with “substantial justification” or that other circumstances make the sanction unjust. [Code Civ. Proc. § 2030.300, subd. (d).] “Our courts have interpreted the term ‘substantial justification’ to mean ‘well-grounded in both law and fact.’ Thus, to avoid sanctions, the deponent must show there

Tentative Ruling: Form Interrogatories

were reasonable grounds to believe an objection was valid or that the answer given was adequate.” [City of Los Angeles v. Superior Court (2017) 9 Cal.App.5th 272, 291 (internal citations, bracketed text, and ellipsis omitted).]

Discussion.

A. Meet-and-Confer Requirement.

Plaintiff has fulfilled her meet-and-confer obligation under Code of Civil Procedure section 2016.040. Her letter dated June 4, 2026, outlined the deficiencies in the Defendant’s discovery responses. [Gladin-Kramer Decl. at ¶ 5 and Exh. D at 91-93.] On June 30, 2026, Defendant provided Supplemental Responses to the Form Interrogatories but did not supplement its responses to Nos. 15.1, 16.1, 16.2, 16.4, 16.5, 16.6, and 20.2. [Id. at ¶ 9 and Exhs. I and J.] As a result, Defendant maintained objections-only responses to these Form Interrogatories, initially served on May 14, 2026. [Id. at ¶ 4 and Exh. C.] Defendant’s later Supplemental Responses failed to add significant new information, only containing boilerplate objections. [Id. at ¶¶ 4, 9, and Exhs. C, I, and J.] Because these responses did not significantly address the previous deficiencies, no further meet and confer was required.

B. Defendant’s Responses to Form Interrogatories.

Plaintiff’s motion to compel is GRANTED as to Form Interrogatory Nos. 15.1, 16.1, 16.2, 16.4, 16.5, and 16.6.

On the Court’s own motion, Defendant is ordered to serve further responses that do not include a Preliminary Statement because it creates doubt as to whether Defendant has provided complete responses.

No. 15.1 asks for information about Defendant’s denials and defenses. Defendant’s response is non-specific and unhelpful. [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 67-68.] Despite asserting prematurity, Defendant must provide all presently known information supporting its denials and affirmative defenses. [Code Civ. Proc. § 2030.220, subds. (a)-(b).] Contentions may be probed via interrogatory even if they involve opinions or theories. [Code Civ. Proc. § 2030.010, subd. (b).] Therefore, a further response to No. 15.1 is warranted because Defendant did not provide a substantive response.

Nos. 16.1-16.2 and 16.4-16.6 request known facts relating to Defendant’s liability defenses, including whether someone else caused the incident [No. 16.1], no injury occurred [No. 16.2], the medical treatment was not related to the incident [No. 16.4], the damages are unreasonable [No. 16.5], and there are loss-of-earnings issues [No. 16.6]. [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 68-73.] Defendant asserted identical objections—prematurity, work product, attorney‐client privilege, and expert disclosure—with no supporting explanation. [Ibid.]

But these interrogatories seek underlying factual contentions, not attorney work product. Indeed, section 2030.010, subdivision (b), explicitly allows such interrogatories even if the answer involves legal theories or application of law to fact. Further, the Court notes that Defendant supplemented its response to No. 16.3, thus undermining Defendant’s claim that responding to

Tentative Ruling: Form Interrogatories

the Form Interrogatories in section 16.0 is premature. [Gladin-Kramer decl. at ¶ 9 and Exh. I at 131-133.] Thus, as to these Form Interrogatories, the motion is granted because Defendant cannot rely on blanket objections that contradict statutory authorization and its own partial responses.

Therefore, the motion is GRANTED. Defendant must provide complete, Code‐compliant responses to Nos. 15.1, 16.1-16.2, and 16.4-16.6 based on all information presently known. [Code Civ. Proc. § 2030.220, subds. (a)-(b).] Discovery may seek contentions [Code Civ. Proc. § 2030.010, subd. (b)], and objections based on prematurity, work‐product, or expert disclosure are not proper here.

C. Sanctions.

Plaintiff’s request for monetary sanctions is GRANTED. Defendant misused the discovery process by serving evasive discovery responses and objections without adequate justification. [Code Civ. Proc. § 2023.010, subds. (e)-(f).] Plaintiff counsel’s $350 hourly rate and the four hours she spent to file and draft the motion are reasonable. [Gladin-Kramer Decl. at ¶¶ 13-14.] Therefore, the Court awards Plaintiff $1,460 in reasonable attorney’s fees.

Defendant’s request for sanctions against Plaintiff is DENIED. Given the reasons behind this ruling, Defendant’s argument that Plaintiff filed a “knowingly improper” motion lacks merit. Defendant’s own failure to provide meaningful supplemental responses is the cause of the motion.

Conclusion.

The motion is GRANTED. Defendant shall serve further verified responses consistent with this Tentative Ruling and pay the $1,460 sanctions award within 20 days of the Court’s order. Plaintiff shall prepare the Proposed Order.

Tentative Ruling: Special Interrogatories

Plaintiff’s Motion to Compel Defendant’s Further Responses to Special Interrogatories

Plaintiff Clorinda Russo (“Plaintiff”) moves for an order compelling Defendant MV Transportation, Inc. (“Defendant”) to further respond to her first set of Special Interrogatories. Plaintiff contends that after “three rounds of responses, multiple extensions, and detailed meetand-confer efforts,” Defendant did not supplement her amended objection-only responses to Nos. 3, 6, 7, 8, 9, and 14. [Motion at 3; Gladin-Kramer Decl. at ¶¶ 4-5, 9, and Exhs. C, D, I, and J.] After considering the parties’ papers and arguments, Plaintiff’s motion is GRANTED IN PART (Nos. 7-9) and DENIED IN PART (Nos. 3, 6, and 14).

Her request for monetary sanctions is GRANTED. Within 20 days of the Notice of Entry of the signed order, Defendant shall serve verified, objection-free, and Code-compliant further responses as detailed below. Further, also within 20 days of the order, Defendant and its counsel, jointly and severally, shall pay a total of $730 in reasonable sanctions, payable to the law firm of Mercado Kramer.

Defendant’s request for sanctions against Plaintiff is DENIED.

Plaintiff shall prepare the Proposed Order consistent with this Tentative Ruling.

Legal Standard.

“Unless otherwise limited by order of the court ... any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved ... if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” [Code Civ. Proc. § 2017.010.]

A party serving interrogatories may file a motion for an order compelling further responses if that party believes an answer is, among other things, evasive or incomplete, or an objection lacks merit or is too broad. [Code Civ. Proc. § 2030.300, subd. (a).] If a timely motion to compel is filed, the responding party has the burden to justify any objection or failure to answer the interrogatories fully. [Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.]

In assessing the motion, a court should generally consider the following factors: (1) the relationship of the information sought to the issues framed in the pleadings; (2) the likelihood that disclosure will be of practical benefit to the party seeking discovery; and (3) the burden or expense likely to be encountered by the responding party in furnishing the information sought. [Columbia Broadcast System, Inc. v. Superior Court (1968) 263 Cal.App.2d 12, 19.]

Evasive discovery responses and objections lacking adequate justification are considered “misuses of the discovery process.” [Code Civ. Proc. § 2023.010, subds. (e)-(f).] The Court “shall” require the party receiving discovery to pay the propounding party’s reasonable expenses, such as attorney fees, for enforcing discovery unless it finds that the sanctioned party acted with “substantial justification” or that other circumstances make the sanction unjust. [Code Civ. Proc. § 2030.300, subd. (d).] “Our courts have interpreted the term ‘substantial justification’ to mean ‘well-grounded in both law and fact.’ Thus, to avoid sanctions, the deponent must show there

Tentative Ruling: Special Interrogatories

were reasonable grounds to believe an objection was valid or that the answer given was adequate.” [City of Los Angeles v. Superior Court (2017) 9 Cal.App.5th 272, 291 (internal citations, bracketed text, and ellipsis omitted).]

Discussion.

A. Meet-and-Confer Requirement.

Plaintiff has fulfilled her meet-and-confer obligation under Code of Civil Procedure section 2016.040. Her letter dated June 4, 2026, outlined the deficiencies in the Defendant’s discovery responses. [Gladin-Kramer Decl. at ¶ 5 and Exh. D at 38-40.] On June 30, 2026, Defendant provided Supplemental Responses to the Special Interrogatories but did not supplement its responses to Nos. Nos. 3, 6, 7, 8, 9, and 14. [Id. at ¶ 9 and Exhs. I and J.] As a result, Defendant maintained objections-only responses to these Special Interrogatories, initially served on May 14, 2026. [Id. at ¶ 4 and Exh. C.] Defendant’s later Supplemental Responses failed to add significant new information, only containing boilerplate objections. [Id. at ¶¶ 4, 9, and Exhs. C, I, and J.] Because these responses did not significantly address the previous deficiencies, no further meet and confer was required.

B. Defendant’s Responses to Special Interrogatories.

On the Court’s own motion, Defendant is ordered to serve further responses that do not include a Preliminary Statement because it creates doubt as to whether Defendant has provided complete responses.

Nos. 3 and 6 concern whether Defendant disciplined or terminated Defendant Luis Pacheco, who is the driver involved in the incident. [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 23-25.] Defendant argues that these interrogatories are irrelevant due to its admission of vicarious liability. Indeed, “an employer’s admission of vicarious liability for an employee’s negligent driving in the course of employment bars a plaintiff from pursuing a claim for negligent entrustment.” [Diaz v. Carcamo (2011) 51 Cal.4th 1148, 1159, 1161.]

Under Diaz, employer negligence theories (e.g., hiring, training, supervision, discipline, or prior complaints) are irrelevant because the employer’s liability cannot exceed the driver’s. Therefore, discovery solely aimed at negligent entrustment, which is irrelevant and inadmissible, does not appear reasonably calculated to lead to the discovery of admissible evidence. [Code Civ. Proc. § 2017.010.] Defendant’s admission of vicarious liability, which is conditioned upon Mr. Pacheco being deemed negligent, is binding on Defendant and fully aligns with Diaz, 51 Cal.4th at 1151-1152.

Therefore, as to Nos. 3 and 6, the motion is DENIED.

No. 7 seeks facts regarding the training provided to Mr. Pacheco about “transporting riders in wheelchairs.” [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 25-26.] Unlike discipline or termination, Mr. Pacheco’s training may lead to the discovery of admissible evidence relevant to driver negligence. Plaintiff alleges the wheelchair was not properly secured. How Mr. Pacheco was trained could bear on whether he performed in accordance with training or departed from expected safety protocols. Thus, this interrogatory goes to Mr. Pacheco’s own negligence, not

Tentative Ruling: Special Interrogatories

negligent entrustment. Under Diaz, the information this interrogatory seeks relates to Mr. Pacheco’s conduct—not Defendant’s fault. As to No. 7, the motion is GRANTED.

Nos. 8 and 9 seek facts supporting Defendant’s affirmative defense that other persons were responsible for the incident. [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 26-27.] By objecting that the interrogatory is premature, Defendant ignores that its Answer includes a Twelfth Affirmative Defense labeled “Conduct of Others.” [Answer at 4-5.] Because Defendant raised this defense, it must articulate any presently known facts. [Code Civ. Proc. § 2030.220, subds. (a)-(b).] Defendant’s boilerplate objections are insufficient. As to Nos. 8 and 9, the motion is GRANTED.

No. 14 requests the Defendant to “[d]escribe with particularity all COMMUNICATIONS that YOU or YOUR REPRESENTATIVES had with PLAINTIFF, her Guardian Ad Litem Gina Mineo, or any PLAINTIFF’S REPRESENTATIVES at any time.” [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 30-31.] Additionally, the Defendant’s response must include “the date of the COMMUNICATION, the name of the PERSON who made or received the communication, and a brief summary of the substance of the COMMUNICATION.” [Ibid.] Defendant objected, claiming that this request is “overly broad, vague and ambiguous as framed.” [Ibid.]

The Court agrees. The interrogatory is unlimited in both time and scope. As a result, Plaintiff likely engaged in many "communications,” making compliance unduly burdensome without clear limitations. Therefore, the motion regarding No. 14 is DENIED because the interrogatory is overly broad and has limited practical value relative to the burden of responding.

C. Sanctions.

Plaintiff’s request for monetary sanctions is GRANTED IN PART. For Nos. 7-9, Defendant misused the discovery process by serving evasive discovery responses. However, Defendant’s objections to Nos. 3, 6, and 14 were justified. Given the mixed result, the Court awards Plaintiff half of the requested fees, or $730, based on Plaintiff’s counsel’s reasonable $350 hourly rate and the two hours she spent filing and drafting the motion. [Gladin-Kramer Decl. at ¶¶ 13-14.]

Defendant’s request for sanctions against Plaintiff is DENIED. Given the reasons behind this ruling, Defendant’s argument that Plaintiff filed a “knowingly improper” motion lacks merit. Defendant’s own failure to provide meaningful supplemental responses is the cause of the motion.

Conclusion.

The motion is GRANTED IN PART as to Nos. 7-9, and DENIED IN PART as to Nos. 3, 6, and 14. Defendant shall serve further verified responses consistent with this Tentative Ruling and pay the $730 sanctions award within 20 days of the Court’s order. Plaintiff shall prepare the Proposed Order.

Tentative Ruling: Requests for Production

Plaintiff’s Motion to Compel Defendant’s Further Responses to Requests for Production

Plaintiff Clorinda Russo (“Plaintiff”) moves for an order compelling Defendant MV Transportation, Inc. (“Defendant”) to further respond to her first set of Requests for Production. Plaintiff contends that after “three rounds of responses and two extensions,” Defendant failed to: (1) supplement her amended responses to Nos. 12, 14-17, and 19-21; and (2) serve sufficient supplemental responses to Nos. 1-6, 10-11, and 18. [Motion at 2-3; Gladin-Kramer Decl. at ¶¶ 3, 4, 8, 10, and Exhs. B, C, E, and F; Reply at 2.]

After considering the parties’ papers and arguments, Plaintiff’s motion is GRANTED IN PART (Nos. 1-6, 10-12, 18, and 20-21) and DENIED IN PART (Nos. 14-17 and 19). Her request for monetary sanctions is GRANTED. Within 20 days of the Notice of Entry of the signed order, Defendant shall serve verified, objection-free, and Code-compliant further responses as detailed below. Further, within 20 days of the order, Defendant and its counsel, jointly and severally, shall pay a total of $1,460 in reasonable sanctions, payable to the law firm of Mercado Kramer.

Defendant’s request for sanctions against Plaintiff is DENIED.

Plaintiff shall prepare the Proposed Order consistent with this Tentative Ruling.

Legal Standard.

If a party responding to a request for production fails to permit inspection, copying, testing, or sampling as specified in that party’s statement of compliance, the requesting party may file a motion for an order to enforce compliance. [Code Civ. Proc. § 2031.320, subd. (a).] A motion to compel further responses to a request for production must include specific facts demonstrating “good cause” to justify the discovery sought by the demand. [Code Civ. Proc. § 2031.310, subd. (b)(1).] If the moving party shows good cause for producing documents, the burden shifts to the objecting party to justify the objections. [Kirkland v.

Superior Court (2002) 95 Cal.App.4th 92, 98.] The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully files or opposes a motion to compel further responses to a demand for inspection or production of documents, or a motion to compel compliance with a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make it unjust to impose sanctions. [Code Civ. Proc. §§ 2031.310, subd. (h), and 2031.320, subd. (b).]

Discussion.

A. Meet-and-Confer Requirement.

Plaintiff has fulfilled her meet-and-confer obligation under Code of Civil Procedure section 2016.040. Her letter dated June 4, 2026, outlined the deficiencies in the Defendant’s discovery responses. [Gladin-Kramer Decl. at ¶ 4 and Exh. C at 58-60.] On June 30, 2026, Defendant provided Supplemental Responses. However, they largely restated Defendant’s earlier objections and merely referenced Defendant’s entire document production. [Id. at ¶¶ 8-10 and

Tentative Ruling: Requests for Production

Exh. E.] Because these responses did not significantly address the previous deficiencies, no further meet and confer was required.

B. Defendant’s Responses to Plaintiff’s Requests for Production.

On the Court’s own motion, Defendant is ordered to serve further responses that do not include a Preliminary Statement because it creates doubt as to whether Defendant has provided complete responses.

No. 12 seeks documents related to the training Defendant gave to the driver, Defendant Luis Pacheco, “about transporting riders in wheelchair.” [Plaintiff’s Separate Statement at 9:15- 10:13.] Documents related to Mr. Pacheco’s training may lead to the discovery of admissible evidence relevant to driver negligence. Plaintiff alleges the wheelchair was not properly secured. How Mr. Pacheco was trained could bear on whether he performed in accordance with training or departed from expected safety protocols. Thus, this request goes to Mr. Pacheco’s own negligence, not negligent entrustment. In other words, the requested documents relate to Mr. Pacheco’s conduct—not Defendant’s fault. As to No. 12, the motion is GRANTED.

Nos. 14-17 seek employer-focused evidence of negligent entrustment (e.g., notice, a pattern of conduct, or discipline). Defendant argues that these requests are irrelevant due to its admission of vicarious liability. Indeed, “an employer’s admission of vicarious liability for an employee’s negligent driving in the course of employment bars a plaintiff from pursuing a claim for negligent entrustment.” [Diaz v. Carcamo (2011) 51 Cal.4th 1148, 1159, 1161.] Under Diaz, employer negligence theories, which are covered in Nos. 14-17, are irrelevant because the employer’s liability cannot exceed the driver’s.

Therefore, discovery solely aimed at negligent entrustment, which is irrelevant and inadmissible, does not appear reasonably calculated to lead to the discovery of admissible evidence. [Code Civ. Proc. § 2017.010.] Defendant’s admission of vicarious liability, which is conditioned upon Mr. Pacheco being deemed negligent, is binding on Defendant and fully aligns with Diaz, 51 Cal.4th at 1151-1152. [Opp. at 5-6.] Therefore, as to Nos. 14-17, the motion is DENIED.

No. 19 requests all “COMMUNICATIONS made by YOU or YOUR REPRESENTATIVES to PLAINTIFF or her REPRESENTATIVES.” [Gladin-Kramer Decl. at ¶ 3 and Exh. B at 44.] In part, Defendant objected that the request is overly broad, vague, and ambiguous. [Ibid.] The Court agrees. The request is unlimited in both time and scope. As a result, Plaintiff likely engaged in many “communication[s],” making compliance unduly burdensome without clear limitations. Therefore, the motion regarding No. 19 is DENIED because the request is overly broad and has limited practical value relative to the burden of production.

No. 20 requests all “COMMUNICATIONS received from any PERSON by YOU or YOUR REPRESENTATIVES, excluding YOUR attorneys, that RELATE to the INCIDENT.” [Gladin-Kramer Decl. at ¶ 3 and Exh. B at 44.] This is narrower than No. 19 because it is confined to incident-related communications. Defendant argues that Plaintiff already has the requested communications. This is inaccurate because Plaintiff would only have communications

Tentative Ruling: Requests for Production

she sent to Defendant, not communications Defendant received from other sources. As to No. 20, the motion is GRANTED.

No. 21 mirrors the documents requested in No. 20, but concerns outgoing communications. [Gladin-Kramer Decl. at ¶ 3 and Exh. B at 44-45.] Defendant provided no specific argument opposing this request. Beyond that, the request is relevant to Defendant’s post-incident statements about the event. Regarding No. 21, the motion is GRANTED.

Plaintiff argues that Defendant’s supplemental responses to Nos. 1-6, 10-11, and 18 are insufficient because “[r]eferring to an undifferentiated production violates Code of Civil Procedure section 2031.280(a), and the ‘equally available’ objection is legally unrecognized.” [Separate Statement at 2-9 and 15.] The Court agrees, and the motion is GRANTED. Defendant’s supplemental responses are insufficient, and it must serve Code-compliant responses to Nos. 1-6, 10-11, and 18 without objection except for objections supported by a Code-compliant privilege log. [Code Civ. Proc. § 2031.240, subds. (b)-(c); Hernandez v. Superior Court (2003) 112 Cal.App.4th 285, 293.]

C. Sanctions.

Plaintiff’s request for monetary sanctions is GRANTED. Defendant misused the discovery process by serving evasive discovery responses and objections without adequate justification to a substantial majority of the at-issue document requests. [Code Civ. Proc. § 2023.010, subds. (e)-(f).] Plaintiff counsel’s $350 hourly rate and the four hours she spent to file and draft the motion are reasonable. [Gladin-Kramer Decl. at ¶¶ 13-14.] Therefore, the Court awards Plaintiff $1,460 in reasonable attorney’s fees.

Defendant’s request for sanctions against Plaintiff is DENIED. Given the reasons behind this ruling, Defendant’s argument that Plaintiff filed a “knowingly improper” motion lacks merit. Defendant’s own failure to provide meaningful amended and supplemental responses is the cause of the motion.

Conclusion.

The motion is GRANTED IN PART as to Nos. 1-6, 10-12, 18, and 20-21, and DENIED IN PART as to Nos. 14-17 and 19. Defendant shall serve further verified responses consistent with this Tentative Ruling and pay the $1,460 sanctions award within 20 days of the Court’s order. Plaintiff shall prepare the Proposed Order.

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