Not stated

(Stanley Mosk Courthouse: Dept. 316) September 2, 2026 DEPARTMENT 316 LAW AND MOTION RULINGS

On December 27, 2024, Plaintiff filed his fourth amended complaint against Defendants Wire Industries, Inc., Zachary Doctor, and Guy Dotan. The operative complaint alleges one cause of action stemming from the facts alleged above. On July 14, 2026, Defendant Wire Industries, Inc. filed three separate Motions to Compel Plaintiff's Further Discovery Responses. On July 20, 2026, Defendant filed another Motion to Compel Plaintiff's Further Discovery Responses. On August 25, 2026, Plaintiff filed four oppositions, one for each corresponding motion. Plaintiff's oppositions were due by August 20, 2026. (Code Civ. Proc., Sec. 1005, subd. (b).) The Court will nevertheless consider Plaintiff's oppositions. Defendant filed a consolidated reply on August 31, 2026, which the Court will also consider.

Defendant's Motions to Compel Plaintiff's Further Discovery Responses are GRANTED. Defendant is awarded sanctions if the amount of $5,805 against Plaintiff and Plaintiff's counsel, jointly and severally. Plaintiff must serve verified, code-compliant and substantive responses to each of Defendant's discovery requests at issue in the motions within 15 days of the Court's order. Plaintiff is also ordered to produce all non-privileged documents responsive to Defendant's document requests that are within his custody, control or possession within 15 days of the Court's order.

Plaintiff and Plaintiff's counsel are ordered to pay the sanctions award of $5,805 to Defendant's counsel within 30 days of the Court's order. LEGAL STANDARD I. Requests for Production of Documents Under Code of Civil Procedure section 2031.310, the Court may order a responding party to serve a further response to a request for production of documents when the Court finds that any of the ¿ following apply: (1) ¿ a statement of compliance with the demand is incomplete; (2) ¿ a representation of inability to comply is inadequate, incomplete, or evasive; (3) ¿ an objection in the response is without merit or too general. ¿¿¿ A motion to compel further response to requests for production "shall set forth specific facts showing good

cause justifying the discovery sought by the inspection demand." (Code Civ. Proc., Sec. 2031.310, subd. (b)(1).) To establish 'good cause,' the burden is on the moving party to show both: (1) relevance to the subject matter (e.g., how the information in the documents would tend to prove or disprove some issue in the case); and (2) specific facts justifying discovery (e.g., why such information is necessary for trial preparation or to prevent surprise at trial). (See ¿ Glenfed ¿ Development Corp. v.

Superior Court ¿ (1997) 53 Cal.App.4th 1113, 1117.) ¿ If ¿ ' good cause ' ¿ is shown by the moving party, the burden is then on the responding party to justify any objections made to document disclosure. (See Coy v. Superior Court ¿ (1962) 58 Cal.2d 210, 220-21.) ¿¿¿¿ A motion to compel ¿ further ¿ responses ¿ must be ¿ accompanied ¿ by a ¿ meet ¿ and confer declaration. (See Code Civ. Proc., Sec. 2031.310, subd. (b)(2).) ¿¿ Code of Civil Procedure section 2031.310, subdivision (h) authorizes a mandatory issuance of sanctions against "any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust."

II. Interrogatories Code of Civil Procedure Section 2030.220, states: (a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits. (b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible. (c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.

Under Code of Civil Procedure section 2030.300, subdivision (a), the Court may order a responding party to serve a further response to interrogatories if any of the following apply: (1) the answer to a particular interrogatory is incomplete or evasive; (2) the exercise of the option to produce documents is unwarranted or the required specification of those documents is improper or inadequate; or (3) that an objection to an interrogatory is without merit or too general. Code of Civil Procedure section 2030.300, subdivision (d), authorizes a mandatory issuance of sanctions against "any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust."

III.

Requests for Admissions Under Code of Civil Procedure section 2033.290, the Court may order a responding party to serve a further response to requests for admission when the Court finds that any of the following apply: (1) an answer to a particular request is evasive or incomplete; or (2) ¿ an objection to a particular request is without merit or too general. (See ¿ Code Civ. Proc., ¿ Sec. ¿ 2033.290, subd. (a).) ¿ Said motion must be filed within 45 days after ¿ service of the verified response, or the requesting party waives any right to compel further response. (See id. ¿ at subd. (c).) ¿¿ Such a motion "shall be accompanied by a meet and confer declaration under Section 2016.040," which "shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion." (Code Civ.

Proc., Sec. 2033.290, subd. (b); Sec. 2016.040.) ¿¿¿¿¿ Code of Civil Procedure section 2033.290, subdivision (d) authorizes a mandatory issuance of sanctions against "any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust." DISCUSSION I. Meet and Confer Defendant's counsel attempted to meet and confer with Plaintiff's counsel on at least three separate occasions. (See Beffa Decl., P. 2.)

Despite these efforts, Plaintiff's counsel was unresponsive. (See ibid.) Given the foregoing, the meet and confer requirement has not been satisfied. However, given Baffa's diligent attempts to meet and confer with Plaintiff's counsel, the Court will still consider the merits of the motions. II. Compelling Further Discovery Responses Defendant seeks to compel Plaintiff's further response to its requests for inspection, requests for admission, and form and special interrogatories. (See Motions, p. 1:6-8.)

Defendant contends that its requests are relevant to this matter and Plaintiff's objections are boilerplate and frivolous. (See id. at p. 4:12-13.) After evaluating Defendant's discovery requests and Plaintiff's responses, the Court finds that further responses are necessary. First, Plaintiff did not provide a substantive response to any of the propounded discovery. There were no facts provided in

response to special or form interrogatories; neither an admission nor denial of a single request for admission; and no agreement to produce any documents in response to inspection demands. Rather, Plaintiff stated the same set of objections to all or virtually all of the requests. The Court finds that Plaintiff's objections are generally without merit and boilerplate. Second, Defendant's discovery requests are relevant and seek information within the scope of discoverable material. (See generally Sep.

Stmts.) Many of the special interrogatories ask for facts supporting specific allegations in the complaint. The requests for admission track assertions Plaintiff made in the complaint and the inspection demands are for documents that are plainly relevant such as communications between the parties and any agreements or proposed agreements Plaintiff claims were exchanged with Defendants. Finally, even if Plaintiff's claims of privilege have merit, which generally it appears they do not, Plaintiff is obligated to provide those facts and documents that are not privileged in response to the requests.

For these reasons the Court finds Plaintiff's responses to be inadequate and not compliant with the requirements of the Code of Civil Procedure and that Plaintiff's opposition lacks substantial justification. Defendant requests sanctions in the total amount of $7,353 ($645 per hour for 11.4 hours) for all four motions. (See Beffa Decl., P. 27.) The Court finds the rate reasonable given counsel's experience and credentials. It finds the hours to be slightly excessive given that the four motions are very similar to one another.

While the Court recognizes that the separate statements are tedious, it also expects those would be prepared (at least in large part) by someone with a lower billing rate. The Court will reduce the hours to a total of 9 hours at the requested rate. Accordingly, the Court will award sanctions in the total amount of $5,805. Defendant also seeks a continuance in the trial date, which is currently scheduled for October 12, 2026. The Court will not continue the trial date at this time. If Defendant continues to believe that a trial continuance is necessary when it receives the ordered discovery responses and documents, it may renew its request in a motion or ex parte application pursuant to California Rules of Court, Rule 3.1332 (b).

CONCLUSION For the foregoing reasons, Defendant's Motions to Compel Plaintiff's Further Discovery Responses is GRANTED. Defendant is awarded sanctions if the amount of $5,805 against Plaintiff and Plaintiff's counsel, jointly and severally. Plaintiff must serve verified, code-compliant and substantive responses to each of Defendant's discovery requests at issue in the motions within 15 days of the Court's order. Plaintiff is also ordered to produce all non-privileged documents responsive to Defendant's document requests that are within his custody, control or possession within 15 days of the Court's order.

Plaintiff and Plaintiff's counsel are ordered to pay the sanctions award of $5,805 to Defendant's counsel within 30 days of the Court's order. |

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