DOMENIQUE NEWMAN vs GREYSTAR CALIFORNIA, INC., et al.

Motions:

(1) Defendant Greystar’s Motion to compel further responses Form Interrogatories, Set One;

2025CUPO041518: DOMENIQUE NEWMAN vs GREYSTAR CALIFORNIA, INC., et al.

(2) Defendant Greystar’s Motion to compel further responses Special Interrogatories, Set One; and

(3) Defendant Greystar’s Motion to compel further responses Request for Production of Documents, Set One.

Tentative Ruling:

(1) Defendant Greystar’s Motion to compel further responses Form Interrogatories, Set One is GRANTED, as detailed below.

(2) Defendant Greystar’s Motion to compel further responses Special Interrogatories, Set One is GRANTED, as detailed below.

(3) Defendant Greystar’s Motion to compel further responses Request for Production of Documents, Set One is GRANTED, as detailed below.

Plaintiff is ordered to provide the further responses described below, on or before June 1, 2026.

Monetary sanctions are awarded in the aggregate amount of $5,000, payable by Plaintiff and counsel on or before June 18, 2026.

Moving party is ordered to serve notice of the Court’s ruling.

Discussion

In responding to discovery, Plaintiff has improperly referred to extrinsic documents, using "N/A" instead of providing substantive answers, failed to provide names and contact information for witnesses and document custodians, has incorporated inconsistencies between interrogatory responses and actual document production, and identified possession of photographs and communications that were not produced. The documents Plaintiff claims in her interrogatory responses to possess (photographs, a "large column of emails and text messages," employer documentation) and what were produced (roughly 20 pages of largely irrelevant records) are inconsistent.

Form Interrogatory No. 2.1 (Name History)

The birth certificate name is not stated here. A further code compliant, verified response is ordered.

Form Interrogatory No. 2.6 (Employment History)

There is a gap between 2016 and April 2018, and from November 2022 to the present. The post- November 2022 gap is particularly significant because the incidents occurred in April and August 2023, and plaintiff is claiming lost wages, meaning she presumably had employment during or around the incident period. Plaintiff's COVID explanation covers 2021 but does not address 2016– 2018 or 2023. A further code compliant, verified response is ordered.

2025CUPO041518: DOMENIQUE NEWMAN vs GREYSTAR CALIFORNIA, INC., et al.

Form Interrogatory No. 2.7 (Education History)

Inability-to-recall is not a compliant response. A party responding to discovery has a duty to investigate and provide all information in their possession, custody and control, including approximate time ranges. The degree section is duplicative and confusing because the same paragraph appears multiple times and does not clearly delineate which institution corresponds to which level of study. A further code compliant, verified response is ordered.

Form Interrogatory No. 2.12 (Disability or Condition at Time of Incident)

Plaintiff’s response is sufficient.

Form Interrogatory No. 6.2 (Injuries)

Plaintiff identifies the body part where the laceration occurred, but references C7-T1 findings without clarifying whether she is asserting a thoracic spine claim. She describes depression and anxiety in other responses but does not list them as injuries here, creating ambiguity about the scope of her psychological damages claim. A further code compliant, verified response is ordered.

Form Interrogatory No. 6.7 (Future Treatment)

This response is insufficient. A party cannot exercise the option to reference medical records without identifying the specific documents which are responsive. A document dump and a “find it yourself” response are improper. A further code compliant, verified response is ordered.

Form Interrogatories Nos. 7.1 and 7.2 (Property Damage)

Plaintiff’s response is sufficient.

Form Interrogatories Nos. 9.1 and 9.2 (Other Damages and Supporting Documents)

Interrogatory responses cannot refer to documents produced elsewhere without tying the documents to the specific information requested. The substance of the response is insufficient as well. As stated above, “A document dump and a “find it yourself” response are improper.” A further code compliant, verified response is ordered.

Form Interrogatory No. 10.3 (Subsequent Injuries)

This response is evasive and nonresponsive to the question. A further code compliant, verified response is ordered.

Form Interrogatory No. 12.1 (Witnesses)

The response does not delineate which witness pertains to which incident. Plaintiff identified by name in her Special Interrogatory responses several Greystar management personnel (Smith, Ruiz,

2025CUPO041518: DOMENIQUE NEWMAN vs GREYSTAR CALIFORNIA, INC., et al.

Willison) with full contact information, yet that information does not appear here. The responses across different discovery sets are inconsistent. “I do not have this information at this time” is insufficient. A party responding to discovery has a duty to investigate and provide all information in their possession, custody and control. It does not appear that any attempt to obtain the information was made. A further code compliant, verified response is ordered.

Form Interrogatory No. 12.4 (Photographs and Videos)

This response is insufficient. The documents must be specifically identified. A further code compliant, verified response is ordered.

Document Production Requests Nos. 1–4, 6, 13–15

The responses to these requests do not state whether production is complete or whether responsive documents are being withheld. They do not identify documents with reasonable particularity tied to each specific request number as required by Code of Civil Procedure section 2031.280, subdivision (a). The 20 pages produced are not responsive to the requests. A party responding to discovery has a duty to investigate and provide all information in their possession, custody and control. A representation that a diligent search and reasonable inquiry was made is required. A further code compliant, verified response is ordered.

Special Interrogatory Nos. 5 and 6 (Witnesses to Each Incident)

Referencing unnamed medical providers with a promise to produce their contact information later is not a complete response. The management witnesses lack addresses and phone numbers as well, which is a meaningful deficiency for subpoena purposes. Plaintiff identified her neighbor as a potential witness but provided no name, address, or phone number, with the excuse that the neighbor was intoxicated and unwilling to cooperate. A party responding to discovery has a duty to investigate and provide all information in their possession, custody and control. A further code compliant, verified response is ordered.

Special Interrogatory Nos. 7 and 8 (Documents Supporting Liability Theories)

Plaintiff has failed to identify the custodians of her medical records, inspection photographs, paystubs, and employer documentation. Plaintiff’s statement that she has “many photos, emails, texts, inspection/repair/complaint records, and other documents that I have not yet fully reviewed” is an express admission of non-compliance with the duty to conduct a reasonable and diligent inquiry before responding. A further code compliant, verified response is ordered.

Special Interrogatory Nos. 18 and 19 (Witnesses to Lost Earnings)

For employers and payroll/financial custodians, however, plaintiff listed only generic categories ("Employers/Payroll Departments/Supervisors — To Be Supplemented") with no names, addresses, or phone numbers, stating she was in the process of reviewing records. This is a deficient response. A further code compliant, verified response is ordered.

2025CUPO041518: DOMENIQUE NEWMAN vs GREYSTAR CALIFORNIA, INC., et al.

Special Interrogatory Nos. 33 and 34 (Prior Medical Treatment for Same Body Parts)

Plaintiff's response that she had no prior treatment for any of the injured body parts is inconsistent with her own Form Interrogatory responses disclosing a prior workers' compensation claim for psychological injury. Plaintiff is now claiming depression and anxiety as damages, the workers’ comp claim for psychological injury is directly relevant and should have been disclosed here. A further code compliant, verified response is ordered.

Special Interrogatory No. 37 (Pharmacies)

Plaintiff identified “CVS Beverly Hills” with no address or phone number and stated she would supplement with previous pharmacies. This response is incomplete and insufficient. A further code compliant, verified response is ordered.

5