MOTION COMPEL ANSWERS TO INTERROGATORIES
mix of objections and substantive responses. The Responses were unverified. The parties agreed to extend Petitioner’s time to bring this motion to 10/10/25. Efforts to meet and confer were unsuccessful.
As to form interrogatories 2.1(b) and (c), 2.2, 2.5, 2.6, and 2.7: Respondent’s objections are without merit. Moreover, Respondent waived all objections by not timely responding to the discovery and accepting the conditional extension of time. (Code Civ. Proc. § 2030.290(a).)
As to form interrogatory 17.1: Respondent’s alleged response as set forth in Petitioner’s separate statement (ROA 131, 10:17-20) does not match the response provided in Respondent’s responses to form interrogatories attached as Exhibit 4 to the Declaration of Anthony Marcus (ROA 147, Marcus Decl., Ex. 4, 5:14-15:1). Thus, the court makes no finding as to the substance of said response. The response must still be verified.
Respondent shall serve further responses to all form interrogatories, under oath and without objection, within 20 days of notice of this ruling, extended for method of service.
Pursuant to Code of Civil Procedure sections 2023.010 and 2030.290(c) and California Rules of Court, Rule 3.1348, the court imposes reasonable sanctions of $1,750 on Respondent payable to Anthony Marcus Law Firm within 30 days of notice of this ruling, extended for method of service, or any later date as agreed upon by the parties in writing.
7 Martinez Cano - Guardianship; MOTION TO CONTINUE HEARING 30-2025-01509000
Notice of Withdrawal filed 05/14/2026
8 Justin – Trust; 30-2023-01357386 MOTION COMPEL ANSWERS TO INTERROGATORIES
Respondent James Hicklin’s Motion to Compel Further Responses to First Set of Special Interrogatories and Request for Sanctions (ROA 449) is DENIED as moot regarding the request for further responses.
On the issue of sanctions, Respondent should be prepared to explain more fully the relevance of the subject interrogatories, which inquire into the relationship, if any, between petitioner and his counsel prior to the retention of counsel for this proceeding. In the motion, Respondent
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