Defendant’s Motion to Compel Further Responses
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2023CUOR012253: AJAY K KESHAP vs DEEPIKA WALI, AN INDIVIDUAL AND ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, O... 05/28/2026 in Department 43 Motion to Compel Further Responses
The morning calendar in courtroom 43 will normally begin at 8:45. Please arrive for your hearing no later than 8:30 a.m. The door will be opened before the calendar is called.
The Court allows appearances by CourtCall and Zoom. Refer to the Courtroom 43 webpage for more information about remote appearances. If appearing by CourtCall, call in no later than 8:30 a.m. If you wish to appear by CourtCall, you must make arrangements with CourtCall by 4:00 p.m. the court day before your scheduled hearing. Requests for approval of a CourtCall appearance made on the morning of the hearing will not be granted. No exceptions will be made.
For Zoom appearances, all counsel appearing by Zoom must email the court at Courtroom43@ventura.courts.ca.gov with a simultaneous copy to all other counsel/selfrepresented parties no later than 3:00 p.m. the court day before the hearing. INCLUDE THE PHRASE "ZOOM APPEARANCE ON (DATE OF HEARING)" IN THE SUBJECT LINE OF YOUR EMAIL. The email must identify the person who will make the appearance. You will receive the login information for your appearance in reply to your email. If appearing by Zoom, log into the hearing no later than 8:30 a.m. The Court will transfer you to the meeting room when your matter is called. Additional instructions can be found on the Courtroom 43 webpage. When you log in to Zoom, be sure that your name and the case name are used as your Zoom name. IF YOU DO NOT FOLLOW ALL OF THESE INSTRUCTIONS, YOU WILL NOT BE PERMITTED TO APPEAR BY ZOOM AT THE HEARING.
With respect to the tentative ruling below, no notice of intent to appear is required. If you wish to submit on the tentative ruling you can fax notice to Judge Coats's secretary, Ms. Brantner at 805- 477-8790, stating that you submit on the tentative. Or you may email Courtroom43@ventura.courts.ca.gov with all counsel copied on the email. Do not call in lieu of sending a fax or email. If you submit on the tentative without appearing and the opposing party appears, the hearing will be conducted in your absence. If you are the moving party and do not advise the Court that you submit on the tentative, or you do not appear at the hearing, the Court may deny your motion irrespective of the tentative.
Unless stated otherwise at the hearing, if a formal order is required but not signed at the hearing, the prevailing party shall prepare a proposed order and comply with CRC 3.1312 subdivisions (a), (b), (d) and (e). The signed order shall be served on all parties and a proof of service filed with the court. A "notice of ruling" in lieu of this procedure is not authorized.
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Motion: Defendants Motion to Compel Further Responses
2023CUOR012253: AJAY K KESHAP vs DEEPIKA WALI, AN INDIVIDUAL AND ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, O...
Tentative Ruling: Defendants Motion to Compel Further Responses is GRANTED in part and DENIED in part.
For most of the items at issue, the supplemental response to Subpart (b) consists of a boilerplate paragraph about the right to use general denial and affirmative defenses, followed by a brief statement of the responding partys position. The responding party contends that it has provided all information presently known after reasonable inquiry. If true, this is a sufficient response. (Responding party is cautioned that if the Court later determines that a factual basis has been improperly withheld, it could form the basis for an order of sanctions.) The motion is denied relative to subpart (b).
As to Subpart (c), the response, Other individuals who may be named in the documents produced concurrently herewith is insufficient. The responding party must identify all witnesses known or discoverable with reasonable inquiry. The Court orders verified further responses to Subpart (c) providing the requested information for each witness with knowledge relative to each RFA.
The responses to Subpart (d) are insufficient. Responding party must identify specifically which document(s) relate to which RFA denial. Requiring the moving party to determine which documents are responsive out of a large archive is improper. Responding party has misinterpreted C.C.P. §2030.230 which permits referencing specific documents from which information responsive to an interrogatory can be derived. This section only applies, If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed The interrogatory here does not require a summary of information contained in the subject documents; it requests identification of the specific documents themselves.
The Court orders verified further responses to Subpart (d) which identify the specific documents that relate to each individual RFA.
The further responses are ordered to be served on the moving party electronically on or before June 26, 2026.
The Court grants the request for sanctions jointly and severally against Keshap, Karr Group and their counsel in the reduced amount of $2,562.50, payable withing 30 days.
Moving party is ordered to serve notice of the Courts ruling.
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