Motion to Compel Further Responses
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3. 25CV00993, Rhoades v. Girl of the Year, LLC.
Plaintiffs Johnnie Rhoades and Milesa Silva-Rhoades (“Plaintiffs”) move for an order pursuant to Code of Civil Procedure section 2030.300 et seq. to compel Defendants D2760 Santa S, LLC and D3145 Santa N, LLC (“Defendants”) to provide further responses to Plaintiffs’ first sets of special interrogatories, form interrogatories, and requests for admission. If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure fully to answer the interrogatories and requests for admissions. (Coy v. Sup.Ct. (Wolcher) (1962) 58 Cal. 2d 210, 220-221.)
On July 7, 2025, Plaintiffs served Defendants with special interrogatories, form interrogatories, and requests for admissions. (Fagan decl., ¶2.) Responses were provided except for responses to Plaintiff’s requests for admissions for defendant D3145 Santa N, LLC. (Ibid.)
In opposition, Defendants concede there is no defense to Plaintiffs’ motion. However, they request a continuance of this matter to allow them to provide supplemental responses. A continuance is not necessary. As Defendants have not justified their responses, the court will GRANT Plaintiffs’ motion. Defendants D2760 Santa S, LLC and D3145 Santa N, LLC are directed to provide further responses to Plaintiffs’ first sets of special interrogatories, form interrogatories, and requests for admission within 30 days of the service of this order. Plaintiffs’ counsel is directed to submit a written order to the court consistent with this ruling and in compliance with Cal. Rules of Court, Rule 3.1312.
4. 25CV04007, Pawlik v. Dupre
I. Motion to Compel Further Responses to Request for Production of Documents Plaintiff Christopher Pawlik (“Plaintiff”) moves for an order pursuant to Code of Civil Procedure section 2031.310 to compel Defendant Ernesto Ongaro & Sons, Inc. (“Defendant”) to serve further responses to Plaintiff’s Requests for Production, Set One. Plaintiff requests sanctions against Defendant and its counsel of record, Christina N. Muñoz, in the amount of $2,260.00.
1. CCP section 2031.310 A motion under section 2031.310 requires the moving party set forth specific facts showing good cause justifying the discovery sought by the demand. (Code Civ. Proc., § 2031.310
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2. Discovery Requests On July 17, 2025, Plaintiff served his first set requests for production on Defendant. (Kayne decl., ¶5.) The request seeks 21 categories of document production. (Id., Exhibit A.) This motion deals with Request Numbers 1, 3, 5, 11, 12, 13, 15, 16, 17, 20, and 21.
a. Request for Production, Numbers 1, 3 Plaintiff’s Request Number 1 seeks: “Any and all film and/or video footage in YOUR possession, custody, or control (or in the possession, custody, or control of YOUR agents) of Plaintiff Christopher Pawlik at any time.” Request Number 3 seeks: “Any and all photographs in YOUR possession, custody, or control (or in the possession, custody, or control of YOUR agents) of Plaintiff Christopher Pawlik at any time.” Subject to various objections, Defendant responded it would produce all non-privileged films and/or video responsive to the request. Defendant identified surveillance footage as privileged 5