Kelson v. Marriott International, Inc.

interrogatories of such breadth are proper in this case, an omission that reasonably suggests lack of a proper discovery objective.” (Id.) It states that “[t] he time available before the motion filing deadline, and the extent to which the responding party was complicit in the lapse of available time, can ... be relevant,” and that an “evaluation of whether, from the perspective of a reasonable person in the position of the discovering party, additional effort appeared likely to bear fruit, should also be considered.” (Id.) The “level of effort that is reasonable is different in different circumstances, and may vary with the prospects for success. These are considerations entrusted to the trial court’s discretion and judgment, with due regard for all relevant circumstances.” (Id. at 432-33.)

Plaintiff’s 1 1⁄2 page letter addressing her document demands, form interrogatories and requests for production of documents is not sufficient to comply with Plaintiff’s meet and confer obligation. The letter cites to no legal authority. Filing the motion without at least sending a follow-up email, letter or making a telephone call was premature and does not demonstrate a good faith effort pursuant to Code Civ. Proc., § 2016.040.

Therefore, the motion is denied for failure to properly meet and confer.

Defendant shall give notice.

5 First Foundation Inc. vs. Keller

2025-01493220 Motion to Compel Production

This is continued to June 29, 2026 at 1:30 p.m. Counsel are ordered to meet and confer by phone or in person on ALL outstanding discovery disputes (whether or not the discovery is currently the subject of a compel motion). This meet and confer shall include the subject of sanctions. The court will withhold its ruling on the June 1, 2026 submitted matter. Parties are to submit a joint statement regarding the meet and confer efforts specifically outlining which issues remain in dispute and why. This is to be filed no later than June 22, 2026.

Moving party will give notice 6 Kelson vs. Marriott International, Inc.

2021-01213506 Motion to Compel Plaintiff’s Compliance With This Court’s Order Dated 02/03/2026

The unopposed motion by Defendant Residence Inn by Marriott, LLC, erroneously sued and served as Marriot International, Inc. (“Moving Party”), for an order compelling Plaintiff Kathryn Kelson (“Plaintiff”)

to comply with the Court’s February 3, 2026 Order pursuant to CCP sections 128, subdivision (a)(4) and 2030.290 is GRANTED.

Pursuant to CCP section 2030.290, subdivision (c), if a party “fails to obey an order compelling answers, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010).” (Code Civ. Proc., § 2030.290, subd. (c).)

CCP section 128, subdivision (a)(4) provides the Court with the power to “compel obedience to its judgments, orders, and process, and to the orders of a judge out of court, in an action or proceeding pending therein.” (Code Civ. Proc., § 128, subd. (a)(4).)

Moving Party showed the Court issued an order on February 3, 2026 ordering Plaintiff to serve verified Code-compliant responses to Moving Party’s special interrogatories, set three, supplemental interrogatory, set one, and supplemental requests for production, set one within 15 days. (Hawatmeh Decl., ROA No. 277, ¶ 8, Exhibit 2.) Notice of ruling was served by mail on Plaintiff (Id., ¶¶ 8 and 13, Exhibit 3 and Exhibit 8; see, Proof of Service, ROA No. 264.)

Moving Party showed despite meeting and conferring with Plaintiff and resending the discovery at issue pursuant to Plaintiff’s requests, Plaintiff has not served any responses to the discovery at issue. (Hawatmeh Decl., ¶¶ 12, 14-16, and 18-21, Exhibit 7, Exhibit 9, Exhibit 10, Exhibit 11, Exhibit 12, and Exhibit 13.)

Moving Party described the Court’s prior order, which included monetary sanctions. (Hawatmeh Decl., ¶ 8, Exhibit 2.) Plaintiff paid the monetary sanctions (Hawatmeh Decl., ¶ 17.)

Unless Plaintiff shows compliance with the Court’s February 3, 2026 Order, Moving Party’s unopposed motion is granted. Plaintiff is once again ordered to serve verified Code-compliant responses to Moving Party’s special interrogatories, set three, supplemental interrogatory, set one, and supplemental requests for production, set one within 15 days.

In light of the Court’s 4/21/2026 Order granting Moving Party’s ex parte application to shorten time to hear this motion and to continue the trial date, Moving Party’s request to continue the trial is moot.

Moving Party shall give notice.