Motion to Compel Plaintiff’s Response to Request for Production; Motion to Compel Plaintiff’s Response to Special Interrogatories; Motion to Compel Plaintiff’s Response to Form Interrogatories
(49) Tentative Ruling
Re: Meza v. City of Sanger et al. Superior Court Case No. 24CECG03246
Hearing Date: June 4, 2026 (Dept. 502)
Motion: 1) By Defendants to Compel Plaintiff’s Response to City of Sanger’s Request for Production of Documents to Plaintiff, Set One, and Request for Sanctions; 2) By Defendants to Compel Plaintiff’s Response to City of Sanger’s Special Interrogatories to Plaintiff, Set One, and Request for Sanctions; 3) By Defendants to Compel Plaintiff’s Response to City of Sanger’s Form Interrogatories to Plaintiff, Set One, and Request for Sanctions
Tentative Ruling:
To grant defendants’ motions to compel plaintiff’s responses to City of Sanger’s Request for Production of Documents to Plaintiff, Set One, City of Sanger’s Special Interrogatories to Plaintiff, Set One, and City of Sanger’s Form Interrogatories to Plaintiff, Set One. Plaintiff is ordered to serve verified responses, without objections, and produce all responsive documents, within 30 days of the clerk’s service of the minute order.
To impose monetary sanctions in favor of defendants and against plaintiff Pablo Meza. (Code Civ. Proc., §§ 2023.010, subd. (d), 2030.290, subd. (c), 2031.300, subd. (c).) Plaintiff is ordered to pay $650 in sanctions to Longyear, Lavra & Cahill, LLP, within 30 days of the clerk’s service of the minute order.
Explanation:
Compel Responses
Defendants City of Sanger and Daniel Joseph Battenfield (“Defendants”) move to compel initial responses from plaintiff Pablo Meza (“Plaintiff”) for City of Sanger’s Request for Production of Documents to Plaintiff, Set One, City of Sanger’s Special Interrogatories to Plaintiff, Set One, and City of Sanger’s Form Interrogatories to Plaintiff, Set One (collectively “Set One”).
Responses to interrogatories and requests for production are due within 30 days after service. (Code Civ. Proc., §§ 2030.260, subd. (a), 2031.250, subd. (a).) If the party fails to serve responses, that party waives all objections to the interrogatories or request for production. (
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On December 3, 2025, Defendants served Set One on Plaintiff. (Kern Decl., ¶ 2.) As of April 6, 2026, Plaintiff has not sent responses to Set One. (Id., ¶ 8.) Plaintiff does not
dispute that responses to Set One were not timely served and are owed. Accordingly, Defendants motions to compel responses to Set One are granted.
Sanctions
When a motion to compel responses is filed, the court shall impose monetary sanctions against the losing party unless there was substantial justification. (Code Civ. Proc., §§ 2023.010, subd. (d), 2030.290, subd. (c), 2031.300, subd. (c).) The court may require a party who misuses the discovery process to “pay the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct.” (Id., § 2023.030, subd. (a).) Misuse of the discovery process includes failing to respond to discovery. (Id., § 2023.010, subd. (d).)
Defendants are seeking sanctions in the amount of $1,635 based on five hours of work by a paralegal at $150 an hour and 3 hours of work by an attorney at $275 an hour1. Plaintiff disputes the amount as excessive. Plaintiff argues that the motion is a routine, noresponse discovery motion. The motion to compel initial responses is not complex and does not require substantial legal research or complex analysis. Accordingly, Defendants request for sanctions is granted but reduced. Plaintiff is ordered to pay $650 in reduced sanctions to Longyear, Lavra & Cahill, LLP, within 30 days of the service of the minute order.
Pursuant to California Rules of Court, rule 3.1312(a), and Code of Civil Procedure section 1019.5, subdivision (a), no further written order is necessary. The minute order adopting this tentative ruling will serve as the order of the court and service by the clerk will constitute notice of the order.
Tentative Ruling
Issued By: KCK on 06/03/26. (Judge’s initials) (Date)
1 Defendants are also seeking recovery of $60 for filing costs. Records show no payment, likely
due to government exemption. (Gov. Code, § 6013.)
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