Motion Types Legal Issues

What is a Motion to Compel Responses to Request for Production of Documents?

Most Useful Motion to Compel Responses to Request for Production of Documents Examples

Recent Examples of Motion to Compel Responses to Request for Production of Documents

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CARRIEN QIAN HE, AN INDIVIDUAL VS JAY MIN CHEN, AN INDIVIDUAL, ET AL.

...______________________________________________________________________________ Plaintiff’s MOTIONS (1) TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; (2) TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; (3) FOR RELEASE OF DOCUMENTS PURSUANT TO SUBPOENA DUCES TECUM. Responding Party: Defendant/Cross-Complainant, Jay Min Chen Tentative Ruling (1) The motion to compel further responses to special interrogatories is GRANTED. Defenda...

...(2) The motion to compel further responses to request for production of documents is GRANTED as to Request for Production of Documents Nos. 1-4, 11-16, 18, 20-42, and 44, and DENIED as to Request for Production of Documents Nos. 5-10, 17, 19, 43, 45-55. Defendant is ordered to serve verified further responses to Request for Production of Documents Nos. 1, 3, 4, 11-16, 18, 20-42, and 44, inclusive, as stated ...

  • Hearing

    Feb 21, 2020

DEANNA AIVAZIAN VS. SARKIS TERSAKIAN ET AL

...Plaintiff: (1) a motion to compel initial responses to form interrogatories, set one (“FROG”), special interrogatories, set one (“SROG”), and requests for production of documents, set one (“RPD”); and (2) motion to deem the truth of matters specified in requests for admission, set one (“RFA”) admitted and conclusively established. On January 23, 2020, the Court denied Defendants’ “Ex Parte Application for an...

... Motion to Compel Response to Interrogatories and Request for Production”. The Court stated in its minute order that Plaintiff’s counsel represented that he provided responses to Defendants’ discovery requests. The Court’s minute order also reflected that Plaintiff’s counsel handed the discovery responses to defense counsel in open court. The Court encouraged defense counsel to take the discovery motions s...

  • Hearing

    Feb 21, 2020

CLAIRE LEVINE VS SYLVESTER STEWART, ET AL.

...Defendant Allan Law Group, P.C. Plaintiff’s motion to compel discovery responses is DENIED. Defendant’s request for sanctions is DENIED. PRELIMINARY COMMENTS: Although the Court is denying Plaintiff’s motion for the reasons stated below, the Court believes that Defense counsel is playing games by its blanket objections to relevant discovery and by not providing answers to legitimate interrogatories. The C...

...malicious prosecution claim and overruled the demurrer to the SAC for the abuse of process claim. Before the Court is Plaintiff’s motion to compel verified responses, or in the alternative, compel further responses, to special interrogatories set one. ANALYSIS: A. Relevant Law Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service...

  • Hearing

    Feb 21, 2020

SILVIA GUTIERREZ VS ADIDAS AMERICA INC

[TENTATIVE] ORDER RE: MOTION TO COMPEL COMPLIANCE WITH SUBPOENA; MOTION TO CONTINUE TRIAL On November 26, 2015, plaintiff Silvia Gutierrez (“Plaintiff”) was allegedly struck by a mannequin in one of Defendant’s stores. Plaintiff alleges s...

...Plaintiff filed suit on June 5, 2017. Motion to Compel Compliance Exodus Recovery/Lucy Estrada, M.D. (“Deponent”) is one of Plaintiff’s treating medical providers as identified in Plaintiff’s discovery responses. Plaintiff alleges she received psychological treatment as a result of her injuries. Defendant served a subpoena on Deponent but received no responsive documents. Accordingly, Defendant filed this mot...

  • Hearing

    Feb 21, 2020

ROBERT S. SHUMAKE LIVING TRUST 1994 VS JASON Q. WILSON TRUST DATED OCTOBER 18, 2007 ET AL

Nature of Proceedings: (4) Motions to Compel TENTATIVE RULING: For the reasons set forth herein, the motions of defendant Louis Armstrong and Associates, LLC, to compel further responses to written discovery from plaintiff Robert S. Shumake L...

...a.m. Background: On October 7, 2019, defendant Louis Armstrong and Associates, LLC, (LAA) served its first sets of special interrogatories, form interrogatories, requests for production of documents, and requests for admission on plaintiff Robert S. Shumake Trust (Shumake Trust). (E.g., Sandler decl. re special interrogatories, ¶ 2.) On November 12, 2019, counsel for Shumake Trust, attorney Rafael Bernardino...

  • Hearing

    Feb 21, 2020

LOUIS METOYER VS MARJORIE ANNE GUZMAN, ET AL.

Louis Metoyer v. Marjorie Anne Guzman, et al. MOTION TO COMPEL DEPOSITION OF LOUIS METOYER MOVING PARTY: Defendant Marjorie Anne Guzman RESPONDING PARTY(S): Plaintiff Louis Metoyer STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: This is a personal injury case...

...deposition. TENTATIVE RULING: Defendant Marjorie Anne Guzman’s motion to compel the deposition of Louis Metoyer is GRANTED. The deposition is to take place within 14 days of the date of this order. Plaintiffs’ request for sanctions is GRANTED in the amount of $1,055.00 against both Plaintiff Louis Metoyer and his counsel, the Law Offices of Jacob Emrani, jointly and severally. Sanctions to be paid to Defendant’s co...

  • Hearing

    Feb 21, 2020

CALIFORNIA MANUFACTURERS AND TECHNOLOGY ASSOCIATION VS. OFFICE OF ENVIRONMENTAL HEALTH HAZARD ASSESSMENT

... requests a hearing, they must follow the instructions at the end of this ruling. The Court notes that it is not available to hear this case on February 21, 2020, as originally scheduled. Should a hearing be requested, it will be held on March 13, 2020 at 1:30 p.m. If this date is not agreeable to the parties, they may contact the clerk to obtain a new hearing date. INTR...

...including altered cognitive development in children and increased cardiovascular risk factors in adults.” (Id.) Perchlorate inhibits iodide uptake into the thyroid gland, which, in turn, can cause decreased production of thyroid hormone. (Id.) This effect is described as “iodide uptake inhibition” or “IUI.” (AR 4576.) “[S]ome susceptible groups or individuals may have perchlorate-related effects at exposures that a...

  • Hearing

    Feb 21, 2020

LESLIE BLAKENEY VS SERGIO GARCIA

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving and opposing papers, the Court rules as follows. No reply papers were filed. BACKGROUND On August 1, 2018, Plaintiff Leslie Blakeney (“Plaintiff”) filed a...

...amended complaint to add a cause of action for fraud/intentional misrepresentation. On January 3, 2020, Defendants Sergio Garcia and Manuela T. Garcia filed a motion to compel Plaintiff to provide verified responses without objections to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) pursuant to California Code of Civil Procedure sections 2030.290 and 2031.300. Trial is s...

  • Hearing

    Feb 20, 2020

CHARLES KUTA V. COLORTOKENS, INC.

...alleging that Kuta failed to pay back a loan that was due when Kuta separated from employment with ColorTokens. Defendant ColorTokens served several discovery requests on Kuta and has filed the instant motion to compel further discovery responses. The requested responses are targeted at discovering information regarding Linkaj, a competing company ColorTokens alleges Kuta and several of his coworkers creat...

...referenced during your July 30, 2019 deposition. Defendant ColorTokens requests further responses to all of the requests for production of documents listed above. A motion for an order compelling further responses “shall set forth specific facts showing good cause justifying the discovery sought by the inspection demand.” (Code Civ. Proc., §2031.310, subd. (b)(1); Kirkland v. Sup. Ct. (2002) 95 Cal.App.4th 92, ...

  • Hearing

    Feb 20, 2020

ARSHA CORPORATION, A CALIFORNIA CORPORATION VS CEDARWOOD CAPITAL PARTNERS LA CIENGA, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY

Arsha Corp. v. Cedarwood Capital Partners La Cienega, LLC, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUESTS FOR ADMISSION, REQUESTS FOR PRODUCTION, DEPOSITION; SANCTIONS (CCP §§ 2030.290, 2031.300, 2033.380, 2025.450) TENTATIVE RULING: Plaintiff Arsha Corporation’s Motion For Order Compelling Defendant Cedarwood Capital Partners La Cienega, L...

...filed the instant Motion to Compel Discovery Responses and Motion to Compel Deposition on January 27, 2020. Defendant filed an opposition to the Motion to Compel Responses on February 5, 2020. Motion to Compel Responses to Discovery Requests Improper Combination of Multiple Discovery Motions Plaintiff’s Motion to Compel Discovery Responses attempts to combine multiple requests for relief into a single mot...

  • Hearing

    Feb 20, 2020

MARIA CANO VS GENERAL MOTORS, LLC, A DELAWARE LIMITED LIABILITY COMPANY

...2020 TENTATIVE: Plaintiff’s motion to compel further responses to form interrogatories is GRANTED as to 1.1, 15.1 and 17.1 and otherwise denied. Plaintiff is to provide notice and GM is to provide further, verified responses within 20 days. MOTION: Motion to Compel Further Responses to Requests for Production MOVING PARTIES: Plaintiff, Maria Cano OPPOSING PARTY: Defendant, General Motors, LLC PROOF OF SERVICE: OK OPP...

... requests: Form Interrogatories: 1.1, 12.1, 15.1, 17.1 Request for Production, 1, 3, 9, 16, 27, 32, 37-57, 63 Special Interrogatories: 1, 7, 14, 27, 42-46, 52-53 GM opposes each motion. MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES As a preliminary note, the court has reviewed each of the three motions to compel and it appears that each has the same procedural and meet and confer history. As such, the be...

  • Hearing

    Feb 20, 2020

IRMA MOJARRO ET AL VS CITY OF WHITTIER

...DENIED. III. Plaintiff’s Motion to Compel Further Responses to Request for Production of Documents (set four) is DENIED. IV. Plaintiff’s Motion to Compel Further Responses to Request for Production of Documents (set five) is DENIED. Opposing Party to give notice. “Except as provided in (b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a s...

...require a separate statement include a motion: (1) To Compel further responses to requests for admission; (2) To compel further responses to interrogatories…; (5) To compel or quash the production of documents or tangible things at a deposition…. (7) For issue or evidentiary sanctions.” (CRC Rule 3.1345(a).) “A separate statement is a separate document filed and served with the discovery motion that provide...

  • Hearing

    Feb 20, 2020

IPFS CORP VS CENTERPOINTE INSURANCE

..."defendants"): (1) Motion to Compel Centerpointe's Further Responses to Form Interrogatories (Set No. 1), and for $2,520 in Monetary Sanctions (Opposed); (2) Motion to Compel Centerpointe's Further Responses to Requests for Admissions (Set No. 1), and for $2,625 in Monetary Sanctions (Opposed); (3) Motion to Compel Centerpointe's Further Responses to Special Interrogator...

...Monetary Sanctions (Opposed); and (4) Motion to Compel Centerpointe's Further Responses to Requests for Production (Set No. 1), and for $2,505 in Monetary Sanctions (Opposed) Timeliness The motions were brought within the time required by the Discovery Act. Meet & Confer The Court finds that IPFS fulfilled its obligation to meet and confer in good faith in an effort to avoid these motions. De...

  • Hearing

    Feb 20, 2020

IPFS CORP VS CENTERPOINTE INSURANCE

..."defendants"): (1) Motion to Compel Centerpointe's Further Responses to Form Interrogatories (Set No. 1), and for $2,520 in Monetary Sanctions (Opposed); (2) Motion to Compel Centerpointe's Further Responses to Requests for Admissions (Set No. 1), and for $2,625 in Monetary Sanctions (Opposed); (3) Motion to Compel Centerpointe's Further Responses to Special Interrogator...

...Monetary Sanctions (Opposed); and (4) Motion to Compel Centerpointe's Further Responses to Requests for Production (Set No. 1), and for $2,505 in Monetary Sanctions (Opposed) Timeliness The motions were brought within the time required by the Discovery Act. Meet & Confer The Court finds that IPFS fulfilled its obligation to meet and confer in good faith in an effort to avoid these motions. De...

  • Hearing

    Feb 20, 2020

IPFS CORP VS CENTERPOINTE INSURANCE

..."defendants"): (1) Motion to Compel Centerpointe's Further Responses to Form Interrogatories (Set No. 1), and for $2,520 in Monetary Sanctions (Opposed); (2) Motion to Compel Centerpointe's Further Responses to Requests for Admissions (Set No. 1), and for $2,625 in Monetary Sanctions (Opposed); (3) Motion to Compel Centerpointe's Further Responses to Special Interrogator...

...Monetary Sanctions (Opposed); and (4) Motion to Compel Centerpointe's Further Responses to Requests for Production (Set No. 1), and for $2,505 in Monetary Sanctions (Opposed) Timeliness The motions were brought within the time required by the Discovery Act. Meet & Confer The Court finds that IPFS fulfilled its obligation to meet and confer in good faith in an effort to avoid these motions. De...

  • Hearing

    Feb 20, 2020

IPFS CORP VS CENTERPOINTE INSURANCE

..."defendants"): (1) Motion to Compel Centerpointe's Further Responses to Form Interrogatories (Set No. 1), and for $2,520 in Monetary Sanctions (Opposed); (2) Motion to Compel Centerpointe's Further Responses to Requests for Admissions (Set No. 1), and for $2,625 in Monetary Sanctions (Opposed); (3) Motion to Compel Centerpointe's Further Responses to Special Interrogator...

...Monetary Sanctions (Opposed); and (4) Motion to Compel Centerpointe's Further Responses to Requests for Production (Set No. 1), and for $2,505 in Monetary Sanctions (Opposed) Timeliness The motions were brought within the time required by the Discovery Act. Meet & Confer The Court finds that IPFS fulfilled its obligation to meet and confer in good faith in an effort to avoid these motions. De...

  • Hearing

    Feb 20, 2020

WIBERG V. JOHNSON

...contested when calling the Court and Counsel. ORDER GRANTING MOTION OF PLAINTIFFS TO DEEM REQUESTS FOR ADMISSIONS TO BE ADMITTED; COMPELLING DEFENDANTS TO RESPOND TO WRITTEN INTERROGATORIES, DOCUMENT PRODUCTION AND ORDERING GARY JOHNSON AND CONNIE BLUCK TO APPEAR FOR DEPOSITION I. Statement of Facts. Plaintiff filed this complaint on 26 April 2019.19 This is an action for breach of contract; breach of fid...

...for HoD Pros, Johnson reneged, depriving Plaintiffs of their promised compensation and purporting to grab a larger stake of HoD Pros for himself. On 2 July 2019, plaintiffs served upon HoD requests for production, requests for admissions; request for admission on genuineness; form interrogatories; and special interrogatories. The respondent has provided no response to these discovery devices. On 2 August 2019...

  • Hearing

    Feb 20, 2020

MONICA MARIE DE LA TORRE, ET AL. VS MUOI THI HUA, ET AL.

[TENTATIVE] ORDER RE: DEFENDANTS’ MOTION TO COMPEL PLAINTIFF KELLEY JEAN PHILLIPS’S RESPONSES TO DISCOVERY AND MONETARY SANCTIONS On May 23, 2019, Plaintiffs Monica Marie de la Torre and Kelley Jean Phillips (“Plaintiff”) filed this action against Defendants Muoi Thi Hua and Binh Dao (collect...

...demand for production of documents, and form interrogatories on Plaintiff. On November 13, 2019, Defendants sent a letter asking for the responses. Defendants received no responses. Defendants move to compel Plaintiff’s responses. Where a party fails to serve timely responses to discovery requests, the court may make an order compelling responses. (Code Civ. Proc., §§ 2030.290, 2031.300; Healthcare Consu...

  • Hearing

    Feb 20, 2020

CASHCALL, INC. VS LIZETT IBARRA

...calling the Court and Counsel. MOTION OF PLAINTIFF TO COMPEL DEFENDANT TO RESPOND TO FORM INTERROGATORIES (LIMITED CIVIL CASES), SET ONE; SPECIAL INTERROGATORIES, SET ONE; AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE I. Statement of Facts. Plaintiff filed this verified complaint on 12 March 2019 2019.17 This is an action for breach of contract and common counts. On 9 October 2019, plaintiff served defen...

...interrogatories and request for production of documents are due within 30 days after service. (Code of Civil Procedure, §§ 2030.260(a); 2031.260(a).) Moving party plaintiff does not seem to be pursuing the request for admissions at this time. The court must impose monetary sanctions against the losing party on a motion to compel responses to interrogatories and requests for production unless it finds that the o...

  • Hearing

    Feb 20, 2020

LLAMZON V. PEREZ-HIDROGO

...Salvardor Perez-Hidrogo’s unopposed Motion for Order Compelling Response to Request for Production and for an Order Imposing Monetary Sanctions of $519.00 is GRANTED. Plaintiff is ordered to provide verified responses, without any objections, to defendants’ request for production of documents, set one, within 10 days. Plaintiff is also ordered to pay monetary sanctions in the total amount of $346.00 to defendants. ...

...(CCP § 2031.260.) Defendants have demonstrated that they properly served plaintiff with requests for production of documents, set one, on October 18, 2019. Ex. A. Yet, plaintiff has failed to provide responses, even after defendants unilaterally extended the time for providing a response. Wood Decl., at ¶¶3 and 5; Ex. B. Given plaintiff’s complete lack of response, defendants are entitled to an order compel ...

  • Hearing

    Feb 20, 2020

DOUGLAS HART VS ALTA VISTA GARDENS, INC., ET AL.

...Plaintiff’s motions to compel Defendant/Cross-Defendant Alta Vista Gardens, Inc.’s responses to Form Interrogatories and Request for Production (Both Set One). On December 12, 2019, Plaintiff filed a motion for issue or evidentiary sanctions pursuant to California Code of Civil Procedure section 2023.030. Trial is set for December 7, 2020. PARTY’S REQUESTS Plaintiff asks the Court to order either: (1)...

...objection to discovery. Making an evasive response to discovery. Disobeying a court order to provide discovery. Making or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery. Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning d...

  • Hearing

    Feb 20, 2020

JAMES LEWALLEN, ET AL. VS DOES 1-100

James Lewallen, et al. v. Does 1 through 100 PLAINTIFFS’ MOTION TO COMPEL DEPOSITION OF THIRD-PARTY WITNESS AXIALL CORPORATION AS SUCCESSOR-IN-INTEREST TO SPECTRA-TONE PAINT AND PRODUCTION OF RECORDS; REQUEST FOR MONETARY SANCTIONS OF $2510.00 AGAINST AXIALL CORPORATION AND ITS COUNSEL OF RECORD POLSINELLI LLP AND SUSAN GILEFSKY MOVING PARTY: Plaintiffs James Lewallen and Carole Lewallen RESPONDING PARTY...

... production of documents and requests sanctions. TENTATIVE RULING: Plaintiffs James Michael Lewallen and Carole Lewallen’s motion to compel the deposition of third-party witness Axiall Corporation and its production of records is DENIED. Plaintiffs’ request for sanctions is DENIED. Axiall’s cross-request for sanctions is also DENIED. DISCUSSION: Motion To Compel Deposition and Production of Records Meet and C...

  • Hearing

    Feb 20, 2020

MAURO GASPAR CAMPOS ET AL VS LONG BEACH MEMORIAL CENTER ET A

...testified at his deposition. Plaintiffs’ counsel asked Defendant certain questions that Defendant upon instruction by his counsel did not answer. On January 17, 2020, Plaintiffs filed this motion seeking to compel Defendant to answer certain questions that refused to answer at his deposition along with reasonable follow-up questions. Plaintiffs also seek $7,831.20 in monetary sanctions. On February 5, 2020, De...

...Plaintiffs. On February 11, 2020, Plaintiffs filed their reply. MEET AND CONFER Defendant argues that that Court should deny Plaintiffs’ motion because of insufficient meet and confer efforts. A motion to compel answers for depositions questions must be accompanied by a declaration stating facts showing “a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” (Cod...

  • Hearing

    Feb 20, 2020

MARIA PINEDA VS N B & T INDUSTRIES, INC., A CORPORATION, ET AL.

Plaintiff’s motion to compel responses to form interrogatories, set two, and request for sanctions, is GRANTED. When a party to whom interrogatories are directed fails to respond, under CCP § 2030.290(b) a party propounding the interrogatories may move for an order compelling a respo...

...entitled to an order compelling responses. The motion to compel responses to form interrogatories, set two is GRANTED. Defendant N B & T Industries, Inc. is ordered to provide code-compliant, verified responses without objection within 10 days. Plaintiff’s request for sanctions is GRANTED in the reduced amount of $1,260 (4 hours at $300/hour plus $60 filing fee—see Yeroushalmi Decl.,. ¶ 9) against Defendant...

  • Hearing

    Feb 20, 2020

MATTER OF HELGE T GRAHN FAMILY TRUST

Nature of Proceedings: (1) Motion to Compel Production of Business Records (2) Petition to Determine Questions of Trust Construction Matter of Helge T. Grahn Family Trust, #19PR00160, Judge Sterne Hearing Date: February 20, 2020 Matter: Motion for Or...

...Petitioner: Diana B. Mercier (Reetz, Fox & Bartlett) For Trustee: Jana S. Johnston (Mullen & Henzell) Tentative Ruling: The court grants Petitioner Matthew A. Grahn’s motion to compel production of the requested business records specified in the November 5, 2019 subpoenas to Chase Bank and Wells Fargo Bank. Background and Petition: On April 25, 2019, petitioner Matthew A. Grahn (“Matthew”) filed a Petition...

  • Hearing

    Feb 20, 2020

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