Nature of Proceedings: (4) Motions to Compel TENTATIVE RULING: For the reasons set forth herein, the motions are granted in part and denied in part. On or before January 29, 2021, defendant Shalini Ananda shall serve counsel for plaintiff Luca Foschini with verifications under penalty of perjury as to all supplemental responses previously served on counsel for Foschini as to plaintiffs’ first sets of special interrogatories, form interrogatories, requests for production of documents, and requests for admission. The motion is in all other respects denied. The denial of monetary sanctions in each motion is without prejudice to asserting a claim for monetary sanctions in a subsequent motion arising out of the same discovery at issue in these motions, which claim includes attorney fees and costs sought in these motions. Background: On February 14, 2019, plaintiff Luca Foschini filed his original complaint against defendant Shalini Ananda alleging causes of action for intentional infliction