Juan Rodriguez (“Plaintiff”) filed this action on July 3, 2019, against Shepard Enterprises, Inc. (“Shepard”) and James Shepard (collectively with Shepard, “Defendants”). Defendants filed an answer on September 20, 2019. The complaint alleges violations of the Labor Code and the Unfair Practices Act (Bus. & Prof. Code, § 17000, et seq.).
On September 20, 2019, Shepard served by mail a first set of form interrogatories and requests for production of documents (“RFPs”) on Plaintiff. Responses were due on October 25, 2019. (Code Civ. Proc., §§ 2030.260, 2031.260, 2016.050.) Prior to that Plaintiff requested, and was given, an extension to November 1, 2019. When no responses were provided on that date, Shepard’s counsel reached out to Plaintiff’s counsel on November 18, 2019 by email, but did not receive a reply. At the time of filing the motion (December 20, 2019), no responses had been provided. (Daner Decl., ¶¶ 2-6.)
Shepard now seeks to compel Defendant to comply with the RFPs. (Code C