CASE NAME: Beata Sadurska v. Thomas Calus, et al.

CASE NO.: 19SMCV01885

MOTION: Motions to compel initial responses to Plaintiff’s RFPs set two, sanctions (COMBINED)

HEARING DATE: 08/04/2021

Legal Standard

If a party failed to respond to a document inspection demand, “[t]he party making the demand may move for an order compelling response to the demand.” (Code Civ. Proc., § 2031.300(b).) When a party fails to respond to document production request, the party “directed waives any objection to the demand, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018.010).” (Code Civ. Proc., § 2031.300(a).) “The party to whom the demand for inspection, copying, testing, or sampling is directed shall sign the response under oath unless the response contains only objections.” (Code Civ. Proc., § 2031.250(a).) “[T]he court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person,