Motion to Compel Further Responses to Special Interrogatories and Requests for Production of Documents and Request for Monetary Sanctions by Defendant Norcal CB- First Street, Inc. dba Coffee Bean & Tea Leaf

Factual and Procedural Background

This is a slip and fall case. On February 28, 2014, plaintiff Alexis Winter (“Plaintiff”) was a patron at a café commonly known as the Coffee Bean and Tea Leaf when she fell and suffered severe injuries while using the restroom. (First Amended Complaint [“FAC”] at ¶ 10.) The condition of the floor in the restroom caused Plaintiff to fall. (Ibid.) Plaintiff alleges that defendants occupied and controlled the subject premises. (Id. at ¶¶ 11, 17.) Plaintiff claims defendants were negligent by failing to use reasonable care to keep the property in a reasonably safe condition. (Id. at ¶ 18.)

The operative FAC alleges causes of action for negligence and premises liability. 2

Discovery Dispute

On October 15, 2018, defendant Norcal CB-First Street, In