21CV01245
BERONIO v. FELDSTEIN
MOTION TO COMPEL FURTHER DISCOVERY RESPONSES AND
SANCTIONS
BERONIO’S SPECIAL INTERROGATORIES NOS. 25, 26, 28, 29, 31, AND 32:
Plaintiff filed this motion on 9/14/22 seeking further responses to Plaintiff’s Beronio’s
special interrogatories at issue. These interrogatories seek all treatment and health care providers
for pain and suffering, emotional distress, and anxiety as alleged in Defendant’s cross-complaint.

(Baughman Decl. Ex. B) On 9/29/22, Defendant served verified Second Supplemental Responses
to those interrogatories, providing a substantive response. (Beck Decl. Ex. H)
Therefore, this motion is moot.
REQUEST FOR PRODUCTION NOS. 22 THRU 33:
This motion is granted provided the parties fashi