Motion to Compel Deposition (Oral or Written)
The Motion by Defendants Kelly Nguyen and Cong Nguyen to compel answers to deposition questions is DENIED.
The dispute concerns the deposition of Plaintiff’s designated expert witness, Dr. Jeffrey Gross, and his refusal to answer certain questions at his 12/10/2019 deposition, pursuant to the instruction of Plaintiff’s counsel.
The motion to compel is not accompanied by the requisite separate statement that “provides all the information necessary to understand each discovery request and all the responses to it that are at issue,” “so that no person [including the Court] is required to review any other document in order to determine the full request and the full response.” Cal. R. Ct. Rule 3.1345(c). Even after Plaintiff pointed out this defect in his opposition, Defendants did not attempt to remedy it on reply. Defendants’ procedural violation is a sufficient basis for the court to decline to consider the motion. Mills v. U.S. Bank (2008) 1