Before the Court are four motions filed by plaintiff Myra Decarolis (“Plaintiff”). Plaintiff seeks an order compelling defendant William Gonzalo Patron (“Defendant”) to provide further responses to: (1) Form Interrogatories, Set One; (2) Special Interrogatories, Set One; (3) Requests for Production, Set One; (4) Requests for Admission, Set One
A motion to compel must be filed within 45 days of service of a verified response, “or on or before any specific later date to which the propounding party and the responding party have agreed in writing.” (CCP §§ 2030.300(c) [interrogatories], 2033.290(c) [requests for admission], 2031.310(c) [requests for admission].)
Plaintiff argues that the motions are timely filed because of an agreement to which the parties allegedly entered. On 3/16/20, Plaintiff’s counsel sent a letter to Defendant’s counsel, stating, in part, as follows: “During our period of remote work, we will therefore transition all of our correspondence and service of discovery and