Maria Manzano vs Mathias Morgan Management Company

Case No.: 37-2019-00061181-CU-OE-NC    

Plaintiff Maria Manzano ("Plaintiff")'s motion to compel Defendant Mathias Morgan Management Company, LLC ("Defendant") to provide further responses to Special Interrogatories (Set One) (the "Discovery Request"), and for sanctions, is granted. See Cal. Code Civ. P. §§ 2023.010(d), 2023.030(a), 2030.300(a), 2030.300(d).

The court declines to deny the motion on procedural grounds. Defendant's responses to the Discovery Request were not verified. "Unsworn responses are tantamount to no responses at all." Appleton v. Super. Ct. (1988) 206 Cal. App. 3d 632, 635-636 (citing Zorro Inv. Co. v. Great Pac. Sec. Corp. (1977) 69 Cal. App. 3d 907, 914). A separate statement need not accompany a motion to compel further responses to interrogatories when no response has been provided. See Cal. R. Ct. 3.1345(a)(2), (b)(1). The court will not deny the motion owing to alleged deficiencies in Plaintiff's separate statement when one was not required at all.

Nor will the c........