MOVING PARTY: Defendant Tuy Dang Pham dba Velvet Nails
RESPONDING PARTY: None
(1) Motion to Compel Responses to Form Interrogatories (Set One)
(2) Motion to Compel Responses to Special Interrogatories (Set One)
(3) Motion to Compel Responses to Demand for Identification and Inspection of Documents (Set One)

The court considered the moving papers.
BACKGROUND
On July 19, 2017, plaintiff Jolanta Bojarski filed a complaint against defendant Pham Tuy dba Velvet Nails for general negligence. She alleges that in September 2015, defendant’s tools and facilities to perform manicures and pedicures on plaintiff were contaminated with an infectious fungus. She contracted a serious fungal infection in the nails of her fingers and toes that proved difficult and expensive to treat.
On January 29, 2018, plaintiff’s counsel filed a motion to be relieved as counsel, set for March 13, 2018.
Trial is set for January 22, 2019.
LEGAL STANDARD
Interrogatories
If a party to whom interrogatories are directed