Plaintiffs Cheyenne Figueroa and Tatijana Tolerson (“Plaintiffs”) have brought this employment action against Defendants NBA Automotive, Inc. (“NBA Automotive”), Hooman Nissani (“Hooman”), Rayan Nissani (“Rayan”) and Does (collectively “Defendants”) for eleven causes of action.

On February 28, 2020, Plaintiffs filed the Motion to Compel Deposition of Defendant Hooman Nissani and Request for Sanctions.

On March 11, 2020, Plaintiffs filed the Motion to Compel Further Deposition and Further Response of Defendant Rayan Nissani and Request for Sanctions.

On March 13, 2020, Plaintiffs filed the Motion to Compel Deposition of Defendant NBA Automotive’s Person(s) Most Knowledgeable (“PMK”) and Request for Sanctions.

The Court considered the moving, opposition, and reply papers and rules as follows.

Motion to Compel Deposition Standard

C.C.P. §2025.450(a) provides that, "[i]f, after service of a deposition notice, a party to the action ... without having served a valid objection under Sec