O’BRIEN v. ROTTMAN

Case No.: PC-20190076    

(1) Plaintiffs’ Motion to Deem Admitted Requests for Admission.
(2) Plaintiffs’ Motion to Compel Responses to Requests for Production. (3) Plaintiffs’ Motion to Compel Responses to Interrogatories.
Plaintiff’s counsel declares: on June 1, 2020 form interrogatories, requests for production, and requests for admission were served on State Farm Insurance Company attorneys representing deceased defendant David Rottman’s estate in this action; unverified responses were served on plaintiff on June 22, 2020; defense counsel claimed that the defendant estate had no personal knowledge regarding the underlying facts; and despite a request for responses and production, deceased defendant David Rottman’s estate failed to provide verifications for the responses.
Plaintiff moves to compel answers to interrogatories and production of documents without objections; and to deem admitted the requests for admission. Plaintiff further requests an award of monetary sanctions in th........