The motion is denied in part and granted in part. The motion to compel further response to Request for Production No. (“RFP”) 18 is denied. The motion to compel further responses to all other RFPs is granted. The responses are to be provided without objection and within twenty (20) days of the hearing on this motion. The Court awards sanctions in the amount of $3,500.00 for attorneys’ fees and $900.00 for costs for a total of $4,400.00 to be paid within twenty (20) days of the date of the hearing on the motion. The proposed order will be signed after being modified to conform to the Court’s ruling. Plaintiff is to give notice pursuant to CCP 1019.5, forthwith.

Plaintiff Dawn Foote’s Third Amended Complaint against William Nielsen individually and as trustee alleges nine causes of action for: 1) breach of express contract, 2) declaratory relief, 3) intentional infliction of emotional distress (“IIED”), 4) negligent infliction of emotional distress (“NIED”), 5) partition, and 6) breach