ESPINO v. HUMASON II, INC., ET AL.

LAW AND MOTION CALENDAR APRIL 17, 2026

4. ESPINO v. HUMASON II, INC., ET AL., 25CV1572

(A) Motion to Compel

(B) Motion to Compel

(C) Motion to Compel

On August 28, 2025, Plaintiff served Form Interrogatories, Special Interrogatories,

and Request for Production of Documents. (Arakelyan Decl. ¶ 3.) The parties previously

agreed to several discovery extensions and were engaged in informal settlement

negotiations, which included an agreement to stay discovery. (Catalano Decl. ¶¶ 3-19.) Defendant served verified, code-compliant responses to Plaintiff’s Form

Interrogatories – Employment, Set One, Special Interrogatories, Set One, and Plaintiff’s

Request for Production of Documents, Set One on April 6, 2026. (Catalano Decl. ¶ 22.)

Plaintiff’s Motions do not comply with Local Rule 7.10.05. Repeated failure to

comply with the requirements of the Local Rules may result in sanctions, pursuant to

Local Rule 7.12.13.

The Court finds that Plaintiff’s counsel failed to satisfy the requirements of

§ 2016.040(a) of the Code of Civil Procedure (“CCP”) which requires: “A meet and confer

declaration in support of a motion shall state facts showing a reasonable and good faith

attempt, either in person, by telephone, or by videoconference, to informally resolve

each issue presented by the motion.” Plaintiff sent two e-mails indicating that responses

were due but did not make any further attempts. The Court would generally require the parties to further meet and confer before hearing the Motions, but Defendant has since

served responses, so the Motions are moot.

In terms of sanctions, the Court finds that the imposition of sanctions would be

unjust, as Plaintiff failed to comply with the requirements of CCP § 2016.040