Motion to Compel Responses to Special Interrogatories; Motion to Compel Production of Documents
DEPARTMENT 731 LAW AND MOTION RULINGS WEST CASITAS, LLC, Plaintiff, v. SWING HOUSE STAGES, INC., Defendant. Case No:
Hearing Date: May 18, 2026 Calendar Number: 1 Judgment Creditors Kanon Ventures, LLC, Mark Beskind, Jeff Stauffer, Ara Tavitian, and Avedis Tavitian move to compel Judgment Debtors Swing House Stages, Inc. and Genoveva Winsen’s responses to Special Interrogatories, and Demand for Production, Sets One. Judgment Creditors also seek $2,055 in sanctions against each Judgment Debtor. Judgment Creditors? Motions to Compel Responses to Special Interrogatories and Request for Production of Documents are GRANTED.
Judgment Debtors Swing House Stages, Inc. and Genoveva Winsen are ordered serve verified responses to the discovery requests without objections within 20 days of this order. Judgment Creditors’ request for sanctions is GRANTED in a reduced amount. Judgment Debtor Swing House Stages, Inc. is ordered to pay sanctions in the amount of $685 to Judgment Creditors’ counsel within 20 days of this order. Judgment Debtor Genoveva Winsen is ordered to pay sanctions in the amount of $685 to Judgment Creditors’ counsel within 20 days of this order.
Judgment Creditors are ordered to pay to the court a $120 filing fee.
Background
On October 14, 2021, West Casitas, LLC, filed a Complaint against Swing House Stages, Inc. On March 28, 2022, Cross-complainants Swing House Stages, Inc., and Genoveva Winsen filed a Cross-Complaint against Cross-Defendants West Casitas, LLC, Kanon Ventures, LLC, Ara Tavitian, Avedis Tavitian, Jeff Stauffer, and Mark Beskind. On August 9, 2023, the Court entered judgment in favor of Cross-Defendants/ Judgment Creditors Kanon Ventures, LLC, Mark Beskind, Jeff Stauffer, Ara Tavitian, and Avedis Tavitian. On December 14, 2023, the Court granted Judgment Creditors’ motion for attorney fees and awarded them $326,469.76 in attorney’s fees and costs against Judgment Debtors Swing House Stages, Inc. and Genoveva Winsen.
Legal Standard
A judgment creditor may propound written interrogatories to the judgment debtor in the manner provided by Section 2030.010, et seq. (Code Civ. Proc., 708.020, subd. (a).) Interrogatories pursuant to this section may be enforced, to the extent practicable, in the same manner as interrogatories in a civil action. (Code Civ. Proc., § 708.020
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Proc., § 708.030, subd. (a).) Inspection demands served pursuant to this section may be enforced in the same manner as demands in a civil action. (Code Civ. Proc., § 708.030, subd. (c) .) A party must respond to interrogatories and requests for production of documents within 30 days after service. (Code Civ. Proc., § 2030.260, subd. (a); Code Civ. Proc., § 2031.260, subd. (a).) If a party to whom interrogatories or requests for production of documents are directed does not provide timely responses, the requesting party may move for an order compelling responses to the discovery. (Code Civ.
Proc., § 2030.290, subd. (b); Code Civ. Proc., § 2031.300, subd. (c).) The party also waives the right to make any objections, including one based on privilege or work-product protection. (Code Civ. Proc., § 2030.290, subd. (a); Code Civ. Proc., § 2031.300, subd. (a).) There is no time limit for a motion to compel responses to interrogatories or production of documents other than the cut-off on hearing discovery motions 15 days before trial. (Code Civ. Proc., §§ 2024.020, subd. (a), 2030.290; Code Civ.
Proc., § 2031.300.) No meet and confer efforts are required before filing a motion to compel responses to the discovery. (Code Civ. Proc., § 2030.290; Code Civ. Proc., § 2031.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.) The court shall impose a monetary sanction against any person who unsuccessfully makes or opposes a motion to compel a response to interrogatories, or request for production, unless that party acted with substantial justification or that other circumstances make the imposition of the sanctions unjust. (Code Civ.
Proc., §§ 2030.290, subd. (c), and 2031.300, subd. (c).) California Rules of Court, rule 3.1348(a) provides: “The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed.”
Discussion
On November 5, 2025, Judgment Creditors served Judgment Debtors with Special Interrogatories, Set One, and Demand for Production of Documents, Set One. (Wallin Decl., ¶¶ 4, 6; Exhs. A-B.) No responses were provided. (Id., ¶ 8.) Based on the foregoing, Judgment Creditors are entitled to an order that Judgment Debtors serve verified responses to the discovery requests without objections. (Code Civ. Proc., §§ 708.020, 708.030.) Sanctions As Judgment Debtors failed to provide responses to the discovery and failed to provide substantial justification for the failure to respond, sanctions are warranted.
However, the amount sought is excessive given the simplicity of these unopposed motions. As such, Judgment Creditors’ request for sanctions is granted in the reduced amount of $685 ($685 per hour, for one hour), against each Judgment Debtor, to be paid within 20 days of this order. Further, Judgment Creditors have filed only two motions, seeking four sets of discovery. As a result, Judgment Creditors have only paid for two filing fees, and must pay $120 to the court for the filing fee of the additional two motions it failed to file.
Accordingly, Judgment Creditors? Motions to Compel Responses to Special Interrogatories and Request for Production of Documents are GRANTED. Judgment Debtors Swing House Stages, Inc. and Genoveva Winsen are ordered serve verified responses to the discovery requests without objections within 20 days of this order. Judgment Creditors’ request for sanctions is GRANTED in a reduced amount. Judgment Debtor Swing House Stages, Inc. is ordered to pay sanctions in the amount of $685 to Judgment Creditors’ counsel within 20 days of this order.
Judgment Debtor Genoveva Winsen is ordered to pay sanctions in the amount of $685 to Judgment Creditors’ counsel within 20 days of this order. Home -->)" -->