Motion to compel further responses to requests for production
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Case No:
Hearing Date: May 19, 2026 Calendar Number: 6 Plaintiff P&P Broadway, LLC (“Plaintiff”) moves to compel Defendants Abode LA, LLC, Alexsandra Watkinson, and Tobin Watkinson’s (“Defendants”) further responses to its requests for production, set one. Plaintiff’s motion is DENIED as moot. Plaintiff’s request for sanctions is DENIED.
Background
Plaintiff alleges that it entered into a lease with Defendants as tenants on or about June 15, 2022. Plaintiff alleges that Defendants breached the Lease by failing to pay all rent that became due in the total amount of $160,000. On May 23, 2025, Plaintiff filed the First Amended Complaint (“FAC”) for Breach of Lease.
On March 30, 2026, Adobe LA, LLC filed a cross-complaint against P&B Broadway, LLC alleging causes of action for breach of contract, and declaratory relief. Cross-Complainant Abode alleges it was to lease 6 residential dwelling units (traditional apartments) at 735 So. Broadway to rent out on a short-term basis to transient tenants for less than 30 days in consideration for the payment of rent, as specified in the lease. Cross-Complainant alleges Defendant breached by failing to obtain the requisite permits from the City of Los Angeles allowing for the demised premises to be used for short-term rentals to transient tenants; and because the Certificate of Occupancy that was obtained was void because the authorized use of the demised premises under the Certificate of Occupancy ("Apartment-Hotel") was not consonant with the actual use to which the demised premises were put ("Short-Term Rental Use").
On February 4, 2026, the Court held an Informal Discovery Conference, and based on the parties’ agreement, ordered Defendant to produce all responsive documents by February 23, 2026. On February 20, 2026, Plaintiff filed these three motions to compel further responses to requests for production. On May 6, 2026, Defendants filed an Opposition. No Reply has been filed as of May 13, 2026. (The Reply was due on May 12, 2026.)
Legal Standard
C.C.P. §2031.310 provides, in pertinent part, as follows: (a) On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete. (2) A representation of inability to comply is inadequate, incomplete, or evasive. (3) An objection in the response is without merit or too general.
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(b) A motion under subdivision (a) shall comply with each of the following: (1) The motion shall set forth specific facts showing good cause justifying the discovery sought by the demand. (2) The motion shall be accompanied by a meet and confer declaration under Section 2016.040. (3) In lieu of a separate statement required under the California Rules of Court, the court may allow the moving party to submit a concise outline of the discovery request and each response in dispute.
(c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the demanding party and the responding party have agreed in writing, the demanding party waives any right to compel a further response to the demand.
(h) Except as provided in subdivision (j), the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response to a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.
A motion to compel further production must set forth specific facts showing good cause justifying the discovery sought by the inspection demand. (See Code Civ. Proc., § 2031.310(b)(1).) It is not necessary for the motion to show that the material sought will be admissible in evidence. “Good cause’ may be found to justify discovery where specific facts show that the discovery is necessary for effective trial preparation or to prevent surprise at trial. (See Associated Brewers Dist. Co. v. Superior Court (1967) 65 Cal.2d 583, 586-588; see also CCP §§ 2017.010, 2019.030(a)(1) (Information is discoverable if it is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence and it is not unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome, or less expensive.); Lipton v.
Superior Court (1996) 48 Cal.App.4th 1599, 1611-1612 (noting a party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence).)
If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure fully to answer. (See Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98 (addressing motion to compel further responses to demand for production of documents).)
Discussio n
Plaintiff seeks Defendants’ further responses to its Request for Production, Set One, Nos. 1-11, 14, 16, 17-18, 20, 23-24. The Court notes that Defendants were ordered to provide responses by February 23, 2026, but Plaintiff filed this motion three days before, on February 20, 2026.
In opposition, Defendants argue that 1,400 documents were produced on February 23, 2026. Defendants contend that Plaintiff has never objected that the documents were not responsive to its requests. Plaintiff has failed to file a Reply indicating what documents, if any, it believes are still at issue. Thus, based on the current record, it appears the motions are MOOT.
Sanctions
Plaintiff requests sanctions. The request is denied as the motion was filed before the agreed upon production date and no Reply has been filed indicating what documents are still at issue. Thus, it appears the motions were not necessary.
Case Number: 25STCV14772 Hearing Date: May 19, 2026 Dept: 731 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES DEPARTMENT 731 TENTATIVE RULING BUILDERS FENCE COMPANY, INC., Plaintiff, v. SOCAL CONTRACTING SERVICES, et al. Defendants.