RAYMOND VINCENT DIGIACOMO JR. VS. HEALTHRIGHT 360 ET AL

SF Superior Court - Law & Motion / Discovery Dept 301 - CGC22601012 - November 19, 2025 Hearing date: November 19, 2025 Case number: CGC22601012 Case title: RAYMOND VINCENT DIGIACOMO JR. VS. HEALTHRIGHT 360 ET AL Case Number: | | CGC22601012 | Case Title: | | RAYMOND VINCENT DIGIACOMO JR. VS. HEALTHRIGHT 360 ET AL | Court Date: | | 2025-11-19 09:00 AM | Calendar Matter: | | Notice Of Motion And Motion For Order Compelling Defendant Denise Williams To Further Respond To Dfp1 And Request For Monetary Sanction | Rulings: | | On the Law and Motion/Discovery calendar for November 19, 2025, line 3. PLAINTIFF RAYMOND DIGIACOMO'S Motion For Order Compelling Defendant Denise Williams To Further Respond To Dfp1 And Request For Monetary Sanction.

Plaintiff Raymond Vincent DiGiacomo, Jr.'s motion for an order requiring defendant Denise Williams to further respond to his first request for production of documents is denied. DiGiacomo's RFP No. 1 requests all documents identified by Williams in response to Form Interrogatory 17.1(d). Williams responded that no documents were identified. (DiGiacomo Decl., Ex. 3; see also id., Ex. 5 [form interrogatory responses].) This response is full and complete. Williams is not relying on documents for her denial of DiGiacomo's requests for admission. No further response is required.

Ordinarily a party would be required to report whether documents previously existed and were destroyed, but this RFP is in the nature of contention discovery that ascertains what a party is relying on (and might introduce at trial) in support of a particular litigating position. The court concludes these responses substantially comply with the relevant statutes.

DiGiacomo also requests an order requiring Williams to replace her electronically signed verification with a wet signature. The court denies this request for the reasons stated in its prior discovery order: electronic signatures are as binding as ink signatures where a party intends them to be, and the fact that Williams placed an electronic signature on a verification sufficiently indicates her intent to be bound. (See Civ. Code, sections 1633.7 & 1633.9.)

The court denies sanctions, concluding that DiGiacomo's position with respect to the content of the response had substantial justification in Code of Civil Procedure, section 2031.230, and his continued insistence on a wet signature predated the court's previous order rejecting this request.

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