Christopher Siraganian, et al. v. Stillwater Insurance Co., et al.

Plaintiff incorrectly filed the instant motion under the docket for instant case, case no. 24NNCV04195, and not the Related Case. Likewise, Plaintiff incorrectly claims that the Court "consolidated" the instant case and the Related Case. (Glover Decl., P. 2.)

Plaintiff believed that the Court's order meant the cross-complaint in the Related Case was automatically absorbed into the instant action. (Glover Decl., P. 2.) However, in its July 1, 2026 Minute Order, the Court stated that it found the cases to be related within the meaning of California Rules of Court, rule 3.300(a). The Court did not "consolidate" the matters and their respective dockets into one action.

The Related Case involves Plaintiff and Toi, a separate entity who is not a party to the instant action. In the Related Case, the Court entered judgment in favor of Toi against Plaintiff. Plaintiff filed proof of service on Defendant, but Plaintiff has not filed proof of service on Toi. Defendant notes in opposition that it responds to the instant motion solely because Plaintiff filed it in this action, but states that it is not a party to the Related Case. (Opp., 2:11-19.)

Toi has yet to be properly served with notice of the instant motion. Therefore, the party who obtained default remains unserved without notice of the motion. Accordingly, the Court denies the instant motion and directs Plaintiff to file the motion in the proper action and properly serve the correct party to give them notice and opportunity to respond before it is considered on its merits.

CONCLUSION

Based on the foregoing, the Court DENIES Plaintiff Nicholas Glover's motion to vacate and set aside entry of default. Moving party is ordered to give notice of this ruling. IT IS SO ORDERED. DATED: September 8, 2026 _____________________________ Sarah J. Heidel Judge of the Superior Court

County of Los Angeles - NORTHEAST District Department V Christopher Siraganian, Caroline McLoughlin, Plaintiffs, vs. Stillwater Insurance Co. and DOES 1 through 10, Defendants. |

Case No.: |

| | | Hearing Date: | September 8, 2026 | | | Time: | 8:30 a.m. | | | [Tentative] Order RE: MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET FOUR | MOVING PARTY: Plaintiff Christopher Siraganian RESPONDING PARTY: Defendant Stillwater Insurance Company The Court considered the moving papers, opposition, and reply filed in connection with the instant motion.

BACKGROUND

On March 10, 2025, Plaintiffs Christopher Siraganian ("Plaintiff") and Caroline McLoughlin (collectively, "Plaintiffs") brought this action against Defendant Stillwater Insurance Company ("Defendant"), alleging causes of action for (1) breach of contract, (2) breach of statutory duty, (3) breach of the covenant of good faith and fair dealing, (4) fraud, (5) negligence, and (6) intentional infliction of emotional distress. The causes of action arise out of an insurance claim dispute after Defendant alleged declined coverage for Plaintiffs' loss of their home in the Eaton Fire.

On September 30, 2025, Plaintiffs filed a first amended complaint. On January 23, 2026, Plaintiffs filed their second amended complaint, alleging causes of action for (1) breach of contract, (2) breach of statutory duty, (3) breach of the covenant of good faith and fair dealing, (4) constructive fraud, and (5) negligence misrepresentation.

On June 23, 2026, Plaintiff filed the instant motion to compel further responses to Special Interrogatories, Set Four (the "SROGs"), from Defendant. On August 25, 2026, Defendant filed an opposition. On August 26, 2026, Plaintiff filed a reply.

LEGAL STANDARD

Within 30 days after service of interrogatories, the responding party must serve responses unless otherwise stipulated or ordered. (Code Civ. Proc., Sec. 2030.260, subd. (a).) Code of Civil Procedure section 2030.300 provides that a propounding party may move for an order compelling further responses if: (1) an answer is evasive or incomplete; (2) the exercise of option to produce documents is unwarranted or inadequate; or (3) an objection is without merit or too general. (Code Civ. Proc., Sec. 2030.300, subd. (a).)

If a party fails to timely respond, objections are waived unless the court relieves the waiver upon a showing of mistake, inadvertence, or excusable neglect and a subsequently served compliant response. (Code Civ. Proc., Sec. 2030.290.) A motion to compel further responses must be brought within 45 days of service of verified responses. (Code Civ. Proc., Sec. 2030.300, subd. (c); Sexton v. Superior Court (1997) 58 Cal.App.4th 1403, 1409; Vidal Sassoon, Inc. v. Superior Court (1983) 147 Cal.App.3d 681, 685.)

DISCUSSION

A. Timeliness

On February 27, 2026, Plaintiffs served the SROGS on Defendant. (Hancock Decl., P. 3, Exh A.) On May 6, 2026, Defendant served responses. (Hancock Decl., P. 4, Exh. C.) Plaintiffs had 45 days, plus two additional days for electronic service, to file motions to compel further responses. (Code Civ. Proc., Sec. 1010.6, subd. (a)(3)(B).) The motion filed June 23, 2026 is therefore timely.

B. Separate Statement

California Rules of Court, rule 3.1345 requires a separate statement for motions to compel further responses. Plaintiff filed a separate statement that includes references to counsel's declaration and the exhibits attached thereto. "The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference." (Cal. Rules of Court, rule 3.1345(c).) Despite the deficiency, the court turns to the merits of the motion.

C. Meet and Confer

A motion to compel further responses must be accompanied by a meet and confer declaration showing a reasonable and good faith effort to resolve the dispute. (Code Civ. Proc., Sec. 2016.040; Sec. 2030.300, subd. (b)(2).) The parties satisfied this requirement. (Hancock Decl., P. 6.)

D. SROGs

Plaintiff seeks a further response to Interrogatory Nos. 69, 70, 71, and 72. Defendant served further responses on August 25, 2026. (Yu Decl., P. 10, Exh. D.) Courts are not precluded from considering a motion to compel further responses when the responding party serves further responses after a motion to compel further is brought. (Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 407.) Plaintiff argues the further responses do not resolve the issues raised in the motion. (Reply, p. 2.) Therefore, the Court continues to analyze the merits of the motion.

SROG No. 69

This interrogatory is vague, ambiguous, and speculative in the phrase "made the determination." Motion denied.

SROG No. 70

Defendant's further response is sufficient. Defendant explains that it is not aware of any person who directed it to change the "bill to." Motion denied.

SROG No. 71

Defendant's further response is sufficient. Defendant explains that the Offer of Renewal was transmitted by Assurant, and details how the transmission occurred. Motion denied.

SROG No. 72

This interrogatory is vague and ambiguous as to "each and every person that lead Stillwater to believe that Assurant was responsible." Motion denied.

E. Sanctions

Code of Civil Procedure section 2023.030 authorizes monetary sanctions for misuse of the discovery process. Sanctions are not warranted against Defendant because the motions were denied as Defendant provided proper responses and objections. However, "[t]he court shall impose a monetary sanction ... against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, 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." (Code Civ. Proc., Sec. 2030.300, subd. (d).)

Here, Plaintiff unsuccessfully makes this motion to compel further responses without substantial justification. Defendant's counsel requests $1,770.00 in sanctions for five hours of attorney work preparing the opposition to Plaintiff's motion and an anticipated hour reviewing the reply brief and attending the hearing on the instant motion at a billable rate of $295.00 per hour. (Yu Decl., P.P. 13-14.) The Court finds the hourly rate reasonable but reduces the time claimed due to the motion's lack of complexity. The Court awards sanctions in the reduced amount of $590.00 for two hours of attorney work. Sanctions are imposed jointly and severally against Plaintiff and counsel of record.

CONCLUSION

Based on the foregoing, the Court DENIES Plaintiff's motion to compel further responses to Special Interrogatories, Set Four, Nos. 69, 70, 71, and 72. Monetary sanctions are imposed against Plaintiff and counsel of record, jointly and severally, in the amount of $590.00, payable to counsel for Defendant within 20 days of notice of this order. Moving party is ordered to give notice of this ruling. IT IS SO ORDERED. DATED: September 8, 2026 _____________________________ Sarah J. Heidel Judge of the Superior Court Case Number: 26NNCV02311 Hearing Date: September 8, 2026 Dept: V Superior Court of California County of Los Angeles - NORTHEAST District Department V NGOZI KIM UDENKWO, Plaintiff, vs. CHRIS LE FEUVRE, Defendant. | Case