JOANNE KLUCK VS. FREUD FELIX FARLEY ET AL

SF Superior Court - Law & Motion / Discovery Dept 302 - CGC23610866 - June 27, 2025 Hearing date: June 27, 2025 Case number: CGC23610866 Case title: JOANNE KLUCK VS. FREUD FELIX FARLEY ET AL Case Number: | | CGC23610866 | Case Title: | | JOANNE KLUCK VS. FREUD FELIX FARLEY ET AL | Court Date: | | 2025-06-27 09:00 AM | Calendar Matter: | | Notice Of Motion And Motion To Compel Donna Lee Farleys Answers To Request For Production Of Documents, Tangible Things, And Esi, Production Of Requested Documents And For Sanctions | Rulings: | | Matter on calendar for Friday, June 27, 2025, Line 7, PLAINTIFF JOANNE KLUCK's, Motion To Compel Donna Lee Farleys Answers To Request For Production Of Documents, Tangible Things, And ESI, Production Of Requested Documents And For Sanctions. (Part 1 of 2).

3 - Plaintiff's Motion To Compel from Defendant Donna Lee Farley Further Responses to Requests for Admissions and For Sanction is GRANTED. Answers to RFAs are to be "as complete and straightforward as the information reasonably available. . . permits." (Code of Civil Procedure section 2033.220(a).)

When the response is an answer to the substance of the request, the answer must: (1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party. (2) Deny so much of the matter involved in the request as is untrue. (3) Specify so much of the matter involved in the request as to the truth of which the responding party lacks sufficient information or knowledge. (Code of Civil Procedure section 2033.220(b).)

"On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (1) An answer to a particular request is evasive or incomplete. (2) An objection to a particular request is without merit or too general." (Code of Civil Procedure section 2033.290(a).)

The court finds the motion is timely. The following RFAs are not proper and, therefore, the court will not compel further responses: ## 7, 10 & 16. Requests to "admit" legal conclusions are not proper. The remaining requests are reasonably calculated to lead to the discovery of admissible evidence. (See CCP Section 2017.010.)

The court compels further responses to RFP nos. 1, 2, 3, 4, 5, 6, 8, 9, 11, 12, 13, 14, 15. Plaintiff has shown Defendant's responses are incomplete/non-compliant and its objections are without merit. Defendant has not demonstrated the merit of any cognizable objection. Defendant must provide supplemental Code-compliant responses by July 13, 2025.

The court does not find Defendant Donna Lee Farley or her counsel. acted with substantial justification in connection with this discovery. Defendant and counsel Michael M. Lum and Leonidou & Rosin, jointly and severally, shall pay to Plaintiff $1,365 as sanctions, payable payment no later than by July 25, 2025.