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 Admissions 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 Admissions And For Sanctions.

2 - Plaintiff's Motion To Compel from Defendant Donna Lee Farley Further Responses to Request For Production of Documents and For Sanctions is GRANTED. Plaintiff moves under Code of Civil Procedure section 2031.310. Subdivision (a) of section 2031.310 provides: "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."

The court finds the motion is timely. Defendant demonstrated reasonable meet and confer. The requests at issue appear 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. 7. 8. 9, 10, 11, 12, 13, 14, 15 & 16. 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. If a privilege is claimed, a Code-compliant privilege log must be produced by the same deadline

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 $1,165 as sanctions, payable payment no later than by July 25, 2025.

For the 9:00 a.m. calendar, all attorneys and parties may appear in Department 302 remotely or in person. Remote hearings will be conducted by videoconference using Zoom. (Dept. 302 Zoom ID 160 409 7690; Passcode 516287.) To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number.

Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing.

Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested.

The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/JMQ). | |