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Letter Head
Conclusion
Discovery Obligations
MEGERDOMIAN LAW OFFICES
A Professional Corporation
320 Non Central Avenue, 408 North Camleu Drive, Suite 220
Glendale, CA 91203 Beverly Hills, CA 91210
: (877) 734-3095 P. (877) 734-3095
F.(818)272-8634 F: (818) 272-8634
December 18, 2023
Karl Loureiro
633 W. Sth Street, Suite 4000
Los Angeles, CA 90071
Via Email at [Link]@lew
[Link]
Re: Sonia Gramajo Olivarri v. Alliante International, Northgate Gonzalez Market, Inc.
Our Client: Sonia Gramajo Olivarri
Date Of Loss: 1/19/2020
Case Number: 21STCV0S451
Dear Mr. Loureiro
Plaintiff Sonia Gramajo Olivarri (hereinafter “Plaintiff”) served their discovery requests
on Defendants Alliante International and Northgate Gonzalez Market, Inc., (hereinafter
“Defendants") on October 27th, 2023. Since then, the parties have been in communication
regarding a potential settlement. At this juncture, however, it seems the parties are at an impasse.
‘Therefore, Plaintiff demands the responses to their discovery or it will bring a motion to compel
Since the Defendants have not timely responded to the discovery requests, they have relinquished
their rights to object to the responses. Accordingly, please provide the responses without any
objections
11P Discovery Obligations
A party has an obligation to respond to discovery demands, including requests for
production, in good faith as best as they can, even if there is ambiguity in the request. (Code of
Civil Procedure §2031.220(c); Regency Health Services, Inc. v. Superior Court (1998) 64
Cal. App.4th 1496, 1504; Deyo v. Kilbourne (1978) 84 Cal. App.3d 771, 783.)
‘The Discovery Act imposes a duty on parties to state the truth, the whole truth, and
nothing but the truth in answering written discovery. (Scheiding v. Dinwiddie Const. Co. (1999)
69 Cal. App. 4th 64, 76.) Thus, when answering each interrogatory, Defendants have a duty to
provide “each answer in a response to interrogatories" as "complete and straightforward as the
information reasonably available to the responding party permits." (Code of Civ. Proc. §
2030.220 emphasis added.) Answers must not be evasive or deftly worded conclusions. (Deyo,
‘supra, 84 Cal, App. 34 at 783.) Nonresponsive or evasive answers to properly drafted
interrogatories are a misuse of the discovery process. (See Code of Civ. Proc. §2023.010(f).) In
keeping with these well-established precepts, we therefore respond to the objections and
deficiencies in Defendants” discovery responses, in an effort to resolve this dispute informally.
CONCLUSION
Please provide substantive responses to the discovery that were served on both
Defendants on or before December 22, 2023, at 10:00 a.m. If Plaintiff does not receive the
discovery responses from both defendants, a motion to compe! will be filed.
Best Regards,
Megerdomian Law Offices, P.C
