Excerpt: ... accompanied by a proposed answer. Here, counsel for Defendants confirms he was in touch with the insurance company representative, Deanna Ceriani, who confirmed that she was not provided with a copy of the complaint. Ayotte Declaration, ¶ 2. Mr. Ayotte later telephoned Plaintiff's counsel to inform that he had been retained and asked for a courtesy copy of the complaint. Id. ¶ 3. He did not follow up in writing. Mr. Garcia‐Martinez confirmed...

Excerpt: ... Plaintiff has not shown substantial justification for the delay in responding to discovery propounded in August 2017. It was only until Defendant filed motions that Plaintiff provided verified responses. The court imposes total sanctions of $1,000 for both motions against Plaintiff for the failure to timely respond to authorized methods of discovery without substantial justification. Cal Code Civ Procedure § 2023.010(a)(4). Defendant's Motion t...