Obregon v. Superior Court
California Court of Appeal
79 Cal. Rptr. 2d 62 (1998)
Jovita Obregon (plaintiff) sued her employer, a Burger King franchise operated by Cimm's, Inc. (defendant), for sexual harassment and served broad, not clearly focused interrogatories; Cimm's responded with a mix of factual answers and objections. Obregon sent one letter requesting further responses thirteen days before her motion-to-compel deadline, Cimm's responded four days before that deadline reasserting objections but also offering alternative resolutions, and Obregon, receiving that response only one day before her deadline, filed a motion to compel without any further communication with Cimm's. The trial court agreed with Cimm's that Obregon had not made a reasonable, good-faith effort to informally resolve the dispute, denied the motion to compel entirely, and imposed sanctions on Obregon.
Whether a single letter demanding further discovery responses, sent without further follow-up despite a partial response offering alternative resolutions, satisfies the reasonable and good-faith meet-and-confer requirement before filing a motion to compel, and whether denying the entire motion is an appropriate sanction for falling short.