Jeanneth Franco v. Costco Wholesale Corporation et al.

I. Background

On August 9, 2024, Plaintiff filed an action against Defendant in Los Angeles County Superior Court. See Dkt. # 1 (“NOR”) ¶ 1. On April 2, 2025, Plaintiff served Defendant with a summons, complaint, and statement of damages. See id. ¶ 2; Mot. 2. The statement of damages set forth Plaintiff’s general damages as $5,000,000. See Mot. 2. On April 17, 2025, Defendant served its answer to the complaint. See NOR ¶ 3; Mot. 2. Along with Defendant’s answer, on April 17, 2025, Defendant served initial written discovery on Plaintiff. See NOR ¶ 6. Plaintiff’s deadline to respond to that discovery was May 20, 2025, see Opp. 2, but Plaintiff waited until after her deadline had passed to request an extension. See id. Defendant granted Plaintiff multiple extensions, giving Plaintiff until June 20, 2025, to serve her responses. See id. When Plaintiff had not served the discovery responses by June 27, 2025, Defendant filed discovery motions to compel Plaintiff’s responses. See id. 3. The first available hearing date for the motions to compel was January 30, 2026, and Plaintiff ultimately served her discovery responses on October 7, 2025. See id. Those discovery…