Yue

BACKGROUND

On January 21, 2020, Mahagama was served Yue’s Special Interrogatories Set One, Requests for Production of Documents Set One, Requests for Admissions, Set One and Form Interrogatories Set One. After Mahagama failed for months to provide verified, code-compliant responses to those requests, Yue filed a “Motion to Compel Responses to Requests for Production of Documents and Special Interrogatories and Request for Sanctions Against Defendant Cosmas Mahagama and His Attorney . . . .” On September 9, 2020, the trial court sanctioned Mahagama and granted the motion to compel, referring specifically to Yue’s “Request for Production of Documents . . . Nos. 33-34, 36-39, [and] 43-50” in the order. As the trial court noted, “Mahagama concede[d]” in his opposition to the motion to compel “that he [h]as waived any objections to the Requests.” Two months later, Yue’s counsel sent a letter to Mahagama’s counsel, reminding him that Mahagama had “failed to provide timely responses to our . . . requests for production of documents,” and therefore waived “all objections . . . for all responses, including those based on attorney-client privilege and work product.” The letter concluded by…