Estate of Bennett CA4/1

INTRODUCTION

Josephine Bennett and Monica Bennett are sisters engaged in litigation

over the estate of their deceased mother, Lucia Reyes Bennett.1 Monica, an attorney herself, is self-represented. Wishing to take Monica’s deposition in advance of a mandatory settlement conference, Josephine served Monica with a notice of deposition. Monica did not respond. Josephine’s attorney reached out to Monica one week before the noticed deposition date and, only then, did Monica indicate that she intended to object to the notice. Monica filed a motion to quash the notice of deposition four days later. The motion was the first and only written notice of Monica’s objections received by Josephine or her counsel. The trial court denied Monica’s motion and awarded sanctions in the form of attorney fees to Josephine, based in part on Monica’s failure to adequately meet and confer before filing the motion to quash. Monica appeals the order awarding sanctions on several grounds, but none have merit. We affirm the order.

FACTUAL AND PROCEDURAL BACKGROUND

Josephine and Monica’s mother, Lucia, died in October 2016. Lucia was survived by six adult children, including Monica and Josephine. The…