Garcia

FACTS

Daniel Bramzon and R. Paul Katrinak (collectively, the Attorneys) practice under the name “BASTA, Inc.,” an organization that advocates for tenants‟ rights. They represent plaintiffs in a class action lawsuit filed in May 2010. Plaintiffs, who rent units in an apartment house owned by defendants, allege that the building is unfit for habitation. Farmers Insurance Exchange (Farmers) is an intervener in the lawsuit. In September 2011, Farmers propounded special interrogatories consisting of 10 questions relating to plaintiffs‟ damages. The questions were simple.2 Plaintiffs gave one response to all of the questions, which consisted only of objections.

All undesignated statutory references are to the Code of Civil Procedure. The interrogatories were: (1) do you seek monetary recovery for damage to or loss of use of personal property?; (2) if yes, describe each item of personal property, the date it was damaged, and the monetary value of it; (3) do you seek monetary recovery for bodily injuries?; (4) if yes, describe each injury, the date you were injured, and the amount of damage; (5) do you seek monetary recovery for emotional distress?; (6) if yes, state the…