Wood

BACKGROUND

After an incident in which Daniel Maleev’s dog allegedly bit Christopher Wood at a dog park, Christopher and his wife, Carolin Sue Wood, sued Daniel Maleev and his father, Ivan, for negligence, strict liability, and loss of consortium. The Woods

1 propounded 87 special interrogatories, 87 form interrogatories, and 62 requests for production of documents.1 On September 28, 2020, the Maleevs responded solely with objections. The parties then exchanged letters and emails about the propriety of the Maleevs’ responses, at the end of which the Maleevs asked the Woods to withdraw the discovery requests and offered instead to provide sworn declarations and stipulate to undisputed facts. Pursuant to the trial court’s local rules in effect at the time, on November 12, 2020, the Woods requested an informal discovery conference with the court as a prelude to filing a motion to compel further responses. After various delays, the trial court held the informal discovery conference on March 1, 2021. The record does not contain a transcript or a substitute for a transcript describing what occurred at the conference. A minute order posted after the conference states, “The court…