In London v. Dri-Honing Corp. (2004) 117 Cal.App.4th 999, the plaintiff moved for a motion to compel further response to an inspection demand after the defendant refused to produce documents. (Id. at p. 1002.) The defendant chose to accept an evidentiary limitation rather than fully comply and the trial court invited the plaintiff to document the fees and costs incurred in litigating the motion so the court could impose a discovery sanction under former Code of Civil Procedure section 2031, subdivision (m). (Ibid.) After a separate, noticed motion and hearing, the court imposed a monetary discovery sanction. (Ibid.) On appeal, Dri-Honing asserted that "since a motion to compel further response under section 2031, subdivision (m), now Code of Civil Procedure section 2031.310 must be made within a 45-day time limit, so too must the movant's request for monetary sanctions related to that motion; therefore, such a request must be part of that motion." (London v. Dri-Honing Corp., supra, 117 Cal.App.4th at p. 1004.) The appellate court rejected that argument and determined that "a motion for discovery monetary sanctions may be made after an underlying motion to compel further response to an inspection demand is litigated. (Code Civ. Proc., 2031, subd. (m).)" (Id. at p. 1001.) The court acknowledged that, even though "a motion for monetary sanctions may be filed separately from a motion to compel further response under section 2031," the issue of "timeliness" was "still important" and "subject to the trial court's discretion." (Id. at pp. 1008-1009.) The court also recognized that "Dri-Honing was correctly concerned with protecting the Discovery Act's policy interest in speedy resolution of discovery disputes." (Id. at p. 1008.)