MOLLINS vs RELIANCE, INC., et al.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with

24CV014460: MOLLINS vs RELIANCE, INC., et al. 04/29/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc in Department 8D

a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporter’s Office and an official reporter will be provided

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G. ST. SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 25 WILL BE HEARD IN DEPARTMENT 8D OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION****

TENTATIVE RULING

Plaintiffs Ryan Mollins and Talia Mollins’s (“Plaintiffs”) Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc. (“Defendant”) is CONTINUED to June 15, 2026 to permit the parties to further meet and confer, including regarding the effect of Defendant’s supplemental responses to form interrogatories nos. 4.1 and 214.1 which were served on January 20, 2026.

At the outset, the Court must remind counsel that given the number of motions such as this which must be addressed on a daily basis, there are simply not enough judicial resources available to resolve each and every discovery dispute that could have and should have been resolved informally. This serves to highlight the critical need for all counsel's legitimate, reasonable and good faith meet-and-confer efforts before filing any discovery motion. Although it dealt with a motion to compel answers to deposition questions, the decision of Townsend v. Superior Court (1998) 61 Cal.App.4th 1431 is instructive in that it clarifies that the meet-andconfer process is not intended to be some perfunctory formality but rather it “requires...a serious effort at negotiation and informal resolution.” (Id., at 1438.)

Having reviewed the moving and opposing papers, and the numerous discovery requests in dispute, it is apparent to the Court that counsel must further engage in the meet-and-confer process in good faith, via telephone, videoconference, or in person. In particular, with respect to Defendant’s supplemental responses to form interrogatories, nos. 4.1 and 214.1, which Defendant contends provide the information which Plaintiffs seek to compel in the instant motion. The Court is further concerned by Plaintiffs’ use of an approximately 240-page meetand-confer letter regarding Defendant’s responses to discovery. While Plaintiffs did not file the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 04/29/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc in Department 8D

entire letter in support of this instant motion, the Court is concerned that such a lengthy letter does not constitute a good faith attempt to meet and confer. Moreover, with respect to the special interrogatories at issue, the letter devotes approximately a half-page to these responses, noting that “Plaintiff will reserve meeting and conferring on SROGs 1-7 depending on whether the information sought is appropriately responded to in FROG-GEN 4.1 or FROG-EMP 214.1.” It appears that follow-up written meet and confer letters again raised the interplay between the special rogs at issue in this motion and responses to form interrogatories. (See. Exh H. to Brouwer Decl., p. 5 [“Do Defendants plan on providing the requisite responses to the SROGs 1, or in the alternative, further supplement F-Gen 4.1/F-Emp. 214.1?”].)

Counsel for the parties are thus ordered to further engage in the meet-and-confer process in order to resolve or substantially narrow their discovery dispute. In order to encourage a meaningful dialogue and improve the prospects for resolution, the meet-and-confer efforts shall be conducted either in person or via telephone, rather than by the mere exchange of letters or emails.

Counsel shall meet and confer in person (including via telephone or videoconference) no later than May 25, 2026. After thoroughly meeting and conferring in an attempt to resolve each and every discovery request that the motion currently encompasses, and no later than June 1, 2026, counsel shall file a joint statement indicating which discovery requests have been resolved, and which requests (if any) remain outstanding. For each outstanding request, counsel shall set forth in the joint statement their respective positions, citing the relevant facts and authorities. Boilerplate or cut-and-paste arguments are strongly discouraged.

On the Court's own motion, the Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc scheduled for 04/29/2026 is continued to 06/15/2026 at 01:30 PM in Department 8D at Tani G. Cantil-Sakauye Courthouse.