NAMBA vs AMERICAN HONDA MOTOR CO., 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

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 05/06/2026 Hearing on Motion to Compel Further Discovery Responses to Request for Production of Documents 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

Plaintiff Kenneth Jay Namba’s (“Plaintiff”) Motion to Compel Further Responses to Requests for Production of Documents, Set One from Defendant American Honda Motor Co., Inc.’s (“Defendant”) is CONTINUED to June 15, 2026 to permit the parties to further meet and confer.

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 p. 1438.)

Having reviewed the moving and opposing papers, and the numerous discovery requests that the parties dispute, and the further supplementation and efforts that have taken place after the motion was filed, it is apparent to the Court that further progress could be made if counsel continues to engage in the meet-and-confer process in good faith. Counsel for the parties are thus ordered to 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 and consistent with recent revisions to Code of Civil Procedure section 2016.040, the meet-andconfer efforts shall be conducted either in person or via telephone/videoconference, rather than by the mere exchange of letters or emails.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 05/06/2026 Hearing on Motion to Compel Further Discovery Responses to Request for Production of Documents in Department 8D

In resuming the meet-and-confer process, the parties should be guided by the observations that the instant motion is not rendered moot by Defendant’s service of supplemental responses, as Code of Civil Procedure section 1005.5 specifically provides that a motion is deemed made at the time it is file. The parties should also be guided by the following general principles: (1) objections to a demand for inspection must identify with particularity any documents that are not being produced based on the objection (Code Civ.

Proc. § 2031.240(b)); (2) a privilege log is generally required for documents being withheld based on a claim of privilege; (3) conclusory assertions that a party is “hiding” documents, without more, is generally insufficient to support a motion to compel; (4) a plaintiff in a lemon law action is typically permitted to obtain discovery regarding the manufacturer’s knowledge of similar complaints in identical (same year, make, model, sold in California) vehicles, but further scope may be considered overbroad; and (5) the Court typically cannot compel a responding party to produce documents until after the responding party identifies the responsive documents in a statement of compliance and agrees to produce them.

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 Discovery Responses to Request for Production of Documents scheduled for 05/06/2026 is continued to 06/15/2026 at 01:30 PM in Department 8D at Tani G. Cantil-Sakauye Courthouse.