MOLLINS vs RELIANCE, INC., et al.

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/15/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc in Department 8D

reporter from the Court’s Approved Official Reporter Pro Tempore list. 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 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 ruled upon as follows.

Factual Background

Plaintiffs served the at issue discovery requests on December 5, 2024. (Brouwer Decl., ¶ 2.) Defendant served its responses on May 14, 2025. (Brouwer Decl., ¶ 3.)

Plaintiffs now move to compel further responses to special interrogatories, set one, nos. 1-12. Defendant opposes.

This matter was previously continued from April 29, 2026, to permit the parties to further meet and confer. On June 1, 2026, the parties filed their joint statement representing their positions with respect to the matters raised in the instant motion.

Per the joint statement, the parties have come to an agreement with respect to special interrogatories, nos. 1, 2, 5, 8, and 9. The parties require judicial intervention with

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/15/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc in Department 8D

respect to interrogatories nos. 3-4, 6-7, and 10-12.

Further Meet-and-Confer Efforts

The Court’s April 29, 2026 Minute Order states, in relevant part:

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.

Defendant argues that despite the continuance, “Plaintiffs gave Defendants fewer than 24 hours to evaluate their final positions regarding the discovery requests at issue.” (Joint St., p. 10:13-14.)

Pursuant to the Joint Statement, the parties met and conferred via phone on May 22, 2026. (Joint St., p: 6:3-4.) Defendant argues that having received no communications from Plaintiffs’ counsel, Defendant requested a time to meet and confer. Following the phone call between the parties, “Plaintiffs did not share any information regarding their final positions on the requests in their motions—including which SROGs they ultimately intended to pursue, which SROGs they intended to withdraw, or any additional legal support for their positions—until Sunday, May 31, 2026 at 10:35 PM.” (Id., p. 10:18-21.) As a result, “Defendants have thus had only a few hours to prepare their responses for this Joint Statement despite repeated requests for Plaintiffs’ final positions on their SROGs well in advance of the Joint Statement filing deadline.” (Id., p. 10:21-23.)

Plaintiff’s counsel states that they began trial in Santa Clara on May 4, 2026, which is still ongoing, which limited counsel’s ability to meet and confer with Defendant.

As noted in the Court’s April 29, 2026 Minute Order, the Court was concerned by Plaintiffs’ initial meet-and-confer efforts prior to bringing the instant motion. The fact that Plaintiffs’ sent Defendant their portion of the proposed joint statement for the first time on May 31, 2026 (a Sunday) at 10:35 PM. is similarly concerning. The fact that Plaintiffs’ counsel is in trial does not negate their obligations in other cases. Had Plaintiffs required more time to properly meet and confer, the Court would have granted it. Instead, Plaintiffs chose to hide the ball, refusing to inform Defendants of which interrogatories they would continue to pursue, which shows a lack of good faith in the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/15/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set One from Defendant Reliance, Inc in Department 8D

meet-and-confer process.

Therefore, the Court will DENY Plaintiffs’ motion in its entirety for failure to meet and confer. The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.