RANDHAWA vs CALIFORNIA DEPARTMENT OF JUSTICE, et al.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a 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

25CV002397: RANDHAWA vs CALIFORNIA DEPARTMENT OF JUSTICE, et al. 05/04/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set Two in Department 8D

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 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 Rajdeep Randhawa’s (“Plaintiff”) Motion to Compel Defendant Amanda Christine Evans (“Defendant”) to provide further responses to Plaintiff’s Special Interrogatories, Set Two and for monetary sanctions is continued to June 15, 2026 to permit the parties to engage in further meet-and-confer

Plaintiff’s notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Plaintiff’s counsel is directed to contact opposing counsel and advise of Local Rule 1.06 and the Court’s tentative ruling procedure and the manner to request a hearing. If Plaintiff’s counsel is unable to contact opposing counsel prior to the hearing, Plaintiff’s counsel is ordered to appear at the hearing by Zoom or in person.

Plaintiff filed this personal injury action on January 29, 2025. No trial date is currently set.

Plaintiff served the at issue special interrogatories on December 19, 2025. (Shantel Yaghoobian [“Yaghoobian Decl.”], ¶ 4.) Defendant Amanda Christine Evans served responses on February 4, 2026. (Yaghoobian Decl., ¶ 6.) The parties met and conferred, by letter, between February 5, 2026 and February 11, 2026 regarding Defendant’s responses. (Yaghoobian Decl., ¶¶ 7-8 and Exhibits C-D.)

Plaintiff now moves to compel further responses to special interrogatories on the ground that Defendant’s responses are insufficient. Defendant opposes the motion.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV002397: RANDHAWA vs CALIFORNIA DEPARTMENT OF JUSTICE, et al. 05/04/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set Two in Department 8D

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. The meet-and confer process is not intended to be some perfunctory formality but rather it “requires...a serious effort at negotiation and informal resolution.” (Townsend v.

Superior Court (1998) 61 Cal.App.4th 1431, 1438.) Indeed, a motion to compel must be accompanied by a declaration stating facts showing a “reasonable and good faith attempt” to resolve informally the issues presented by the motion before filing the motion. (Code Civ. Proc., §§ 2016.040, 2025.450(b)(2).) The purpose of the meet and confer requirement is to bridge the gap between the parties – to force lawyers to reexamine their positions, and to narrow their discovery disputes to the irreducible minimum, before calling upon the court to resolve the matter. (Stewart v.

Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1016.)

Moreover, as of January 1, 2026, Code of Civil Procedure section 2016.040 requires that meet-and-confer efforts prior to bringing a motion to compel be made “either in person, by telephone, or by videoconference.” (emphasis added)

Having reviewed the briefing, including the declarations submitted by both moving and opposing counsel, it is apparent to the Court that counsel must make further efforts to engage in the meet-and-confer process in good faith and to comply with the requirements of Code of Civil Procedure section 2016.040. As noted above, based on the declaration submitted to the Court, it appears that all attempts to meet and confer occurred via written correspondence. However, as discussed above, the Code of Civil Procedure now requires that meet-and-confer efforts be made “either in person, by telephone, or by videoconference.”

Second, it appears to the Court that the efforts that counsel made to meet and confer were truncated—having taken place over the course of only one week. In this regard, the Court notes that counsel for Plaintiff sent Defendant’s counsel a five-page correspondence on February 5, 2026, which addressed what Plaintiff’s counsel’s “substantial concerns” with Defendant’s responses to the subject interrogatories. Despite this lengthy correspondence, Plaintiff’s counsel nonetheless requested Plaintiff provide “our office verifications, further responses to the requests, and all documents requested below within seven (7) days of this letter”. (Yaghoobian Decl., Exhibit C [emphasis added].)

In this regard, Plaintiff’s counsel states that “time is of the essence.” (Ibid.) However, at the conclusion of its letter, Plaintiff’s counsel does state, that while it would prefer responses within the time stated at the beginning of its letter (i.e., 7 days) if

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV002397: RANDHAWA vs CALIFORNIA DEPARTMENT OF JUSTICE, et al. 05/04/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set Two in Department 8D

Defendant’s counsel requires more time, it can contact Plaintiff’s counsel. (Ibid.)

It appears that Defendant’s counsel did not require any additional time and instead sent a one-and-a-half-page response to Plaintiff’s counsel on February 11, 2026. (Id., at Exhibit D.) While Defendant’s counsel does not agree to provide any supplemental responses, Defendant’s counsel does invite further meet and confer efforts with Plaintiff’s counsel at the end of this letter. (Ibid.) Specifically, Defendant’s counsel stated at the conclusion of his letter:

In sum, Defendant provided proper, code-compliant responses to the interrogatories. If you have case or statutory law that you believe supports your position, please provide and I will be happy to review and re-evaluate my position, if appropriate.

(Ibid.)

Plaintiff’s counsel filed this motion to compel two days later, on February 13, 2026. It does not appear that Plaintiff’s counsel responded to Defendant’s invitation to provide any additional case or statutory law. Counsel must engage in further meet-and-confer efforts via “either in person, by telephone, or by videoconference” as required by statute and to engage in a meaningful dialogue.

Counsel shall meet and confer in person, by telephone, or by 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 whether any part of the at issue discovery has been resolved, and what remains outstanding for the Court’s consideration. If any issues remain, 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.

Plaintiff is admonished that the motion will be dropped if no joint statement is filed. If Plaintiff contends that the parties have been unable to meet and confer as directed, Plaintiff shall file a declaration by the due date for the joint statement describing the efforts made to contact Defendant.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; Cal. Rules of Court, rule 3.1312.)

On the Court's own motion, the Hearing on Motion to Compel Further Responses to Special

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV002397: RANDHAWA vs CALIFORNIA DEPARTMENT OF JUSTICE, et al. 05/04/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories, Set Two in Department 8D

Interrogatories, Set Two scheduled for 05/04/2026 is continued to 06/15/2026 at 01:30 PM in Department 8D at Tani G. Cantil-Sakauye Courthouse.