Motion for Protective Order
SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 12 Honorable Nahal Iravani-Sani, Presiding Courtroom Clerk, Ryan Nguyen 191 North First Street, San Jose, CA 95113 Telephone: (408) 882-2230
DATE: 06/17/2026 TIME: 9:00 A.M. and 9:01 A.M.
LINE 6 Charity Emos vs Ford Motion: Withdraw as an Attorney Motor Company et al Plaintiff’s counsel Tionna Carvalho of Strategic Legal Services moves to be Relieved as Counsel for Plaintiff Charity Emos, pursuant to Code of Civil Procedure Section 284(2). Good cause appearing, and no opposition received, the motion is GRANTED. The Court will sign the previously submitted Form MC-053 but will modify the next court date for accuracy.) The Court has subsequently received Notice from new counsel Larry Chae and Tyson Smith from same law firm – Strategic Legal Services – as handling attorneys for Plaintiff.
Counsel shall appear at the Case Management Conference 6/17/26 at 10:00.
LINE 7 25CV464001 Shari Yuan vs Please Ctrl Click on (or scroll down to) Line 7 Starbucks Corporation LINE 8 25CV481792 Avelardo Saenz vs Hearing: Petition Compel Arbitration Ford Motor Company et al Please Ctrl Click on (or scroll down to) Line 8
Calendar Line 7 Shari Yuan vs Starbucks Corporation
DEFENDANT’S MOTION FOR PROTECTIVE ORDER
As an initial matter, the motion was timely filed. The parties agreed to extend Defendant’s deadline to respond to the Requests for Admission to March 6, 2026, and Defendant filed the present motion on that date after engaging in meet-and-confer efforts.
Under CCP sections 2017.010 and 2033.080, discovery may be obtained regarding matters relevant to the subject matter of the action or to the determination of a motion made in the action. During the parties’ meet-and-confer efforts, Plaintiff’s counsel acknowledged that Requests for Admission Nos. 1 through 7 are not relevant to the allegations of the complaint and asserted they may be relevant to Plaintiff’s anticipated opposition to Defendant’s motion to transfer venue.
The Court finds good cause for a protective order. Requests Nos. 1 through 7 seek admissions concerning the residence of Defendant’s Chief Executive Officer and the existence and use of a Starbucks office in Newport Beach, California. Defendant has presented evidence that its principal place of business is located in Washington. Even assuming the truth of the requested admissions, Plaintiff has not demonstrated how the existence or use of a corporate office in Orange County, or the residence of Defendant’s Chief Executive Officer, would tend to establish that venue is proper in Santa Clara County under CCP sections 395 or 395.5.
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The Court is mindful that the motion to transfer venue remains pending, scheduled for July 10, 2026. However, Plaintiff has not filed opposition to the present motion and has not identified any legal theory, evidence, or authority demonstrating the relevance of Requests Nos. 1 through 7 to the venue issues presently before the Court. On the record before it, the Court finds the requests are not reasonably calculated to lead to the discovery of admissible evidence relevant to any claim, defense, or motion in this action. (CCP §§ 2017.010, 2017.020, 2019.030.)
Accordingly, Defendant’s motion for a protective order is GRANTED. Defendant need not respond to Requests for Admission Nos. 1 through 7.
Defendant to prepare the final order, accompanied by the necessary Forms EFS-020, within 10 days of the date of the hearing.
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