Motion to Compel Production (x2)
This cause of action also requires, however, “actual disruption of the relationship.” (SC Manufactured Homes, Inc., supra, 148 Cal.App.4th at p. 672 fn. 7 [emphasis added].)
Plaintiffs allege Thomas asked one employee whether he would be interested in an opportunity with a competitor and that the employee was subsequently contacted by the competitor. (Compl. ¶ 32.) Plaintiffs further allege another employee received unsolicited calls from a competitor and responded he was not interested in joining. (Compl. ¶ 33.) Plaintiffs allege Thomas then contacted that employee and informed him Thomas was working with the competitor, had been told by the competitor about the employee’s response, and encouraged the employee to consider the competitor’s offer. (Compl. ¶ 33.) Plaintiffs allege the employee then received an offer letter from the competitor. (Compl. ¶ 34.) Finally, Plaintiffs allege “Thomas solicited additional Acrisure employees to join him at the competitor.” (Compl. ¶ 35.)
While Plaintiffs include a single allegation they have “suffered substantial and irreparable injury, including the loss of business, employees, and damage to its goodwill and reputation” (Compl. ¶ 39), the alleged loss of employees is unsupported by any factual allegations. Plaintiffs do not allege either the specifically referenced employees or any other employees actually left Acrisure for a competitor due to Thomas’ conduct.
The Court SUSTAINS Thomas’ demurrer to the third cause of action in Plaintiffs’ complaint with 20 days leave to amend. 2 25-01453685 1) Motion to Compel Production 2) Motion to Compel Production Adams vs. Colliers International Group, Plaintiffs Irene Adams and West Palmyra Ltd. moves to compel Inc. Defendant Colliers International Group Inc. (“CIGI”) to serve further responses to Plaintiffs’ Requests for Production of Documents, Set One, and to produce all responsive, non-privileged documents.
On 5-21-26, the court continued the hearing on the Motion and ordered the parties to further meet and confer. (ROA 452.) On 6-18-26, parties filed a Joint Statement which shows the parties have met and conferred and CIGI has agreed to produce all non-privileged documents responsive to the Request for Production. To date, CIGI has produced 18,613 documents. CIGI states that it will be producing additional responsive documents on 6-22-26 and will serve supplemental responses to the Request including identifying bates numbers of documents by category by 6-24-26.
It appears the parties have successfully resolved the issues raised in the Motion. The court asks that the parties come prepared to discuss the status of the service of supplemental responses and production of supplemental documents and any remaining issues not resolved by the meet and confer.
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Plaintiffs to give notice.
MOTION NO. 2: Plaintiffs Irene Adams and West Palmyra Ltd.’s motion to compel defendant Millrock Investment Fund 1, LLC (“Millrock”) to serve verified, code-compliant further responses, without objection, to Plaintiffs’ Requests for Production of Documents, Set One, and to produce all responsive, non-privileged documents and for monetary sanctions is CONTINUED to _______.
The rule requiring a good faith effort to meet and confer about discovery disputes “is designed to encourage the parties to work out their differences informally so as to avoid the necessity for a formal order . . . [t]his, in turn, will lessen the burden on the court and reduce the unnecessary expenditure of resources by litigants through promotion of informal, extrajudicial resolution of discovery disputes.” (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1016.) “The level of effort at informal resolution which satisfies the ‘reasonable and good faith attempt’ standard depends upon the circumstances. In a larger, more complex discovery context, a greater effort at informal resolution may be warranted. In a simpler, or more narrowly focused case, a more modest effort may suffice.” (Obregon v. Superior Court (1998) 67 Cal.App.4th 424, 431.)
Millrock contends that Plaintiffs failed to sufficiently meet and confer prior to filing the Motion. On 12-15-25, Plaintiffs counsel sent a meet and confer letter to Millrock’s counsel. (Dardashti Decl., ¶ 5, Ex. C.) On 12- 22-25, Millrock responded to the letter and explained why Millrock was having difficulty understanding Plaintiffs’ requests and offered to further meet and confer regarding the Requests. (Dardashti Decl., ¶ 6, Ex. D.) Millrock states that in their Motion, Plaintiffs characterize their Requests far more narrowly than the versions they propounded on Millrock and that it is likely that if Plaintiffs met and conferred with Millrock and narrowed their Requests, as they have attempted to do in their Motion, many of the disputes identified by Plaintiffs could potentially be resolved. (Opp., 8:16-19.)
The court finds further conferences between the parties would be productive. Therefore, the parties are ordered to engage in additional attempts to meet and confer regarding the issues that remain in dispute, including a telephonic or in-person conference (not email). No later than 9 court days prior to the continued hearing, the parties are to file a Joint Statement which shall (1) describe the parties’ attempts to meet and confer pursuant to this order, (2) identify each discovery request that remains in dispute, and (3) each party’s position on the discovery request that remains in dispute.
Plaintiffs to give notice. 3 24-01393857 Motion to Vacate
Bank Of America, N.A. Plaintiff Bank of America, N.A.’s Motion to Vacate Dismissal and Enter vs. Chadha Judgment Pursuant to Stipulation of the Parties is DENIED without prejudice.