Raygoza v. Mazda Motor of America, Inc.

(03) Tentative Ruling

Re: Raygoza v. Mazda Motor of America, Inc. Case No. 25CECG03565

Hearing Date: July 2, 2026 (Dept. 501)

Motion: Plaintiff’s Motions to Compel Further Responses to Special Interrogatories and Requests for Admissions, Set One, and for Sanctions

Tentative Ruling:

To deny plaintiff’s motions to compel further responses to special interrogatories and requests for admissions, set one. Defendant has now served supplemental responses to the disputed requests and interrogatories, so the motions are moot.

However, the court intends to grant plaintiff’s request for sanctions against defendant, in the amount of $1,440. Defendant shall pay sanctions to plaintiff within 30 days of the date of service of this order. (Code Civ. Proc., §§ 2030.300; 2033.290.)

Explanation:

Defendant has now served supplemental responses to the interrogatories and requests for admissions, so the motions are moot to the extent that they seek to compel further responses.

Also, while plaintiff contends that the court should rule on the merits of defendant’s supplemental responses to interrogatories, the court declines to rule on whether the supplemental responses are adequate. Plaintiff would need to meet and confer on the supplemental responses, bring a request for pretrial discovery conference on the supplemental responses, and receive leave of court to bring her motion to compel before the court would rule on the merits of the responses. (See Code Civ. Proc., § 2030.300; Fresno Sup. Ct. Local Rule 2.1.17 A.) Since plaintiff has not complied with the procedural requirements for bringing a motion to compel further responses with regard to the newly served supplemental responses, the court will not rule on the issue of whether the supplemental responses are sufficient.

On the other hand, the court intends to grant plaintiff’s request for sanctions against defendant for its willful and unjustified refusal to serve substantive responses to the interrogatories and requests for admissions. (Code Civ. Proc., §§ 2030.300, subd. (d); 2033.290, subd. (d).) Defendant objected to the interrogatories and requests for admissions, and refused to provide substantive responses because it claimed that plaintiff had not served a declaration showing good cause for serving more than 35 interrogatories and requests for production. However, plaintiff’s counsel had served a declaration to justify the additional requests, and defendant never moved for a protective order, so defendant should have served substantive responses.

Plaintiff attempted to obtain supplemental responses from defendant for weeks, and engaged in extensive meet and confer efforts, as well as filing a pretrial discovery conference request before finally filing her motions to compel. It was only after plaintiff went to the expense and trouble of filing the motions that defendant finally relented and served substantive responses, even though it could have provided responses months earlier. Therefore, defendant’s failure to serve substantive responses was unjustified, and was apparently simply intended to cause plaintiff to incur additional costs and delays.

As a result, the court will grant plaintiff’s request for sanctions against defendant. However, the court will reduce the amount of sanctions to a more reasonable number. Plaintiff has requested $3,322.50 in sanctions for the cost of bringing both motions. The requested amount is excessive, especially considering the fairly narrow issue presented by the motions. The court will award only $1,320 in attorney’s fees based on four hours of time billed at $330 per hour, plus $120 in filing fees, for a total of $1,440 in sanctions.

Pursuant to California Rules of Court, rule 3.1312(a), and Code of Civil Procedure section 1019.5, subdivision (a), no further written order is necessary. The minute order adopting this tentative ruling will serve as the order of the court and service by the clerk will constitute notice of the order.

Tentative Ruling

Issued By: KCK on 07/01/26. (Judge’s initials) (Date)

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