Motion to Compel Further Discovery Responses
Browse all Motion to Compel Further Responses rulings statewide →
22CV007091: MUJADADI vs TEAM VOLKSWAGEN OF HAYWARD CORPORATION, A CALIFORNIA CORPORATION,, et al. 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation, a California corporation, (Cross-Complainant) CRS# 583163174079 in Department 16
Tentative Ruling - 07/06/2026 Victoria Kolakowski
The hearing on Team Volkswagen of Hayward Corp.'s Motion to Compel Further Responses to document requests and special interrogatories is denied without prejudice.
I.
Background
In October 2025, Team VW moved to compel further responses to document requests and special interrogatories, and for a $5,100.00 sanction upon Abdul Mujadadi1 and his counsel. (Mot., Oct. 24, 2025.) Abdul opposed. (Oppn, May 12, 2026.)
The Court has continued the hearing on this Motion three times. The first time, the Court continued the hearing one week to provide itself additional time to review the submissions. (Order, May 19, 2026.) The second time, the Court further continued the hearing after, on its own motion, the Court found it appropriate and necessary to refer all discovery disputes to a referee. (Order, May 28, 2026.) The third time, the Court further continued the hearing to permit Abdul time to submit evidence on his economic ability to pay a pro rata share of the referees fee, among another issue. (Order, June 9, 2026.)
Ahead of the fourth hearing on this Motion, Abdul submitted his declaration stating that paying for a discovery referee would create a substantial financial hardship and significantly impair [his] ability to continue funding this litigation. (Abdul Decl. Supp. Mot. Compel Further Resps. ¶¶ 21, 22, June 25, 2026.) Team VW argued that Abdul failed to disclose all his assets and income to the Court in his declaration.
II.
Discussion
The Court finds it appropriate and necessary for a referee to hear and determine any and all discovery motions and disputes relevant to discovery in the action and to report findings and make a recommendation thereon. (Cal. Civ. Proc. Code § 639(a)(5); see also Taggares v. Super. Ct. (1998) 62 Cal. App. 4th 94, 105
Looking for case law or statutes not cited here? Search published authorities
Examples: “Why did the court rule this way?” · “What were the procedural grounds?” · “Is appearance required?”
Here, two factors are present. First, this Motion is one of five currently before the Court. And while several of the motions have significant overlap, the Court must still review each filing independently. And second, the issues raised by the parties in their briefing show that this discovery dispute is only one in a continuum of discovery disputes, beginning in January 2025. The Court has issued rulings that should have allowed the parties to better inform their discussions, adjust their positions, and resolve their discovery disputes.
Still, the disputes continue. The Court infers that the parties are entrenched in 22CV007091: MUJADADI vs TEAM VOLKSWAGEN OF HAYWARD CORPORATION, A CALIFORNIA CORPORATION,, et al. 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation, a California corporation, (Cross-Complainant) CRS# 583163174079 in Department 16 their respective positions and that their discovery disputes are unlikely to be resolved without continuous supervision.
Altogether, the parties discovery disputes have consumed significant amount of the Courts time and its limited (and underfunded) resources. (See id. at 106 (Where one or more of the above factors unduly impact the court's time and/or limited resources, the court is clearly within its discretion to make an appropriate reference.).) Accordingly, appointment of a referee is necessary because a referee will more effectivelyand, importantly, proactivelysupervise and manage the discovery proceedings, promptly hear discovery disputes, and issue recommendations to the Court.
The Court finds that no party has established an economic inability to pay a pro rata share of the referees fees. The Court finds Abdul did not carry his burden of proof that he ismore likely than notunable to pay 50 percent of the referees fees. Considering Abduls evidence and all argument, the Court concluded that he likely did not disclose all his assets and income to the Court.
The parties will share the costs of the referee equally unless the referee finds that one party has unreasonably caused the specific discovery dispute before the referee.
The parties must further confer on the nomination of a qualified discovery referee. If the parties do not agree on a referee, the parties must follow the procedure provided by section 640 of the Code of Civil Procedure.
III. Orders The Motion is denied without prejudice.
The Court refers any and all discovery motions and disputes relevant to discovery in the action and to report findings and make a recommendation thereon to a referee.
The parties will share the costs of the referee equally unless the referee finds that one party has unreasonably caused the specific discovery dispute before the referee.
The parties must submit a joint statement no later than July 24, 2026, naming their referee if agreed upon by the parties or their proposed nominees if they do not agree. 1 The Court refers to Abdul, Jahid, and Soliman Mujadadi by their first name for claritys
sake as the Court is hearing several motions to compel responses that concern the brothers. The Court intends no disrespect.
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
22CV007091: MUJADADI vs TEAM VOLKSWAGEN OF HAYWARD CORPORATION, A CALIFORNIA CORPORATION,, et al. 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation, a California corporation, (Cross-Complainant) CRS# 583163174079 in Department 16 ***
The Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation, a California corporation, on 10/24/2025 is Denied.
The Court orders counsel to obtain a copy of this order from the eCourt portal.
If a party does not timely contest the foregoing Tentative Ruling and appear at the hearing, the Tentative Ruling will become the order of the court.
How Do I Contest a Tentative Ruling? Find your case in eCourt at https://eportal.alameda.courts.ca.gov/ using Case Search or Calendar Search (after you log in) Select the Tentative Rulings Tab Select "Click to Contest this Ruling" Enter your name and briefly identify the issues you wish to argue. Select "Proceed"
You must also notify the department via email (Dept16@alameda.courts.ca.gov) and opposing parties by no later than 4:00 PM, one court day before the scheduled hearing.
Please provide this information to any opposing parties.
PLEASE TAKE NOTICE THAT THE HEARING/CONFERENCE WILL BE IN- PERSON WITH THE OPTION TO APPEAR REMOTELY.
COUNSEL AND PARTIES MAY APPEAR EITHER IN-PERSON IN DEPARTMENT 16 AT THE ADMINISTRATION BUILDING OR BY REMOTELY THROUGH THE ZOOM PLATFORM. ZOOM LOG-IN INFORMATION FOR DEPARTMENT 16 IS BELOW.
Join ZoomGov Meeting https://alameda-courts-ca-gov.zoomgov.com/j/16024053017 Meeting ID: 160 2405 3017