Motion to Compel Further Discovery Responses
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RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16
Tentative Ruling - 07/06/2026 Victoria Kolakowski
The hearing on Team Volkswagen of Hayward Corporation's Motion to Compel Further Responses to document requests is denied without prejudice.
I.
Background
In October 2025, Team VW moved to compel further responses to document requests 1 through 4, and for a $2,560.00 sanction upon Soliman Mujadadi1 filed and his counsel. (Mot., Oct. 24, 2025.) Soliman opposed. (Oppn, May 6, 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 Soliman 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, Soliman 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. (Soliman Decl. Supp. Mot. Compel Further Resps. ¶ 22, June 25, 2026.)
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 (holding that a court should not make blanket orders directing all discovery motions to a discovery referee except in the unusual case where a majority of factors favoring reference are present).)
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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 their respective positions and that their discovery disputes are unlikely to be resolved without continuous supervision. RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16
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 Soliman has established an economic inability to pay a pro rata share of the referees fees. (See generally Soliman Decl., June 25,2026.) Accordingly, the Court finds that it is fair and reasonable for Team VW to pay 100 percent of the referees fees. The parties are strongly encouraged to minimize the costs of the referee in this action to the greatest practical extent.
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.
***
The Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation on 10/24/2025 is Denied.
The Court orders counsel to obtain a copy of this order from the eCourt portal.
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 07/07/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16
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