Motion to Compel Further Discovery Responses
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25CV160167: ROBIE vs STOTHERS 07/09/2026 Hearing on Motion to Compel Further Discovery Responses filed by Claudia Robie (Plaintiff) CRS# 175164897146 in Department 520
Tentative Ruling - 07/08/2026 Jamilah A. Jefferson
The Motion to Compel Further Discovery Responses filed by Claudia Robie on 06/11/2026 is Granted in Part.
The Motion of Plaintiff Claudia Robie (Plaintiff) to Compel Further as to Defendant Marda Stothers (Defendant) is GRANTED IN PART.
Defendant is ordered to serve Plaintiff with code-compliant responses without objections to Plaintiffs Special Interrogatories, Requests for Admission, and Requests for Production of Documents (Set One) within fifteen (15) days of the date of this Order.
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DISCUSSION
The subject discovery requests concern Special Interrogatories, Requests for Admission, and Requests for Production of Documents (Set One) served on March 29, 2026. (Falahati Decl., Exs. 1-3.)
The crux of Defendants objection lies in the argument that [c]ompelling full merits responses to 102 requests before the Court decides whether the claims survive would squander resources of the parties and the Court[.] (Oppo., p. 2:6-8.) However, pleading deficiencies generally do not affect either party's right to conduct discovery [citation] and this right (and corresponding obligation to respond) is particularly important to a plaintiff in need of discovery to amend its complaint [citation]. (Mattco Forge, Inc. v. Arthur Young & Co. (1990) 223 Cal.App.3d 1429, 1436, fn. 3.)
The Court is also not persuaded by Defendants other objections concerning the ambiguity of certain definitions such as You Your and Defendant to avoid responding to any discovery request altogether. (Separate Statements, p. 4.) For interrogatories and RFAs, it is the responding partys obligation to provide answers as complete and straightforward as the information reasonably available to the responding party permits. (CCP §§ 2030.220(a); 2033.220(a).)
As for Defendants other technical argument, Plaintiff concedes her failure to attach signed declarations complying with code requirements about the necessity of more than 35 SPROGS, RPDs, and RFAs, but as noted, this is a curable defect that Plaintiff alleges that she has already cured. (Reply, p. 5:15-23; Rao Decl., Ex. C, p. 4.) 25CV160167: ROBIE vs STOTHERS 07/09/2026 Hearing on Motion to Compel Further Discovery Responses filed by Claudia Robie (Plaintiff) CRS# 175164897146 in Department 520 Substantively, the Court finds that, although Plaintiff may not have referenced it as such, she has shown good cause for the RPDs sought. (Falahati Decl., Ex. 2.) Thus, the burden shifts to Defendant to justify her objection, which she has not sufficiently done so. (
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'[W]here the reason put forward for refusing discovery is rather clearly without merit under the state of the authorities then existing, it is hard to see how the losing party can show that its actions were taken with substantial justification.' (2 Hogan, Modern Cal. Discovery (4th ed. 1988) § 15.3, p. 303.) (Ibid./Id. at fn. 3.)
As it is difficult to find that Defendant opposed this motion with substantial justification, monetary sanctions are awarded in the reduced amount of $760 against Defendant, jointly and severally, payable to Plaintiff forthwith.
Defendants cross-request for sanctions is denied.
NOTICE TO DEFENDANT: Defendant is advised that failure to comply with this Order may result in the imposition of future sanctions, including evidentiary, monetary, or terminating sanctions.
NOTICE: This tentative ruling will automatically become the courts final order on July 9, 2026 unless, by no later than 4:00 P.M. on July 8, 2026, a party to the action notifies BOTH: 1) the court by emailing Dept520@alameda.courts.ca.gov; AND 2) all opposing counsel or selfrepresented parties (by telephone or email) that the party is contesting this tentative ruling.
The subject line (RE:) of the email must state: Request for CONTESTED HEARING: [the case name], [number]. When a party emails to contest a tentative ruling, the party must identify the specific holding(s) within the ruling they wish to contest via oral argument.
The court does not provide court reporters for hearings in civil departments. A party who wants a record of the proceedings must engage a private court reporter. (Local Rule 3.95.) Any privately retained court reporter must also participate via video conference. Their email must be provided to the court at the time the Notice of Contest is emailed.
ALL CONTESTED LAW AND MOTION HEARINGS ARE CONDUCTED VIA REMOTE VIDEO unless an in person appearance is required by the court. Invitations to participate in the video proceeding will be sent by the court upon receipt of timely notice of contest. A party may
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
25CV160167: ROBIE vs STOTHERS 07/09/2026 Hearing on Motion to Compel Further Discovery Responses filed by Claudia Robie (Plaintiff) CRS# 175164897146 in Department 520 give email notice that they will appear in court in person for the hearing, however all other counsel/parties and the JUDGE MAY APPEAR REMOTELY.