Motion to Compel Further Responses to Form Interrogatories, Special Interrogatories, and Request for Production of Documents, Set One; and Sanctions
SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 1 Honorable Eunice Lee, Presiding TBD, Courtroom Clerk 191 North First Street, San Jose, CA 95113
DATE: July 16, 2026 TIME: 9:00 A.M. and 9:01 A.M. To contest the ruling, call the Court at (408) 808-6856 before 4:00 P.M. Make sure to also let the other side know before 4:00 P.M. that you plan to contest the ruling, in accordance with California Rule of Court, Rule 3.1308(a)(1) and Local Rule 8D.
**Please specify the issue to be contested when calling the Court and counsel**
LAW AND MOTION TENTATIVE RULINGS LINES 24CV444939 Timed Out, LLC Motion to Compel Further Responses to Form Interrogatories, 3-5 vs Liquid Special Interrogatories, and Request for Production of Documents, Restaurant and Set One; and Sanctions. Lounge LLC Parties to appear. Before the court is Plaintiff Timed Out, LLC’s (“Timed Out”) motion to compel responses to the following discovery: further responses to Form Interrogoatires (“FROG”); further responses to Special Interrogatories (“SPROG”); further responses to Request for Production of Documents (“RFPD”), Set One; and Motion for Sanctions against Defendant Liquid Restaurant and Lounge LLC’s (“Liquid Restaurant”).
On December 22, 2025, Plaintiff Timed Out filed this motion to compel further responses to 216 total discovery responses as follows: 13 FROGs (Nos. 1.1, 3.1-3.7, 4.1, 4.2, 15.1, 16.1, and 17.1); 134 SPROGs (Nos. 1-134); and 69 RFPDs (Nos. 1-69).
Plaintiff Timed Out also filed a motion to compel further responses to Request for Admissions (“RFA”), Nos. 1-83 that is set for hearing on August 13, 2026. In total, Plaintiff seeks to compel 299 further discovery responses for FROGs (Nos. 1.1, 3.1-3.7, 4.1, 4.2, 15.1, 16.1, and 17.1); SPROG (Nos. 1-134); RFPD (Nos. 1-69), and RFA (Nos. 1- 83), Set One.
The Court has reviewed the plaintiff’s moving papers filed on December 22, 20255; defendant Liquid Restaurant’s Oppositions filed on July 2, 2026; and the plaintiff’s Reply to defenses’ opposition filed on July 9, 2026; as well as the pleadings. Given the total number—299—of discovery at issue, the Court orders the parties to meet-and-confer and submit a joint statement setting forth discovery that has been resolved and remain at issue. The Court will also discuss having this matter assigned to a discovery referee under Code of Civil Procedure section 639 and 645.1
SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 1 Honorable Eunice Lee, Presiding TBD, Courtroom Clerk 191 North First Street, San Jose, CA 95113
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DATE: July 16, 2026 TIME: 9:00 A.M. and 9:01 A.M. To contest the ruling, call the Court at (408) 808-6856 before 4:00 P.M. Make sure to also let the other side know before 4:00 P.M. that you plan to contest the ruling, in accordance with California Rule of Court, Rule 3.1308(a)(1) and Local Rule 8D.
**Please specify the issue to be contested when calling the Court and counsel**
LAW AND MOTION TENTATIVE RULINGS The court orders that all three discovery motions on calendar today and the motion to compel further responses to RFA set for August 13, 2026 are CONTINUED to September 22, 2026 at 9:00 a.m. in Department 1.
The parties are ordered to conduct good faith, reasonable and meaningful conferences, and meet-and-confer in person, by audio telephone, or video conference, to narrow the many issues in these motions. If any issues remain after the meet and confer efforts, which may span several sessions, the parties shall file an updated joint statement no later than September 14, 2026, which shall identify the remaining items in dispute and the reasons why further responses should/should not be compelled. Additionally, parties are to discuss the retaining a private discovery referee or discovery facilitator offered by the Court [https://santaclara.courts.ca.gov/divisions/civil-division/civil-adr- providers/discovery-facilitator-program]. Failure to comply with this order will result in consideration of sanctions.
The Court will prepare the Order.
LINES 25CV471084 Maria Ruiz vs Motion to Strike (Line # 7) and Demurrer (Line # 8) 6-7 Toyota Motor Scroll down to Lines 7 - 8 for Tentative Ruling. Sales, U.S.A., Inc. et al.
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