S. vs. DOE 1

9. 30-2022- See #2, above. 01259921 S. vs. DOE 1

10. 30-2023- Before the Court is one Motion to Compel Deposition, and 01330408 Sanctions, brought by Plaintiff and Cross-Defendant U.S. U.S. Bank Bank National Association (“Plaintiff”) against Defendant National and Cross-Complainant Pacific Life Insurance Company Association vs. (“Defendant”). ROA 361. Pacific Life Insurance On July 9, 2025, the Court heard oral argument from both Company parties in open court. Importantly, the parties stipulated that Defendant’s objections to Plaintiff’s notice of deposition were timely served in accordance with their mutual agreement to extend Defendant’s deadline to file either objections or a Motion to Quash.

The Court’s original tentative ruling found, on the record before the Court, that Defendant’s objections were not timely served and were therefore waived. Pursuant to the foregoing, the Court will proceed to address the merits of Defendant’s objections to Plaintiff’s Notice of Deposition only.

The underlying controversy concerns the payment of death benefits under a life insurance policy. The action involves claims of breach of contract, breach of the covenant of good faith and fair dealing, promissory estoppel, and unjust enrichment, as well as counterclaims that the underlying policy is void under Delaware law. ROA 361, p.7.

Plaintiff seeks an order, pursuant to California Code of Civil Procedure Section 2025.450, compelling Defendant, within six (6) days of a ruling on this motion, to produce its persons most qualified (“PMQ”) to testify on the topics specified in Plaintiff’s Notice of Deposition served on Defendant on March 6, 2026. ROA 361, p.2