JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver

24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Form Interrogatories, Set One in Department 8D

and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporter’s Office and an official reporter will be provided

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G. ST. SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 25 WILL BE HEARD IN DEPARTMENT 8D OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION****

TENTATIVE RULING

Plaintiff’s Notice of Motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06(D). Plaintiff’s counsel is directed to contact opposing counsel forthwith to advise counsel of Local Rule 1.06 and the Court’s tentative ruling procedure. If Plaintiff’s counsel is unable to contact opposing counsel prior to the hearing, Plaintiff’s counsel shall be available at the hearing, in person or remotely (telephonically or by video conference via Zoom as stated in the introductory notice to today’s tentative rulings), in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

Plaintiff Heidi Johannsen’s (“Plaintiff”) Motion to Compel Further Response to Form Interrogatory, Set One, No. 17.1 from Defendant National Union Fire Insurance Company of Pittsburgh, PA (“Defendant”) is ruled upon as follows.

Factual Background

Plaintiff served her first set of discovery on April 21, 2025, including the at issue interrogatory. (Sanchez Decl., ¶ 2.) Defendant served its responses on May 30, 2025. (Sanchez Decl., ¶ 3.)

Plaintiff now moves to compel further response to form interrogatory, set one, no. 17.1. Defendant opposes.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Form Interrogatories, Set One in Department 8D

To the extent that Plaintiff’s separate statement seeks to compel further response to each request for admission, this request is denied. The instant motion is to compel further responses to form interrogatories, not requests for admission. Further, were Plaintiff to seek to compel further responses to form interrogatories and requests for admission in the instant motion, this would not comply with Local Rule 2.31(E), which states:

When simultaneously filing multiple discovery-related motions in the same case with the same hearing date, each motion shall be filed as a separate document and a separate filing fee paid for each. Parties may not combine motions pertaining to different types of discovery within the same document. Failure to comply with any part of this rule regarding discovery motions may, in the discretion of the court, be grounds for the motions being dropped without consideration.

(Emphasis added.)

Interrogatory at Issue

Form Interrogatory No. 17.1 states:

Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission:

(a) state the number of the request; (b) state all the facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and, (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS and telephone number of the PERSON who has each DOCUMENT or thing.

In response, Defendant objected:

National Union objects to this interrogatory on the grounds it is vague, ambiguous, overbroad, and unduly burdensome. National Union objects to this

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Form Interrogatories, Set One in Department 8D

interrogatory on the grounds it seeks information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence.

Defendant additionally provided the same substantive response with respect to requests for admission nos. 1-58:

(a) Request for Admission No. [1-58] (b) National Union has made a reasonable inquiry concerning the matter in this request, and the information known or readily obtainable is insufficient to enable National Union to admit or deny this request. National Union therefore denies it. Moreover, this request seeks that National Union admit to facts concerning an incident that did not involve National Union. (c) Ignatius Richards via counsel for Responding Party, Plaintiff, and Laura Panasyuk. (d) National Union does not have documents supporting its response to this request.

Discussion

Plaintiff argues that Defendant’s response is deficient, as Defendant “has provided substantively identical responses to all 58 Requests for Admission, claiming “insufficient information” to admit or deny and then universally failing to provide the required detailed information under Form Interrogatory 17.1.” In opposition, Defendant argues that Plaintiff brings the instant motion because she is dissatisfied with Defendant’s responses to requests for admission, not because of any specific defect in Defendant’s responses. Defendant further argues that each of Plaintiff’s requests for admission are inherently improper because they are admissions regarding legal conclusions as opposed to factual admissions.

Code of Civil Procedure section 2030.220 requires that responses to Interrogatories be as “complete and straightforward” as the information reasonably available to the responding party permits, and “if an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220(a), (b); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 788-89.) Defendant has a duty to obtain responsive information and must furnish it from sources under its control. (Ibid.) If Defendant is not aware of any specific facts, witnesses or documents that are responsive to these interrogatories, then Defendant must state as much. (Code Civ. Proc. § 2030.220.)

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Form Interrogatories, Set One in Department 8D

Defendant’s response to form interrogatory no. 17.1 as to each request for admission states that Defendant lacks sufficient information to admit or deny each and that the incident which are the subject of Plaintiff’s requests for admission did not involve Defendant. However, Defendant does not state that it does not have any knowledge pertaining to the incident or with respect to each request for admission. Defendant argues that section 2030.220 does not require a response where the information sought is equally available to the propounding party. However, Defendant did not raise an objection on the grounds that information is equally available to Plaintiff, and cannot assert one for the first time here.

Defendant’s reliance on Holguin v. Superior Court (1972) 22 Cal.App.3d 812, is misplaced, as the Court in Holguin did not consider the merits of the set of interrogatories which “call for the factual bases for defendants' denials of facts they had been asked to admit.” (Id., at p. 818 [noting that no issue was before it with respect to the sufficiency of answers to interrogatories regarding the factual bases of defendants’ denials of facts in requests for admission].) Holguin does not stand for the proposition that, as Defendant argues, the failure to identify facts in support of a failure to answer a request for admission is universally an acceptable response. Rather, in Holguin the Court noted that the trial court had ordered that such interrogatories had to be answered.

The Court notes that Defendant did not assert any objection in response to form interrogatory no. 17.1 that the information is equally available to Plaintiff. Nor does Defendant state that it is unaware of any facts in support of its purported inability to admit or deny the request.

Therefore, the Court finds that Defendant failed to respond to the interrogatory as completely as the information reasonably available to the Defendant permits. Plaintiff’s motion to compel is GRANTED. Defendant is to serve verified amended responses to form interrogatory no. 17.1 by no later than May 20, 2026.

Plaintiff’s request for sanctions is GRANTED in the amount of $860 ($400/hour x 2 hours plus $60 filing fee). Defendant is to pay monetary sanctions to Plaintiff on or before May 20, 2026. If the sanction is not paid by that date, Plaintiff may prepare for the court's signature a formal order granting the sanction, which may be enforced as a separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Form Interrogatories, Set One in Department 8D

The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.