Motion to Compel Further Responses to Request for Admission, Set One
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24CV023707: JOHANNSEN vs NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA, et al. 05/06/2026 Hearing on Motion to Compel Further Responses to Request for Admission, Set One in Department 8D
Tentative Ruling
NOTICE: PLEASE TAKE NOTICE that pursuant to Public Notice Civil Division Wednesday Law and Motion Calendar any oral arguments regarding this tentative ruling will be heard in Department 8D, located at 500 G Street, Sacramento, CA, the Hon. Julie G. Yap presiding. Should argument be requested by either party, the requesting party must call the Law and Motion Oral Argument Request Line at (916) 874-2615, by 4:00 p.m. the Court day before the hearing, request the hearing, and notify the opposing party of the location and time of hearing pursuant to Local Rule 1.06.
At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.
The Court encourages parties to appear remotely for the hearing on the tentative ruling through the Courts Zoom Application. But, any party wishing to appear in person may do so, provided that party notifies the Court by 4:00 the Court day before the hearing. The parties may join the Zoom session for hearing on the tentative ruling by audio and/or video through the following link: https://saccourt-ca-gov.zoomgov.com/j/16113421868 SIP Address: 16113421868@sip.zoomgov.com (833) 568-8864 ID: 16113421868 Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956.
Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.Pdf A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Courts Approved Official Reporter Pro Tempore list.
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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 Request for Admission, 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 Reporters 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
Plaintiffs Notice of Motion does not provide notice of the Courts tentative ruling system, as required by Local Rule 1.06(D). Plaintiffs counsel is directed to contact opposing counsel forthwith to advise counsel of Local Rule 1.06 and the Courts tentative ruling procedure. If Plaintiffs counsel is unable to contact opposing counsel prior to the hearing, Plaintiffs 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 todays tentative rulings), in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).
Plaintiff Heidi Johannsens (Plaintiff) Motion to Compel Further Response to Requests for Admission from Defendant National Union Fire Insurance Company of Pittsburgh, PA (Defendant) is ruled upon as follows.
Factual Background
Plaintiff served the at issue discovery requests on April 21, 2025. (Sanchez Decl., ¶ 2.) Defendant served its responses on May 30, 2025. (Sanchez Decl., ¶ 3.)
Plaintiff now moves to compel further response to requests for admission, set one, request nos. 2, 6, 7, 9, 10, 11, 12, 14, 16, 17, 19, 20, 21, 54, 55, 56, 57, and 58. 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 Request for Admission, Set One in Department 8D
Requests at Issue
Request for Admission No. 2: The percentage of fault attributable to PLAINTIFF for THE CRASH is zero percent (0%).
Request for Admission No. 6: At the time of THE CRASH, UIM DRIVER was an underinsured motorist.
Request for Admission No. 7: At the time of THE CRASH, UIM DRIVER did not have sufficient liability insurance to fully compensate PLAINTIFF for the injuries PLAINTIFF suffered in THE CRASH.
Request for Admission No. 9: The percentage of fault attributable to UIM DRIVER for THE CRASH is one hundred percent (100%).
Request for Admission No. 10: The percentage of fault attributable to UIM DRIVER for THE CRASH is at least fifty percent (50%).
Request for Admission No. 11: The percentage of fault attributable to UIM DRIVER for THE CRASH is greater than one percent (1%).
Request for Admission No. 12: The legal cause of THE CRASH was UIM DRIVERs negligent operation of a motor vehicle.
Request for Admission No. 14: UIM DRIVERs negligent operation of the vehicle that UIM DRIVER was driving at the time of THE CRASH was a substantial factor in causing damage to the vehicle carrying PLAINTIFF.
Request for Admission No. 16: UIM DRIVERs negligent operation of the vehicle UIM DRIVER was driving at the time of THE CRASH was a substantial factor in causing PLAINTIFF bodily injury.
Request for Admission No. 17: PLAINTIFF did not contribute to causing any of the bodily injuries PLAINTIFF suffered in THE CRASH.
Request for Admission No. 19: THE CRASH caused PLAINTIFF to experience pain.
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 Request for Admission, Set One in Department 8D
Request for Admission No. 20: THE CRASH caused PLAINTIFF experience suffering.
Request for Admission No. 21: THE CRASH caused PLAINTIFF to suffer emotional distress.
Request for Admission No. 54: THE CRASH was a substantial factor in causing PLAINTIFF to suffer damages of at least $15,001.
Request for Admission No. 55: THE CRASH was a substantial factor in causing PLAINTIFF to suffer damages of at least $25,001.
Request for Admission No. 56: THE CRASH was a substantial factor in causing PLAINTIFF to suffer damages of at least $250,001.
Request for Admission No. 57: THE CRASH was a substantial factor in causing PLAINTIFF to suffer damages of at least $500,001.
Request for Admission No. 58: THE CRASH was a substantial factor in causing PLAINTIFF to suffer damages of at least $985,001.
Defendant responded to each stating:
National Union objects on the basis that Plaintiff has improperly propounded this request pursuant to Code of Civil Procedure section 2031.010. National Union further objects to this request on the grounds that it is vague and ambiguous with respect to the phrase [percentage of fault attributable/ underinsured motorist/ fully compensate/ legal cause/ substantial factor/ contribute to causing/ pain/ suffering/ emotional distress/ substantial factor.] Subject to and without waiving the foregoing objections, National Union responds as follows:
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.
Discovery is continuing and National Union reserves its right to supplement and/or amend its response following completion of its investigation including third party discovery.
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 Request for Admission, Set One in Department 8D
Discussion
As a preliminary matter, the Court finds that Defendants response, while identical across all requests, is code compliant. Code of Civil Procedure section 2033.220 states:
(a) Each answer in a response to requests for admission shall be as complete and straightforward as the information reasonably available to the responding party permits.
(b) Each answer shall:
(1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party.
(2) Deny so much of the matter involved in the request as is untrue.
(3) Specify so much of the matter involved in the request as to the truth of which the responding party lacks sufficient information or knowledge.
(c) If a responding party gives lack of information or knowledge as a reason for a failure to admit all or part of a request for admission, that party shall state in the answer that a reasonable inquiry concerning the matter in the particular request has been made, and that the information known or readily obtainable is insufficient to enable that party to admit the matter.
(Emphasis added.)
Plaintiff argues that Defendants objections are misplaced, However, she fails to provide any argument as to why further substantive response is required. While Plaintiff argues that Defendant has stubbornly taken the meritless position that eighteen (18) requests for admission are supposedly too vague to answer (Mtn., p. 4:19-20). Defendants response to these requests does not indicate that the inability to respond is based on the objections. This is further supported by Defendants argument in opposition that [Defendant] lacked personal knowledge to respond to Plaintiffs fundamentally defective RFAs that all involved facts concerning an accident that National Union was not involved in. (e.g., Opp. Sep. State., p. 8:3-5.) As noted by Defendant, it is entitled to assert appropriate objections while still providing substantive responses. (e.g., id., p.
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 Request for Admission, Set One in Department 8D
6:15.)
Defendants objections of vague and ambiguous are overruled.
Nevertheless, based on the foregoing, Plaintiffs motion to compel is DENIED, in its entirety. Based on the disposition of the motion, Plaintiffs request for sanctions is also DENIED.
The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.