JENIFER HANKI VS. WAYMO LLC, A DELAWARE LIMITED LIABILITY COMPANY ET AL

Set for Law and Motion/Discovery Calendar on Monday, July 27, 2026, Line 6. Plaintiff Jennifer Hanki's motion to compel further responses to her first sets of general form interrogatories, special interrogatories and requests for production of documents from defendant Waymo LLC is denied. No later than August 14, 2026 Hanki and her counsel must pay $2,288 as reasonable sanctions to Waymo.

CCP 2016.040(a) provides that "[a] meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion." Hanki's counsel merely sent a meet and confer letter on April 22, 2026. (Nystrom Decl., par. 24, Ex. O.) The letter does not satisfy the requirements of section 2016(a)(4). That letter explicitly contemplated that if Waymo agreed to an extension of the deadline to file a motion, to compel, the parties would then engage in "meaningful meet and confer."

Despite Waymo agreeing to the extension and then serving supplemental responses to the discovery at issue on this motion, Hanki's counsel failed to engage in further meet and confer. (Noosha Decl., pars. 7-8; Nystrom Decl., pars. 8-9 and 20-21.) Plaintiff fails to demonstrate that she meaningfully met and conferred, especially since there was no communication between the parties after service of the supplemental responses. Hanki should have taken this motion off calendar when requested by Waymo. Hanki and her counsel did not act with substantial justification with regard to the required meet and confer and efforts. The sanctions amount is calculated at four hours at an hourly rate of $572.

For the 9:00 a.m. calendar, all attorneys and parties may appear in Department 302 remotely or in person. Remote hearings will be conducted by videoconference using Zoom. (Dept. 302 Zoom ID 160 409 7690; Passcode 516287.) To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number.

Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing.

Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested.