Motion to compel further responses to requests for production; Motion to compel production of ESI; Motion for sanctions
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Case: Parazar v. Purves Case No. CV2025-0463 Hearing Date: July 30, 2026 Department Thirteen 9:00 a.m.
On the Court’s own motion, plaintiff Atlanta O. Parazar’s motion to compel defendant Purves & Associates Insurance Agency of Davis, Inc.’s further responses to requests for production (set one), compel production of responsive documents pursuant to electronically stored information requirements, and request for sanctions (filed June 15, 2026) is CONTINUED to September 8, 2026, at 9:00 a.m. in Department Thirteen. The parties are DIRECTED to further meet and confer regarding the issues raised by plaintiff’s motion – in person, by videoconference, or by telephone – by August 13, 2026. (Code Civ.
Proc., § 2016.040, subd. (a) [“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”]); see also Townsend v. Superior Court (1998) 61 Cal.App.4th 1431, 1434-1435 & 1439; Hanassab decl., ¶ 6.)
By August 28, 2026, the parties MUST file either: (1) a joint statement, not to exceed six pages, regarding the parties’ meet and confer efforts showing discussion of the scope of proposed discovery of ESI, further explaining the requested ESI as narrowly and precisely as possible, discussing the factors set forth in Code of Civil Procedure section 2031.310 (g), and identifying any remaining issues for the Court’s determination; or (2) individual statements, not to exceed three pages, regarding the parties’ meet and confer efforts showing discussion of the scope of proposed discovery of ESI, further explaining the requested ESI as narrowly and precisely as possible, discussing the factors set forth in Code of Civil Procedure section 2031.310 (g), and identifying any remaining issues for the Court’s determination. (See Hanassab decl., ¶¶ 12-18; Wheeler decl., ¶¶ 4 & 7-18.)
If appropriate, the parties must also file amended separate statements by this deadline. (See Cal. Rules of Court, rule 3.1345.)
If there are no remaining issues, plaintiff is DIRECTED to request that the September 8, 2026, hearing be vacated.
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