Motion to Compel Further Discovery Responses
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25CV114620: ARIF vs PRECISION GLOBAL CONSULTING, INC., et al. 08/04/2026 Hearing on Motion to Compel Further Discovery Responses filed by Abdulhai Arif (Plaintiff) CRS# 313450148039 in Department 21
Tentative Ruling - 08/03/2026 S. Raj Chatterjee
The Motion to Compel Further Discovery Responses filed by Abdulhai Arif on 05/28/2026 is Granted in Part.
The Motion of Plaintiff to compel further responses to special interrogatories is GRANTED IN PART. The Motion of Plaintiff to compel further production of documents is GRANTED IN PART.
BACKGROUND
Plaintiff Arif worked within California as a non-exempt hourly employee for Defendants between March 2023 and September 2024. Plaintiff asserts various Labor Code claims against Phaidon International (temp agency), Precision Global Consulting (payroll processor), and Exelixis (the workplace company). Plaintiff seeks to represent seven classes, each of which is All non-exempt hourly employees who worked for Defendants in California [who have a claim under a Labor Code section.]
Plaintiff argues The relevant employer for class purposes is not Exelixis; it is Defendant Phaidon the single staffing agency that placed all of the putative class members and PGC, the single employer of record that paid them. The approximately 297 end clients are the analogue of Marshalls many store locations [as in Williams v. Superior Court], not of separate defendants.
Defendant argues that the relevant employer is Exelixis because Exelixis made all the decisions about when Plaintiff clocked in and out and took meal and rest breaks. Defendant states that all the other workplace companies are not relevant, noting From the purported class period of March 2021 through the present, Defendant has assigned temporary workers to approximately two hundred and ninety-seven (297) completely separate end clients throughout California.
Plaintiff served discovery on defendants Phaidon and PGC (temp agency and payroll processor) seeking information about employees of Defendants. Defendants limited their responses to documents relating only to temporary workers assigned to Exelixis.
THE DISCOVERY REQUESTS AT ISSUE
The Document requests are:
(1)Payroll policies (2)Employee handbooks (3)Payroll manuals 25CV114620: ARIF vs PRECISION GLOBAL CONSULTING, INC., et al. 08/04/2026 Hearing on Motion to Compel Further Discovery Responses filed by Abdulhai Arif (Plaintiff) CRS# 313450148039 in Department 21 (7)Meal and rest period polices (8)Overtime polices (9)pay and/or earnings codes on YOUR hourly California employees pay stubs (10)pay codes used in payroll processing on YOUR hourly California employees pay stubs (11)earnings codes used in payroll processing on YOUR hourly California employees pay stubs (12)job codes used in payroll processing (13) DOCUMENTS that discuss how YOU calculate the regular rate for overtime purposes (14) DOCUMENTS that describe all shift premiums and/or shift differentials (15) DOCUMENTS that describe all bonuses, awards, and/or incentive pay (16) DOCUMENTS that explain how to interpret and/or read YOUR pay stubs (17) employment policies applicable to hourly California employees regarding timekeeping, tardy policies, workweeks, overtime, paying or calculating pay, rounding and/or reimbursement policies/practices. (18) (ESI) for a random sampling of time records for 40% of YOUR hourly California employees (19) (ESI) for a 40% sampling of pay records of YOUR hourly California employees (20) (ESI) for a 40% sampling of pay stubs of YOUR hourly California employees (21) exemplars of meal waivers (22) exemplars of new hire packets (23) new hire orientation materials (24) timekeeping systems operation manuals (25) payroll systems operation manuals (26) Time and Attendance policies (27) meal waiver revocations for Plaintiff ABDULHAI ARIF (28) policies that detail how Paid Time Off is paid to employees (29) wage guidelines for nonexempt positions (30) DOCUMENTS that describe YOUR pay period frequency
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The special interrogatories are:
(1) IDENTIFY each PERSON that has worked within the State of California for YOU (2) How many hourly employees working within the State of California are currently employed by YOU? (3) What is the total number of hourly employees working within the State of California that are employed by YOU during the RELEVANT TIME PERIOD? (4) IDENTIFY how YOU calculate overtime during each pay period, during the RELEVANT TIME PERIOD. (5) IDENTIFY in electronic format, a list for all hourly employees working within the State of California for YOU during the RELEVANT TIME PERIOD, which shall include but not be limited to dates of employment, job code, and job title. (6) IDENTIFY what timekeeping system YOU used during the RELEVANT TIME PERIOD and the dates each system was used.
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
25CV114620: ARIF vs PRECISION GLOBAL CONSULTING, INC., et al. 08/04/2026 Hearing on Motion to Compel Further Discovery Responses filed by Abdulhai Arif (Plaintiff) CRS# 313450148039 in Department 21 ANALYSIS
Regarding documents, Phaidon International (temp agency) and Precision Global Consulting (payroll processor) must produce documents that concern and apply to all the workers they hire and for whom they provide payroll without regard to placement at any specific workplace company. These will include documents that concern workers placed at Exelixis and workers placed at all locations including Exelixis. These will not include documents that do not concern workers placed at Exelixis.
Regarding interrogatories 1 and 5, Defendants must produce only the names and contact information of hourly employees placed at Exelixis following a Belaire-West procedure. Plaintiff must pay the expense of that procedure. (Williams v. Superior Court (2017) 3 Cal.5th 531.)
Regarding interrogatories 2, 3, 4, and 6, Defendants must provide only information regarding hourly employees placed at Exelixis.
The Court ORDERS that Defendant must provide responses to the document requests and special interrogatories within 30 days of this order.
PLEASE NOTE: This tentative ruling will become the ruling of the court if uncontested by 04:00pm the day before your hearing. If you wish to contest the tentative ruling, then both notify opposing counsel directly and the court at the eCourt portal found on the courts website: www.alameda.courts.ca.gov.
If you have contested the tentative ruling or your tentative ruling reads, parties to appear, please use the following link to access your hearing at the appropriate date and time: https://alameda-courts-ca-gov.zoomgov.com/my/department21. If no party has contested the tentative ruling, then no appearance is necessary.