MENOR, et al. vs CHANEL, INC., et al.

The Court ORDERS Estee to provide a verified Second Amended Response to FROG No. 3.1, which seeks information from Estee, not ELC. Further, Estee must also provide a verification verified on behalf of Estee, not ELC. 26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/04/2026 Hearing on Motion to Compel Estee Lauder Inc. Responses to Plaintiffs' Form Interrogatories and Request for Production (Set One); filed by JOVY MENOR (Plaintiff) + CRS# 480491203562 in Department 18

Although the Court would have overruled the objections to Estee’s initial Response to FROG No. 4.1 as lacking in merit, the Court finds Estee’s initial Response is adequate under the circumstances. However, Estee’s 7/12/2026 Amended Response states that it is being made on behalf of ELC. Although the Court finds the Amended Response adequate if Estee has no relevant policies of insurance, the Court ORDERS Estee to provide a Second Amended Response to FROG No. 4.1 clearly stating that it is being made on behalf of Estee.

The Court ORDERS Estee to serve verified Second Amended Responses to FROG Nos. 12.1, 12.2, 12.4, 12.5 and 12.6 clearly stating that Estee, rather than ELC, is responding each of these FROG.

The Court ORDERS Estee to serve verified Second Amended Responses to FROG Nos. 13.1 and 13.2 clearly stating that Estee, rather than ELC, is responding each of these FROG.

The Court OVERRULES Defendant’s Objection to each of FROG Nos. 14.1 and 14.2. Although the defined term “INCIDENT” is somewhat vague and ambiguous, it is not so vague and ambiguous that Estee cannot respond substantively to these FROG. The Court ORDERS Estee to serve verified Second Amended Responses to FROG Nos. 14.1 and 14.2 clearly stating that Estee, rather than ELC, is responding each of these FROG.

With respect to the privilege objections asserted by Estee in its Amended Response to FROG No. 15.1, the Court will allow Estee to assert them. Further, the Court will not require Estee to produce expert witness information prior to the time required by CCP § 2034.010 et seq.

The Court ORDERS Estee to serve a verified Second Amended Response to FROG No. 15.1 clearly stating that Estee, rather than ELC, is responding to FROG No. 15.1.

The Court ORDERS Estee to serve verified Second Amended Response to FROG No. 16.1 clearly stating that Estee, rather than ELC, is responding to FROG No. 16.1. The Court will permit Estee’s privilege objections to FROG Nos. 16.2, 16.3 and 16.4 and will not require Estee’s premature disclosure of expert witness information.

The Court ORDERS Estee to serve verified Second Amended Responses to FROG No. 16.2, 16.3 and 16.4 clearly stating that Estee, rather than ELC, is responding to these FROG.

The Court ORDERS Estee to serve verified Second Amended Responses to FROG Nos. 16.5, 16.9 and 16.10 clearly stating that Estee, rather than ELC, is responding to these FROG.

2. Motion to Compel Further RFPD Responses.

The Court elects to consider Plaintiffs’ Reply Separate Statement regarding Estee’s Second

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/04/2026 Hearing on Motion to Compel Estee Lauder Inc. Responses to Plaintiffs' Form Interrogatories and Request for Production (Set One); filed by JOVY MENOR (Plaintiff) + CRS# 480491203562 in Department 18 Amended RFPD Responses served on 7/21/2026. However, Plaintiffs’ request for monetary sanctions is DENIED, because the Reply papers contain no evidence Plaintiff met and conferred with Estee regarding the Amended FROG Responses.

The Court ORDERS Estee to provide verified Third Further Responses to each of RFPD Nos. 2, 11-19 and 22-30 stating clearly that the responses are being made by Estee rather than ELC and containing a verification being made on behalf of Estee. The Court otherwise DENIES Plaintiffs’ requests for further responses as a violation of CCP § 2023.010(c) in the context of this trial preference action.

ANALYSIS OF MOTION TO COMPEL – ELC

1. Motion to Compel Further FROG Responses.

The Court DENIES Plaintiffs’ Motion to Compel Further Responses to FROG Nos. 3.1, 4.1, 12.1, 12.2, 12.4, 12.5 and 12.6. The Court finds ELC’s Amended Responses adequate under the circumstances. The Court also finds ELC’s initial responses substantively acceptable although the propounded objections lack merit. Finally, the Court finds that the Amended Responses are adequately verified to bind ELC to the Amended Responses.

Although the term “INCIDENT” is somewhat vague and ambiguous, it is not so vague and ambiguous that ELC cannot provide substantive responses to FROG Nos. 14.1 and 14.2. Therefore, the Court OVERRULES ELC’s objections to FROG Nos. 14.1 and 14.2.

However, the Court DENIES Plaintiffs’ Motion to Compel Further Responses to FROG Nos. 14.1 and 14.2. The substantive responses provided in both the initial Responses and the Amended Responses are adequate.

The Court will allow ELC’s privilege Objections with respect to FROG No. 15.1 and will not require ELC to disclose expert witness information prior to the time provided for pursuant to CCP z§ 2034.010 et seq.

The Court DENIES Plaintiffs’ Motion to Compel a Further Response to FROG No. 15.1. The Court finds Defendant’s initial and amended Responses acceptable in the context of this trial preference action. Had Plaintiffs more promptly served their FROG, they could have filed a Motion for Summary Adjudication to dispose many of what appear to be an excessive number of affirmative defenses.

The Court DENIES Plaintiff’s request for a further response to SROG No. 16.1. ELC’s Amended Response is acceptable.

The Court will allow ELC’s privilege Objections with respect to FROG Nos. 16.2, 16.3 and 16.4

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/04/2026 Hearing on Motion to Compel Estee Lauder Inc. Responses to Plaintiffs' Form Interrogatories and Request for Production (Set One); filed by JOVY MENOR (Plaintiff) + CRS# 480491203562 in Department 18 and will not require ELC to disclose expert witness information prior to the time provided for pursuant to CCP z§ 2034.010 et seq.

The Court DENIES Plaintiffs’ request for further responses to FROG Nos. 16.2, 16.3 and 16.4. ELC’s amended Responses are acceptable.

The Court DENIES Plaintiffs’ request for further responses to FROG No. 16.5, 16.9 and 16.10. ELC’s amended Responses are acceptable.

2. Motion to Compel Further RFPD Responses.

The Court DENIES Plaintiffs’ Motion to Compel Further Responses to RFPD Nos. 2, 11-19 and 22-30 in its entirety. ELC’s Amended Responses are adequate in the context of this trial preference action.

Estee shall serve verified Further Responses to the extent Ordered above no later than 3:00 p.m. on Monday, 8/24/2026.

The Court finds that Plaintiffs’ Motion to Compel defendant ELC’s Further Responses to FROG and RFPD is both a misuse of this Court’s limited judicial resources and violates CCP § 2023.010(c) in the context of this trial preference action. Plaintiffs could have taken this Motion off calendar once they received Defendant’s Amended Responses but elected to proceed to hearing.

Wherefore, the Court AWARDS ELC a monetary sanction in the amount of $2,000 to be paid by Plaintiffs, an amount the Court finds appropriate under the circumstances where Plaintiffs request monetary sanctions in the amount of $3,250 in the moving papers.

CONTESTING THE TENTATIVE RULING: If the parties do not contest the tentative ruling, it will be adopted. Any party wishing to contest the tentative ruling must notify the court by email at Dept18@alameda.courts.ca.gov, and notify all opposing counsel or unrepresented parties by 4pm the day before the hearing.