Motion – Compel Discovery Facilitator Program; Motion – Compel – Discovery Facilitator Program
2) MOTION – COMPEL – DISCOVERY FACILITATOR PROGRAM
Plaintiff Cabouchon Properties, LLC, (“Plaintiff”) filed a motion to compel further responses to written discovery and for sanctions in the amount of $4,500 against Defendant LL&L, LLC, (“Defendants”).
The discovery requests and responses at issue encompass Form Interrogatories, Special Interrogatories, and Requests for Production. At issue are Defendant’s responses to Form Interrogatory Nos. 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 14.1 and 16.1, which object to the term “INCIDENT” and do not otherwise provide any responses. Plaintiff also moves to compel further responses to 15.1. As to the Special Interrogatories, Plaintiff takes issues with nos. 3-6, 9-11, 14-23, 26-37, 43, 45-47, 58-62, 69-82. Plaintiff also moves to compel further responses/documents in response to nos. 1-8, 19, 21-23, 28-32 on the basis that no documents have been produced and Defendant’s responses fail to identify the documents that are responsive to the request.
Defendant opposes this motion on the basis that a separate statement was not filed, but this is incorrect. Defendant also asserts that some documents have been produced and that amended responses were filed. Defendant attached amended responses to a few of the requests for documents. However, it appears that no responses have been provided that address the alleged deficiencies to the Form Interrogatories or the Special Interrogatories.
On July 13, 2026, Jill Manning was appointed as the Discovery Facilitator to preside over this dispute. It is unclear whether the parties had an opportunity to meet with Ms. Manning. Pursuant to local rule MCR 2.13, the parties were required file a Declaration of Non-Resolution
if the matter did not resolve with the Discovery Facilitator. No Declaration was filed and therefore, the court has no information as to the status of the dispute.
Appearances required.
All parties must comply with Marin County Superior Court Local Rules, Rule 2.10(B) to contest the tentative decision. Parties who request oral argument are required to appear in person or remotely by ZOOM. Regardless of whether a party requests oral argument in accordance with Rule 2.10(B), the prevailing party shall prepare an order consistent with the announced ruling as required by Marin County Superior Court Local Rules, Rule 2.11.
The Zoom appearance information for August, 2026 is as follows: https://marin-courts-ca-gov.zoomgov.com/j/1615487764?pwd=Ob4B5J7LLKcpnkxzJjjEOSHNzEGafG.1
Meeting ID: 161 548 7764 Passcode: 502070
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