Order to Show Cause Re: appointment of discovery referee
24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 08/05/2026 Order to Show Cause Re: appointment of disocvery referee in Department 23
Tentative Ruling - 08/05/2026 Ruben Sundeen
The Court appoints ____________________________________ to act as Discovery Referee pursuant to Code of Civil Procedure section 639. This appointment is for all consideration of all discovery motions filed as of the date of this order.
The Referee to file and serve upon all parties the certification and disclosure required pursuant to California Rules of Court, rule 3.904, as well as the information required by rule 3.931, within 10 days of service of this order.
Compensation of Referee
The Referees shall be compensated based upon an hourly rate of $_____________ per hour.
The Referee shall be compensated privately, with payment facilitated through and paid by Defendants.
Authority and Charge of Referee
The Referee is authorized and empowered to supervise, manage, and make recommendations to the Court with respect to discovery disputes currently pending, including recommending discovery sanctions. The Court may extend the referees charge to include additional later-filed discovery motions. Motions to reduce or limit the number of expert witness depositions will remain before the Court in the first instance for decision.
The Referee will not request use of court facilities or court personnel. The parties may appear before the Referee by videoconference.
The Referee shall convene, within twenty-one (21) days of entry of this order, a meeting of the parties to provide the Referee with an overview of the case, with a summary of the pending discovery motions that also highlights any common issues between the various motions, and with a proposed schedule for hearing the pending motions.
Following this meeting, the Referee shall:
1. Establish the order and timing in which motions will be heard and considered; 2. Establish the manner and method of issuing recommendations to the Court; 3. Establish the procedures and timing for filing, opposing, and hearing any new discovery motions; and 4. Establish any other protocols requested by the parties to facilitate an orderly and expedient discovery process, including conducting informal discovery conferences prior to the filing of a new discovery motion. 24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 08/05/2026 Order to Show Cause Re: appointment of disocvery referee in Department 23
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By submitting the consent to serve, the Referee represents that the Referee consents to serve as provided in this order and is aware of and will comply with applicable provisions of Canon 6 of the Code of Judicial Ethics (specifically cannon 6D) and the California Rules of Court.
Objections to Referee, or Report and Recommendation
An objection to the disclosure, if any, of the Referee made pursuant to the Code of Judicial Ethics and the California Rules of Court must be made in a verified writing that is filed and served upon the Referee and all parties within 10 days of service of the disclosure. Objections not timely filed and served will be deemed waived.
Objections to the Referees Report and Recommendations to the Court shall be made pursuant to California Code of Civil Procedure section 643(c). Objections shall be limited to six (6) total pages, including the case caption page.
Filing of Documents After Appointment of Referee
All documents submitted to and considered by the Referee must be filed in this action with a corresponding reservation number associated with the motion.
All filings related to a matter before the Referee must comport with California Rules of Court, rule 2.111(8).
Given the number of pending motions (which currently total 19), the Court requests that the Referees Report and Recommendations include the following information on the first page so that the Court can easily reference the pertinent filings:
1. The identity of the moving party and title of the motion; 2. The reservation number for the motion; and 3. The title and filing date of all documents associated with the motion.
Further Case Management and Discovery Motion Hearings
Court sets a case management conference for Thursday, September 3, 2026, at 2:30 p.m. in Department 23. The purpose of the conference is to schedule the pending discovery motions for hearing and consideration of the Referees Report and Recommendations.
The Referee to file and serve a proposed schedule for the Court to hear of the pending discovery motions seven (7) days before the case management conference.
The parties are reminded that the Courts law and motion calendar is every Thursday at 2:30 p.m. However, the Court is dark on the following Thursdays in 2026:
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 08/05/2026 Order to Show Cause Re: appointment of disocvery referee in Department 23 · September 10, 2026 · September 24, 2026 · October 1, 2026 · November 26, 2026 · December 24, 2026 · December 31, 2026
The Court requests that the Referee propose to schedule no more than three discovery motions per week. If the Referee and the parties agree that contests of the Referees Report and Recommendations are unlikely, the Referee may propose increasing the number of motions per week that the Court will consider.
If not already filed, the timing of opposition and reply briefs to be based upon the hearing date set after consideration of the Referees proposed schedule or as determined by the Referee.
No supplemental opposition or supplemental reply or sur-reply filings allowed except as allowed by the Referee.