Motion for judgment on the pleadings; Motion to compel further responses to requests for production of documents, requests for admissions, and special interrogatories; Motion for sanctions
Case: City of Woodland v. Patel Case No. CV2024-3350 Hearing Date: August 6, 2026 Department Fourteen 9:00 a.m.
Motion for judgment on the pleadings:
Plaintiff City of Woodland’s evidentiary objections to the declarations of Craig A. Hansen and Wing C. Dam are SUSTAINED. (Cloud v. Northrop Grumman Corp. (1998) 67 Cal.App.4th 995, 999 [“Presentation of extrinsic evidence is...not proper on a motion for judgment on the pleadings”].)
Defendants Shadow Oaks Hospitality, Inc. and Bharat Jivan Patel’s request for judicial notice in support of defendants’ reply is DENIED. (Evid. Code, §§ 452, 453.) “The general rule of motion practice...is that new evidence is not permitted with reply papers.” (Jay v. Mahaffey (2013) 218 Cal.App.4th 1522, 1537.)
Defendants’ motion for judgment on the pleadings is DENIED. (Code Civ. Proc., § 438, subd. (c)(1)(B)(i).) Based on the complaint and matters judicially noticed, defendants have not shown that, if applicable, plaintiff failed to exhaust administrative remedies prior to filing the complaint. (See Cloud, supra, 67 Cal.App.4th at p. 999.) The Court does not reach whether Woodland Municipal Code section 3.12.090 applies under the circumstances.
The notice of motion does not provide notice of this Court’s tentative ruling system as required by Local Rule 11.2(b). Counsel for moving party, or the moving party if unrepresented by counsel, is ordered to notify the opposing party or parties immediately of the tentative ruling system.
If no hearing is requested, and no party appears at the hearing, this tentative ruling is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312
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Discovery motion:
Plaintiff City of Woodland’s motion to compel further responses to requests for production of documents, requests for admissions, and special interrogatories is GRANTED IN PART. (Code Civ. Proc., §§ 2031.320, subd. (a), 2033.290, 2030.300, subd. (a).) First, defendant Shadow Oaks Hospitality does not provide legal authority that this Court can consider its lack of jurisdiction argument in response to a discovery motion. (See Opposition, pp. 3-4.) Second, as to requests for production nos. 1 and 6-12, defendant has failed to produce responsive documents, despite its statements of compliance. (Code Civ.
Proc., § 2031.320, subd. (a); see also Hickey decl., ¶¶ 5, 9-13.) Third, as to requests for production nos. 2-5, plaintiff has shown good cause for the requests, and defendant has failed to justify its objections. (Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98; Coy v. Superior Court of Contra Costa County (1962) 58 Cal.2d 210, 220-221; see also Huckey decl., ¶ 8, Exhibit G.) Fourth, as to request for admissions nos. 5 and 8, defendant’s responses do not comply with Code of Civil Procedure section 2033.220(c). (Code Civ.
Proc., § 2033.290, subd. (a).) Finally, as to special
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interrogatories nos. 3-10, defendant does not justify its objections and/or incomplete answers. (See Kirkland, supra, 95 Cal.App.4th at p. 98.)
Therefore, defendant is DIRECTED to serve further responses and responsive documents by September 8, 2026. The Court declines to order responses without objections. (See Plaintiff’s proposed order [lodged April 20, 2026], p. 2; Holmes decl., ¶¶ 5-7, Exhibit A.)
Plaintiff’s request for sanctions is DENIED. (Code Civ. Proc., §§ 2031.320, subd. (b), 2030.310, subd. (d), 2030.300, subd. (d).) The notice of motion did not “identify every person, party, and attorney against whom the sanction is sought.” (Code Civ. Proc., § 2023.040; see Notice of Motion, p. 2.)
The notice of motion does not provide notice of this Court’s tentative ruling system as required by Local Rule 11.2(b). Counsel for moving party, or the moving party if unrepresented by counsel, is ordered to notify the opposing party or parties immediately of the tentative ruling system.
If no hearing is requested, and no party appears at the hearing, this tentative ruling is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.
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