CARVALHO vs EDGE BUSINESS SERVICES CORP., et al.

25CV141395: CARVALHO vs EDGE BUSINESS SERVICES CORP., et al. 08/06/2026 Hearing on Motion to Compel Further Discovery Responses filed by RAIMUNDO CARVALHO (Plaintiff) CRS# 486570957569 in Department 520

Tentative Ruling - 08/05/2026 Jamilah A. Jefferson

The Motion to Compel Further Discovery Responses filed by RAIMUNDO CARVALHO on 04/01/2026 is Granted in Part.

The Motion of Plaintiff Raimundo Carvalho (“Plaintiff”) to Compel Further as to Defendant EG Ground Management (“Defendant”) and for Monetary Sanctions is GRANTED IN PART.

The Court notes that this is one of four Motions to Compel Further as to Defendant here. The subject discovery requests consist of FROGS – General (Set One), Nos. 1.1, 3.1, 3.2, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, and 17.1. (MPA, p. 2:16-17; Separate Statement.) It is unclear if No. 3.3 is at issue as it is referenced in the Memorandum of Points and Authorities, but not the Separate Statement; thus, the Court disregards it. (MPA, pp. 2:16, 3:11-12.) As the responses were served on February 12, 2026 prior to the Court’s July 9, 2026 ruling on Defendants’ Motion to Quash, Defendant objected claiming that the discovery requests were premature and overbroad temporally such that they were not reasonably calculated to lead to the discovery of admissible evidence.

The Court disagrees and does not find that the cases Defendant cites in support of its argument reflect that Defendant was substantially justified in opposing this Motion. Indeed, as Plaintiff points out, “[a] plaintiff attempting to assert jurisdiction over a nonresident defendant is entitled to an opportunity to conduct discovery of the jurisdictional facts necessary to sustain its burden of proof. [Citation.]” (In re Automobile Antitrust Cases I & II (2005) 135 Cal.App.4th 100, 127.)

Thus, Plaintiff’s Motion is GRANTED. Defendant is ordered to serve Plaintiff with code-compliant responses without objections to Plaintiff’s Form Interrogatories (Set One) Nos. 1.1, 3.1, 3.2, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, and 17.1 without objection within thirty (30) days of the date of this Order. As there is a discrepancy between Plaintiff’s Notice of Motion and Reply as to whether Plaintiff seeks monetary sanctions against just Defendant or Defendant and its counsel, monetary sanctions are denied. (Notice, p. 2:2; Reply, p. 5:16-18.)

NOTICE TO DEFENDANT: Defendant is advised that failure to comply with this Order may result in the imposition of future sanctions, including evidentiary, monetary, or terminating sanctions.

NOTICE: This tentative ruling will automatically become the court’s final order on August 6, 25CV141395: CARVALHO vs EDGE BUSINESS SERVICES CORP., et al. 08/06/2026 Hearing on Motion to Compel Further Discovery Responses filed by RAIMUNDO CARVALHO (Plaintiff) CRS# 486570957569 in Department 520 2026 unless, by no later than 4:00 P.M. on August 5, 2026, a party to the action notifies BOTH: 1) the court by emailing Dept520@alameda.courts.ca.gov; AND 2) all opposing counsel or selfrepresented parties (by telephone or email) that the party is contesting this tentative ruling.