Madrone Homeowners Association vs. Stephanie Stapleton

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

Tentative Ruling

NOTICE:

PLEASE TAKE NOTICE that any oral arguments regarding this tentative ruling will be heard at 1:30 p.m. in Department 8C in the Tani G. Cantil-Sakauye Courthouse at 500 G Street, Sacramento, CA, the Hon. Richard C. Miadich presiding.

Any party who wishes to contest the tentative ruling below must:

(1) request a hearing by calling the Law and Motion Oral Argument Request Line at (916) 874-8380, by 4:00 p.m. the Court day before the noticed hearing date, and leave a voicemail message (a) identifying themselves as the party requesting oral argument; (b) indicating the specific matter/motion for which they are requesting oral argument; and (c) confirming that they have notified the opposing party of their intention to appear; and

(2) advise the opposing party of the location and time of hearing pursuant to Local Rule 1.06.

If a hearing is not requested by 4:00 p.m. on the Court day before the noticed hearing date, the tentative ruling will become the final order of the Court.

If a hearing is requested, the Court prefers in-person attendance by the parties. However, parties may appear by Zoom unless the Court specifically orders in-person attendance. Parties choosing to appear by Zoom are reminded, however, that a Zoom appearance is still a formal appearance before the Court. Parties appearing via Zoom should do so from a quiet location, free from undue distractions, and wear attire suitable for an in-person court appearance.

The parties may join the Zoom session for hearing on the tentative ruling by audio and/or video through the following link:

https://saccourt-ca-gov.zoomgov.com/j/16039062174

SIP Address:

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

16039062174@sip.zoomgov.com

(833) 568-8864

ID: 16039062174

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.Pdf

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporter’s Office and an official reporter will be provided.

TENTATIVE RULING

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 28 WILL BE HEARD IN DEPARTMENT 8C OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION***

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

Defendant and Cross-Complainant Stephanie Stapleton’s (“Stapleton”) motion to compel further responses and compliance with request for production, set one, and for sanctions, against Cross-Defendant Community Association Management Services, Inc. (“CAMS”) is ruled upon as follows.

Factual Background

Plaintiff Madrone Homeowners Association (“Madrone”) brought this lawsuit against Stapleton on November 22, 2021, alleging that Stapleton negligently failed to maintain the HVAC system serving her condominium unit, causing water intrusion into the unit below and damage to Madrone’s common area.

Stapleton asserts that the water damage to her unit was not an isolated maintenance issue, but rather the result of a longstanding construction defect affecting numerous units throughout the Madrone development. (Laino Decl., Ex. A.) Stapleton alleges that Madrone previously identified this same construction defect and entered into a settlement agreement with the homebuilder under which Madrone assumed all responsibility for this defect and numerous other Madrone units have experienced substantially similar HVAC condensation-line failures that the HOA repaired for other homeowners while refusing to do so for Stapleton. (Second Amended Cross Complaint (“SACC”), ¶¶ 21-35; Laino Decl. Ex. A.)

Stapleton’s SACC asserts claims against Madrone, CAMS, and Construction 37, for breach of contract, negligence, nuisance, breach of fiduciary duty, and fraud, and alleges that CAMS has served as Madrone’s property management company throughout the relevant time period.

On May 8, 2024, Stapleton served requests for production, set one (the “RFP”), on CAMS, seeking documents concerning HVAC condensation leaks, water intrusion, mold, prior repairs, maintenance records, communications, insurance claims, and similar incidents occurring at Madrone, as well as documents regarding the same HVAC condensation failures at the Lesarra, Vicara, and Syrah developments. (Laino Decl., Ex.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

G, RFP Nos. 1, 4-6, 8, 15-16, and 53-61.)

On July 26, 2024, CAMS served its original, unverified responses to Stapleton’s RFPs. (Laino Decl., ¶ 8.) CAMS agreed to produce documents responsive to RFP Nos. 1, 5-6, while stating that it could not locate documents responsive to RFP Nos. 4, 8 and 15-16. (Id., Ex. H.) CAMS asserted boilerplate objections to RFP Nos. 53-61 and refused to produce any documents.

Counsel for Stapleton and counsel for CAMS met and conferred regarding CAMS’ responses and on November 26, 2024, CAMS served its first amended responses to the RFP. (Laino Decl., ¶ 11, Ex. K.) CAMS’ amended responses confirmed that it would produce documents responsive to RFP Nos. 1, 5-6, 8, and 15-16. (Id.) CAMS removed all objections in its amended responses to RFP Nos. 15-16. (Id.) With respect to RFP Nos. 53-61, however, CAMS served the same objection-only responses. (Id.)

Counsel for the parties further met and conferred. On February 5, 2025, CAMS served its second amended responses to the RFP, but did not amend its responses to RFP nos. 53-61. (Laino Decl., ¶ 14, Ex. N.)

Counsel for the parties further met and conferred over the next several months, and CAMS agreed to produce documents related to the other properties.

On June 4, 2025, CAMS’ counsel informed Stapleton’s counsel that he would need to withdraw. (Laino Decl., ¶ 19.) CAMS granted an open extension on all of Stapleton’s motion to compel deadlines in order to afford new counsel time to review the file, serve amended responses, and produce the missing documents. (Id.)

On August 11, 2025, Stapleton’s counsel sent CAMS’ new counsel a summary of the ongoing discovery disputes, including CAMS’ responses to RFP nos. 53-61, and CAMS failure to produce any communications related to the other condensation leaks at Madrone despite its prior agreements to do so. (Laino Decl., ¶ 20, Ex. R.) On August 22, 2025, CAMS’ new counsel requested a three-week extension as she had not yet received the case file from prior counsel. (Id.) Stapleton’s counsel granted this extension on the condition that CAMS would serve amended responses and produce

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

the missing documents following the extension. (Id.) Despite this agreement, CAMS failed to serve amended responses or produce the missing documents by the new deadline. (Id.)

Counsel for the parties further met and conferred. On January 9, 2026, CAMS served its unverified third amended responses to the RFP. (Laino Decl., ¶ 25, Ex. U.) CAMS still did not produce any new documents related to the other leaks at Madrone. (Id.) CAMS served the same objection-only responses to RFP nos. 53, 55-57, and 59-61. (Id.) CAMS amended its responses to RFP nos. 54 and 58, it only agreed to produce the work order histories for Lesarra and Vicara that it had previously produced. (Id.)

On February 4, 2026, CAMS’ counsel confirmed that she “went to the CAMS office and helped them search through their files for relevant documents to be produced” and that CAMS would be producing these documents. (Laino Decl., ¶ 26, Ex. V.)

Counsel for the parties further met and conferred. On March 5, 2026, CAMS served its unverified fourth amended responses to the RFP. (Laino Decl., ¶ 27, Ex. W.) In its new responses, CAMS continued to confirm that it would produce documents responsive to RFP Nos. 1, 4-6, 8, and 15-16; however, the only new document it produced with respect to the numerous leaks at the Madrone property was a maintenance log identifying the homeowners and unit numbers that experienced these leaks since 2020. (Id.) With respect to RFP nos. 53-61, CAMS continued to rely on its objections and only agreed to produce the redacted work history reports for the Lesarra and Vicara properties (that its counsel had already informally produced). (Id.)

On April 13, 2026, CAMS’ counsel requested an extension of time to respond to supplemental discovery and once again confirmed that she was going to CAMS’ office to locate additional responsive documents. (Laino Decl., ¶ 29, Ex. X.) On April 17, 2026, CAMS’ counsel confirmed that she located “10 banker boxes” of new documents from 2013 to 2019. (Id.)

Counsel for the parties continued to meet and confer. On June 2, 2026, CAMS provided its additional supplemental document production. (Laino Decl., ¶ 31.) The new production, however, consisted solely of financial statements that were already publicly

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

available as CAMS must provide them to its homeowners on an annual basis. (Id.) In contrast to its repeated representations, CAMS’ production did not include any new documents or communications regarding the other leaks at Madrone, or the leaks throughout the Lesarra, Vicara, and Syrah properties. (Id.)

Counsel for the parties further met and conferred. On June 12, 2026, Stapleton’s counsel once again raised CAMS’ failure to produce the missing documents. (Laino Decl., ¶ 32, Ex. Z.) In response, CAMS now took the position that Stapleton had to subpoena these records from the other properties, and refused to produce communications with other homeowners due to privacy concerns. (Id.) When Stapleton pressed CAMS on these new positions, CAMS’ counsel confirmed that it would not produce the missing documents with respect to Vicara and Lesarra, but that if Stapleton prevailed in her related motion to compel against Construction 37, CAMS might reconsider its position. (Id.)

Stapleton’s counsel sent a final meet and conferral letter on June 18, 2026 and filed the instant motion to compel on July 6, 2026.

Trial is set in this action for October 12, 2026.

Motion to Compel

Stapleton now moves for further production of documents in compliance with CAMS’ agreement to produce documents responsive to RFP nos. 1, 4-6, 8, and 15-16, and for further responses to RFP nos. 53-61.

CAMS filed a late opposition to the motion. The Court, in its discretion, has considered the opposition.

CAMS argues that it has produced over 25,000 pages of documents individually and jointly with Madrone, “substantially complying with the requirements of the Code of Civil Procedure Discovery Act.”

CAMS asserts:

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

The topics at issue are overbroad, going beyond the HVAC issues in Stapleton’s unit and well beyond any proportional need for trial preparation. CAMS has identified, located and produced responsive documents in good faith which are responsive to the core issues in this case. Any technical deficiencies in the initial responses, such as verification and the form of statements of compliance, are curable and do not justify the sanctions.

(Opposition, 2:8-12.)

The Court disagrees with CAMS’ assessment. CAMS concedes that their amended responses lack verifications, and provide no reason for this deficiency, despite the long history of meeting and conferring with Stapleton’s counsel and promises to comply with the requests at issue, which were initially served over two years ago.

In addition to its failure to verify the amended responses, CAMS’ objections are not supported by a response to Stapleton’s separate statement, and are overruled.

Stapleton’s motion to compel is GRANTED.

The Court further finds that CAMS’ opposition is without substantial justification and that CAMS has abused the discovery process. Stapleton’s request for sanctions is GRANTED.

Disposition

CAMS shall provide verified code-compliant responses, without objection, to RFP nos. 53-61, and shall produce all documents responsive to RFP nos. 1, 4-6, 8, and 15-16, no later than August 26, 2026.

Stapleton’s request for sanction is GRANTED in the reduced amount of $7,280.00,

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00311585-CU-BC-GDS: Madrone Homeowners Association vs. Stephanie Stapleton 08/17/2026 Hearing on Motion to Compel Community Association Management Services, Inc. Further Responses and Compliance with Request for Production, Set One in Department 8C

which includes $7,220.00 for the 15.2 hours of attorney time at the reasonable hourly rate of $475 incurred in the preparation of this motion, plus $60 for the filing fee. (Code Civ. Proc. §2023.030(a).) Sanctions shall be paid on or before August 26, 2026. If the sanctions are not paid by that date, Stapleton may prepare for the Court's signature a formal order granting the sanctions, which may be enforced as a separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC Rule 3.1312.)