INDONG ADVANCED MATERIALS, INC vs GREEN ENERGY GLOBAL, INC, AN ARIZONA CORPORATION, et al.

23CV005172: INDONG ADVANCED MATERIALS, INC vs GREEN ENERGY GLOBAL, INC, AN ARIZONA CORPORATION, et al. 04/06/2026 Hearing on Motion to Compel Further Responses from Jaswinder Singh to Request for Production of Documents in Department 25

Tentative Ruling

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Law and Motion Oral Argument Request Line at (916) 874-2615 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail 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 it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

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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.

23CV005172: INDONG ADVANCED MATERIALS, INC vs GREEN ENERGY GLOBAL, INC, AN ARIZONA CORPORATION, et al. 04/06/2026 Hearing on Motion to Compel Further Responses from Jaswinder Singh to Request for Production of Documents in Department 25

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 forward the form to the Court Reporter’s Office and an official reporter will be provided.

****NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT WILL MOVE TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G. ST. SACRAMENTO, CA. MOTIONS NOTICED FOR DEPARTMENT 25 WILL BE HEARD IN DEPARTMENT 8D OF THE NEW COURTHOUSE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION****

TENTATIVE RULING:

The motion of Defendant Rollie Peterson (“Defendant Peterson”) to compel the initial responses of Plaintiff Indong Advanced Materials, Inc., a Republic of Korea Corporation (“Plaintiff”) to his propounded request for production of documents, set one, and request for monetary sanctions, is ruled upon as follows.

As a preliminary matter, the Court notes, as Plaintiff points out in opposition, Defendant Peterson’s motion contains several typographical errors (e.g., captioning this motion as a motion to compel “FURTHER RESPONSES FROM JASWINDER SINGH,” albeit apparently being a motion to compel initial responses from Plaintiff; the Notice of Motion indicating that this motion is “based upon” the Declaration of “Gurprit Singh,” and a “Separate Statement,” without including the same; etc.)[1] Nevertheless, as Plaintiff was able to substantively oppose this motion, the Court will address the merits herein. Defendant Peterson is cautioned to take better care in preparing his papers in future filings.

Plaintiff commenced this action by filing its Complaint on July 21, 2023, alleging five causes of action: (1) breach of contract; (2) fraud; (3) unjust enrichment; (4) professional negligence; and (5) declaratory relief. Plaintiff alleges that Defendant Green Energy Global, Inc. (“GEGI”) purported to assign Plaintiff mining rights to 900,000 metric tons of lithium in Bolivia. Plaintiff alleges that GEGI never had the mining rights, fraudulently induced the subject contracts and stole $10 million from Plaintiff.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

23CV005172: INDONG ADVANCED MATERIALS, INC vs GREEN ENERGY GLOBAL, INC, AN ARIZONA CORPORATION, et al. 04/06/2026 Hearing on Motion to Compel Further Responses from Jaswinder Singh to Request for Production of Documents in Department 25

Plaintiff alleges causes of action against GEGI and numerous other defendants for breach of contract, fraud, unjust enrichment, professional negligence, and declaratory relief. In addition to GEGI, Plaintiff named GEC Exploration, Inc. (“GEC”), and Donald Demery as Trustee of Quantum Trust (“Quantum”), Muhammed Khan, Defendant Victoria Choi’s and Jeffrey Thoreson, Lucia Kim, Defendant Peterson, Tae Joo Yi, Kwon Do Kang, and Bae, Kim & Lee, LLC (“BKL”) as defendants.

Pertinent to this motion, Defendant Peterson’s counsel represents that on July 22, 2025, he propounded and served his request for production of documents, set one, to Plaintiff. (See Barrett Decl., ¶ 3, Exh. 1.) While Defendant Peterson’s counsel agreed to provide an extension to September 30, 2025, for Plaintiff to provide responses to the subject discovery, at the time of filing this motion, no responses were provided. (See Barett Decl., ¶ 3, Exh. 2.)

Generally, responses are due within 30 days from the date the requests for production of documents were served. (Code Civ. Proc., § 2031.260.) This time is extended if the discovery is served by mail, fax, or electronically. (Code Civ. Proc., §§ 1013, 2016.050.) The parties may stipulate for an extension of time for which to respond. (Code Civ. Proc., § 2031.270.)

In opposition, Plaintiff highlights the typographical errors in Defendant Peterson’s motion, argues that the motion is premature in light of the circumstances regarding the incarceration of a certain corporate representative, that Plaintiff cannot provide complete and verified responses without this corporate representative, and that Defendant Peterson failed to adequately meet and confer prior to bringing this motion.

The Court first rejects Plaintiff’s arguments that Defendant Peterson’s failure to meet and confer requires the Court deny or continue the hearing of this motion. There is no meet and confer obligation for parties seeking to compel initial responses to requests for production. (See Code Civ. Proc., § 2031.300.) As to Plaintiff’s additional arguments raised in opposition, the Court does not find these to be grounds to deny this instant motion. Accordingly, as Plaintiff has presented no persuasive arguments in opposing the instant motion, Defendant’s motion to compel is GRANTED.

Accordingly, Defendant Peterson’s motion to compel the initial responses of Plaintiff to the subject discovery is GRANTED. Plaintiff shall serve verified responses, without objections, to Defendant Peterson’s request for production of documents, set one, no later than April 30, 2026, unless the parties otherwise agree to a later date, confirmed in

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

23CV005172: INDONG ADVANCED MATERIALS, INC vs GREEN ENERGY GLOBAL, INC, AN ARIZONA CORPORATION, et al. 04/06/2026 Hearing on Motion to Compel Further Responses from Jaswinder Singh to Request for Production of Documents in Department 25

writing.

To the extent Defendant Peterson seeks to compel production of documents, this request is premature. A motion to compel production is only proper where a party has agreed to produce documents but has failed to do so in compliance with its statement. (Code Civ. Proc., § 2031.320(a).) No such agreement has been made as no responses have been served.

Defendant Peterson’s request for sanctions is DENIED as the Court finds the imposition of sanctions to be unjust. (Code Civ. Proc., § 2031.300(c).)

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules Court, rule 3.1312.)

[1] The Court notes Defendant Peterson has filed a Notice of Errata, although it appears

to be filed with its reply on March 26, 2026, and seemingly in response to Plaintiff’s contentions raised in opposition regarding the same.