O’LOUGHLIN vs AHRARI ENTERPRISES LLC, et al.

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 08/19/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

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 Department 8D Oral Argument Request Line at (916) 874-7719 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.

Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings.

The Department 8D Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16113421868 and the Zoom Meeting ID is 161 1342 1868. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.

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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.

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 08/19/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

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.

*** EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET IN SACRAMENTO, CA 95814. ALL HEARINGS NOTICED FOR DEPARTMENT 25 WILL BE HEARD IN DEPARTMENT 8D OF THE NEW COURTHOUSE. ***

TENTATIVE RULING:

The notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06(D). Moving counsel is directed to contact opposing counsel forthwith to advise of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing. If moving counsel is unable to contact opposing counsel prior to the hearing, moving counsel shall be available at the hearing, in person or remotely, in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

Plaintiff Matthew O’Loughlin’s (“Plaintiff”) Motion to Compel Further Reponses to Form Interrogatories, Set One, is GRANTED as stated below.

This is a dispute over Plaintiff’s purchase of a truck from Defendant Ahrari Enterprises LLC (“Defendant”). Plaintiff served discovery demands, including Form Interrogatories, Set One, by mail on September 20, 2025, with responses due by October 27, 2025. (Quirk Decl. ¶¶ 2, 3.) Plaintiff received a response on November 7. (Id. ¶ 3.) Defendant provided additional responses on January 10, 2026. (Id. ¶ 6.) Plaintiff believed the responses were inadequate and filed this motion to compel on January 23, 2026.

This matter was initially set to be heard on June 17, 2026. The Court continued the hearing to August 5 and ordered the parties to meet and confer in an attempt to resolve the discovery requests by no later than July 29, 2026. The Court also ordered the parties to file a joint statement no later than August 5, 2026, stating which discovery requests have been resolved and which, if any, requests remain outstanding.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 08/19/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

Plaintiff filed the Joint Statement on August 5. In the Joint Statement, Plaintiff’s counsel writes that the parties met and conferred by telephone on July 28 but were unable to resolve Defendant’s responses to Form Interrogatory (“FROG”) No. 17.1. All other discovery requests were resolved.[1]

Written interrogatories must be answered in writing under oath by answering with the information sought, producing responsive writings, or objecting to a particular interrogatory. (Code Civ. Proc., § 2030.210.) If the party propounding discovery believes responses are evasive or incomplete, the party can move for an order compelling further responses. (Id., ¶ 2030.300.)

FROG 17.1 demands:

Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing.

(Sep. Statement, at p. 2.) Defendant did not give unqualified admissions to Plaintiff’s Request for Admissions (“RFAs”) numbers 11 through 27. (See Quirk Decl., Exh. G.) Defendant’s November 7, 2025 response to FROG 17.1 consisted of only the sentence “all except those as noted in those responses.” (Id., Exh. B.) This apparently responded to the initial question in FROG 17.1 but did not respond to the detailed list of information in subsections (a) through (d). Defendant’s additional response of January 10, 2026 first lists five non-specific objections to the discovery and then adds “Answer is Yes, to all. Subject to General objections listed above.” (Id., Exh. E.) This again appears to respond to the initial question in FROG 17.1 and could be read as admitting all of the RFAs, which would conflict with the direct responses to the RFA discovery.

Following the ordered meet-and-confer period, Plaintiff states that responses to FROG 17.1 for RFAs Nos. 11–18 and 22–27 are still outstanding.[2] (Joint Statement, at p. 2.).

As an initial matter, the Court must review the responses at issue in the motion, which are those set forth in the initial separate statement; belated service of responses does not moot a motion to

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 08/19/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

compel discovery. (Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 405–406; see Cal. Rules of Court, rule 3.1348(a).) The moving party is entitled to a ruling once the motion is made. (See Code Civ. Proc., § 1005.5.)

In this case, the initial and supplemental response to Form Interrogatory 17.1 is deficient. The initial and supplemental response do not respond, in any way, to the questions in 17.1(a)–(d) for those responses to RFAs that are not qualified admissions. Defendant’s opposition fails to address or support any of the objections in the initial or supplemental response. As such, Plaintiff’s motion to compel, based on the initial and supplemental response at issue, is GRANTED.

The Court notes that the email responses alluded to in the Joint Statement do not resolve the pending issues (and are not part of the responses properly before the Court). As the email acknowledges, interrogatories must be answered under oath. Further, as with the initial and supplemental response at issue, the email responses do not provide any of the detailed information sought by FROG 17.1 regarding identity and location of documents or witnesses.

Accordingly, Plaintiff’s motion for further responses to Form Interrogatories, Set One, is GRANTED.

Plaintiff also requests monetary sanctions in the amount of the $3,125 pursuant to Code of Civil Procedure, section 2030.300. At the time this motion was made, Defendant’s discovery responses not only failed to answer FROG 17.1 but were confused and contradictory. Defendant appears to argue in opposition that because he had already provided relevant documents, he was not obligated to give a detailed response to FROG 17.1. (Opp. at p. 2:9–21.) Defendant does not cite any authority for this proposition.

The Court finds that Defendant opposed this motion without substantial justification or a showing that any circumstances make the imposition of sanctions unjust. Monetary sanctions are therefore mandatory. (Code Civ. Proc., § 2030.300, subd. (d).)

Monetary sanctions in discovery are for the purpose of making an injured party whole and are limited to 'reasonable expenses, including attorney's fees, incurred by anyone as a result of' misuse of discovery process. (Cornerstone Realty Advisors, LLC v. Summit Healthcare REIT, Inc. (2020) 56 Cal.App.5th 771, 790.) Plaintiff’s counsel declares that his hourly rate is $625 and that he spent “more than three hours drafting this motion” and “anticipate[s] spending at least another hour if this motion is opposed,” plus a $60 filing fee. (Quirk Decl., ¶ 11.)

The Court finds Plaintiff’s counsel’s rate and time spent somewhat excessive given the nature of

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 08/19/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

this matter and the rates in the community. Further, Plaintiff initially filed three separate motions to compel further responses to different discovery requests. Much of the drafting between the three motions appears cumulative. The Court GRANTS Plaintiff’s motion for monetary sanctions in the reduced amount of $1,560 (three hours at $500 per hour, plus the filing fee).

Disposition

Plaintiff’s motion for further responses to Form Interrogatories, Set One, is GRANTED. Defendant shall serve complete, code-compliant, verified responses, without objections, by no later than September 18, 2026.

The Court orders that Defendant and Defendant’s attorney of record, as noticed in the motion, are jointly liable for and shall pay to Plaintiff a monetary sanction in the amount of $1,560 by no later than September 18, 2026.

If the sanction is not paid by that date Plaintiff may prepare for the Court’s signature a formal order granting sanctions, which may itself be enforced in the same manner and with the same force and effect as a money judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615 [“[M]onetary sanction orders are enforceable through the execution of judgment laws.”].)

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

[1] Plaintiff filed an “Addendum to Joint Statement” on August 17, 2026, two days before the

hearing. The Court does not consider Plaintiff’s Addendum for this tentative ruling because Defendant will not have had an opportunity to respond, it is beyond the date that the Court ordered a Joint Statement, and it addresses further responses that are beyond the scope of the pending motion. [2] Defendant admitted RFAs Nos. 19, 20, and 21.