BRIDGES vs CALIFORNIA DEPARTMENT OF TRANSPORTATION

24CV016129: BRIDGES vs CALIFORNIA DEPARTMENT OF TRANSPORTATION 08/19/2026 Hearing on Motion to Compel Further Responses to Request for Production of Documents (Set Two) 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.

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 on the Court Reporter Services webpage available on the Sacramento Superior Court website at https://saccourt.ca.gov/general-information/court-reporter-servicestranscripts. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000.

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.

24CV016129: BRIDGES vs CALIFORNIA DEPARTMENT OF TRANSPORTATION 08/19/2026 Hearing on Motion to Compel Further Responses to Request for Production of Documents (Set Two) 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.

TENTATIVE RULING:

Plaintiff’s notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Plaintiff is directed to contact opposing counsel and advise them of Local Rule 1.06 and the Court’s tentative ruling procedure and the manner to request a hearing. If Plaintiff is unable to contact opposing counsel prior to 2:00 the day before the hearing, Plaintiff is ordered to appear at the hearing. Pro per Plaintiff Robert Bridge’s (“Plaintiff”) motion to compel Defendant California Department of Transportation’s (“Defendant”) further responses to request for production of documents (set two) is DENIED for failure to comply with the separate statement requirements of CRC Rule 3.1345.

CRC Rule 3.1345, subdivision (c) requires, in relevant part: The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference. The separate statement must include—for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested—the following:

(1) The text of the request, interrogatory, question, or inspection demand; (2) The text of each response, answer, or objection, and any further

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV016129: BRIDGES vs CALIFORNIA DEPARTMENT OF TRANSPORTATION 08/19/2026 Hearing on Motion to Compel Further Responses to Request for Production of Documents (Set Two) in Department 8D

responses or answers; (3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; ...

Plaintiff’s purported separate statement does not contain the text of the requests, or the text of the responses. Further, Plaintiff does not set forth, for each request at issue (Request Nos. 1-37), the factual and legal reasons for why further responses are required. This is particularly true where a motion to compel further responses to document requests “shall set specific facts showing good cause justifying the discovery sought by the demand.” (Code of Civil Procedure section 2031.310(b)(1).) Nowhere in Plaintiff’s motion or supporting documents does Plaintiff provide a request-by-request showing of good cause. Accordingly, Plaintiff’s failure to submit a separate statement requires the motion to be DENIED.

Moreover, even if Plaintiff had provided a sufficient separate statement, the motion would also be denied for failure to meet and confer. Code of Civil Procedure section 2031.310 provides that a motion to compel further response to a request for production of documents “shall be accompanied by a meet and confer declaration under Section 2016.040.” Code of Civil Procedure section 2016.040(a) provides, “A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion.” Plaintiff’s email request to meet and confer, prior to the deadline for and production of responses, is insufficient to meet Plaintiff’s meetand-confer obligations.

The Court, again, notes that it is unclear whether Plaintiff brings the instant motion in his individual capacity or on behalf of entities that were named as Plaintiffs at the time the discovery was served. To the extent that Plaintiff brings the instant motion on behalf of a corporate entity, the motion must be dropped as improper. Plaintiff cannot bring a motion in pro per on behalf of a corporation.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV016129: BRIDGES vs CALIFORNIA DEPARTMENT OF TRANSPORTATION 08/19/2026 Hearing on Motion to Compel Further Responses to Request for Production of Documents (Set Two) in Department 8D

The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.