REYNOLDS vs BERNHARDT, et al.

24CV018092: REYNOLDS vs BERNHARDT, et al. 05/18/2026 Hearing on Motion to Compel Plaintiff's Further Responses to Form Interrogatories, Set One in Department 8D

Tentative Ruling

NOTICE:

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24CV018092: REYNOLDS vs BERNHARDT, et al. 05/18/2026 Hearing on Motion to Compel Plaintiff's Further Responses to Form Interrogatories, Set One in Department 8D

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 HAS MOVED 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:

Defendant A3 Mobility LLC’s (“Defendant”) motion to compel Plaintiff Yvette Reynolds’ (“Plaintiff”) further responses to Defendant’s form interrogatories, set one, is UNOPPOSED and GRANTED.

Defendant propounded its form interrogatories on June 16, 2025. (Declaration of Alexander Cheung (“Cheung Decl.”), ¶ 3, 2025.) Plaintiff’s counsel requested and was granted seven extensions to respond. (Id., ¶¶ 4-9.) On October 24, 2025, Plaintiff served objection only responses signed by her attorney. (Id., ¶ 10; Ex. J.) On November 5, 2025, Defendant’s counsel sent a meet and confer letter to Plaintiff’s counsel requesting amended responses. (Id., ¶ 11.) On November 19, 2025, counsel for both parties engaged in a telephonic meet and confer regarding the responses, but Plaintiff’s counsel was unable to meet and confer because he was unable to reach Plaintiff. (Id., ¶ 12.)

Plaintiff did not file an opposition to this motion. A party’s failure to oppose a motion is construed as a concession on the merits of the motion. (See D.I. Chadbourne, Inc. v. Superior Court (1964) 60 Cal.2d 723, 728, n.4.)

No later than June 1, 2026, Plaintiff shall serve verified responses, without objections, to Defendant’s form interrogatories, set one.

Defendant did not request sanctions, and therefore none are awarded.

This minute order is effective immediately. No formal order or other notice is required. (Code

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV018092: REYNOLDS vs BERNHARDT, et al. 05/18/2026 Hearing on Motion to Compel Plaintiff's Further Responses to Form Interrogatories, Set One in Department 8D

Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.)