SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al.

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518

Tentative Ruling - 08/20/2026 Mark Fickes

The Motion to Compel Further Discovery Responses filed by Darian Scott on 06/26/2026 is Granted in Part.

PRELIMINARY OBSERVATIONS

Before the Court are a total of six discovery motions, argued the same day, in a single-vehicle personal injury case. The Civil Discovery Act was built on the premise that counsel can resolve most disputes without judicial help, and it makes the court the forum of last resort, not the first stop. The parties have inverted that design.

BACKGROUND

This personal injury action arises from an August 20, 2022 roadside incident in which Plaintiffs Marlin Scott and Darian Scott were injured while awaiting a tow of their Hertz rental vehicle after a hit-and-run driver struck the tow truck. The timing and handling of two roadsideassistance calls that Defendant American Automobile Association of Northern California, Nevada & Utah ("AAA NCNU")identifies as Call #672 and Call #679 are central to liability. Trial is set for December 21, 2026, and the mandatory settlement conference for October 7, 2026. (Harris Decl. (Aug. 12, 2026) ¶ 2.) On Plaintiffs' ex parte application, granted July 21, 2026, the Court advanced and consolidated the hearing on these motions to August 25, 2026. (Id., Ex. B.)

The three motions divide into two categories. The first, Darian Scott's motion, seeks further responses to Requests for Production, Set One (Nos. 1 through 21), which AAA NCNU answered but, Plaintiff contends, deficiently. The second and third, Marlin Scott's motions, seek initial responses to Requests for Production, Set Two (Nos. 1 through 15), and Special Interrogatories, Set One (Nos. 1 through 11), to which AAA NCNU served no timely response at all. A common thread runs through all three: AAA NCNU's former lead counsel, Allison Friedman, represented that responses would be served, did not serve them, and departed her firm in June 2026, after which successor counsel appeared. (Harris Decl. (Aug. 12, 2026) ¶ 3.)

As to Set One, Darian Scott served the requests on September 17, 2025. AAA NCNU served original responses and a 1,055-page production (Bates AAA_NCNU_000001 through 001055) on December 18, 2025, and amended responses on March 12, 2026. The verification accompanying the amended responses was executed on March 4, 2026, eight days before they were served. Between February 2 and June 11, 2026, Plaintiff served four meet-and-confer letters and obtained five written extensions of the deadline to move to compel, the last through 24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 June 26, 2026, when the motion was filed.

AAA NCNU served further amended responses on July 10, 2026, after the motion was filed. (Finck Decl. (June 26, 2026) ¶¶ 5-18; Mem. P. & A. at pp. 2-4.)

As to Set Two and the Special Interrogatories, Marlin Scott served both on April 3, 2026. Plaintiff granted a series of extensions, the last to May 20, 2026, and AAA NCNU served nothing by that deadline, despite representing on June 8 and 10, 2026 that responses were "forthcoming." Plaintiff filed the Requests for Production, Set Two motion on July 2, 2026, and the Special Interrogatories motion on July 15, 2026. AAA NCNU served its response to Set Two on July 10, 2026 (98 days after service, 51 days after the deadline, and 8 days after the Set Two motion was filed), and its responses to the Special Interrogatories on August 10, 2026 (129 days after service, 82 days after the deadline, and 26 days after that motion was filed). (Finck Decl. re Requests for Production, Set Two (July 2, 2026); Finck Decl. re Special Interrogatories (July 15, 2026); Harris Decl. (Aug. 12, 2026) ¶¶ 3-4, Ex.

A.)

LEGAL STANDARD

On receipt of a response to a demand for production, the demanding party may move to compel a further response if a statement of compliance is incomplete, a representation of inability to comply is inadequate, incomplete, or evasive, or an objection is without merit or too general. (Code Civ. Proc., § 2031.310, subd. (a).) The motion must show good cause and be accompanied by a separate statement, and must be noticed within 45 days of the verified response or a later date agreed in writing. (§ 2031.310, subds. (b), (c); Cal. Rules of Court, rule 3.1345(a).) Once the moving party shows good cause, the burden shifts to the responding party to justify each objection. (Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98; Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221.)

A party that fails to serve a timely response to an inspection demand or to interrogatories waives all objections, including privilege and work product; a party in default of interrogatories also waives the option to produce writings under section 2030.230. (§§ 2031.300, subd. (a), 2030.290, subd. (a); Leach v. Superior Court (1980) 111 Cal.App.3d 902, 905-906.) The propounding party may then move to compel a response without a showing of good cause, a separate statement, or regard to the 45-day limit. (§§ 2031.300, subd. (b), 2030.290, subd. (b).)

The court may relieve a party of the waiver only on motion, and only on a determination that the party subsequently served a response in substantial compliance with the governing statutes and that the failure to respond timely resulted from mistake, inadvertence, or excusable neglect. (§§ 2031.300, subd. (a)(1)-(2), 2030.290, subd. (a)(1)-(2).)

That AAA NCNU served responses after a motion was filed does not defeat the motion or divest the Court of authority to hear and rule on it. The Court evaluates whether the operative responses comply with the Code, and may compel responses without objection, deny a motion as

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 unnecessary only where the late response contains no objections and sets forth legally valid answers, treat the motion as one for further responses, or take it off calendar. (Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 408- 409.)

A response must be verified, and an unverified response is tantamount to no response at all. (§§ 2030.250, 2031.250, 2015.5; Appleton v. Superior Court (1988) 206 Cal.App.3d 632, 636.) The Court shall impose a monetary sanction against a party that unsuccessfully makes or opposes any of these motions, unless the party acted with substantial justification or other circumstances make the sanction unjust. (§§ 2031.310, subd. (h), 2031.300, subd. (c), 2030.290, subd. (c).) Argument of counsel is not evidence. (In re Zeth S. (2003) 31 Cal.4th 396, 413, fn. 11; Cal.

Rules of Court, rule 3.1306(a).)

DISCUSSION

I. Darian Scott's Motion to Compel Further Responses to Requests for Production, Set One

A. The Motion Is Timely and the Meet-and-Confer Requirement Is Satisfied

The motion is timely; the parties agreed in writing to extend the deadline to move to compel through June 26, 2026, and the motion was filed that day. (§ 2031.310, subd. (c).) The meet-andconfer requirement of sections 2031.310, subdivision (b)(2), and 2016.040 is satisfied, and amply so: over more than four months Plaintiff sent four detailed letters, conferred by telephone, and granted five extensions to allow AAA NCNU to cure. (Finck Decl. ¶¶ 7-18.) The inadequacy in that process was not Plaintiff's. AAA NCNU repeatedly promised supplemental production that did not arrive, served its further amended responses only after the motion was filed, and on August 13 and 17, 2026 first agreed and then refused to correct the response language at issue. (Finck Reply Decl. re Set One (Aug. 18, 2026) ¶¶ 3-6, Exs. A, B.)

B. Good Cause Is Established

The call, dispatch, and timing records for Call #672 and Call #679 (Nos. 19-21) bear on when AAA NCNU was contacted and why the response took as long as it did. The operator's employment, training, performance, and compliance records (Nos. 1-6, 10-11) and AAA NCNU's operating and safety policies (Nos. 7-9) bear on the negligence and negligent hiring, training, supervision, and retention claims. The vehicle damage and repair records (Nos. 12-13), investigation materials (No. 14), and contention documents (Nos. 15-18) bear on causation and on AAA NCNU's defenses. Good cause is established as to each. (§ 2017.010.)

C. AAA NCNU's Objections Are Overruled

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 The burden to justify each objection rests on AAA NCNU, and it has not carried it. The attorneyclient privilege and work-product objections asserted across Nos. 1, 2, and 4 through 18 are facially inapplicable to ordinary personnel, training, policy, vehicle, and contention records.

The "private personnel information," "confidential business practices," and "trade secret" objections, including the objection to No. 3 (the operator's tow-truck-driver certificate, a regulatory credential), rest on no factual showing, and any genuine privacy interest is addressed by the protective order AAA NCNU itself invokes. The "vague, ambiguous, and overly broad" objections to Nos. 2, 7, 15 through 18, and 21 are not sustainable, as each request is reasonably intelligible. AAA NCNU defends only its particularity objection, and only as to Nos. 14 through 18, on the ground those requests share the same "RELATE TO" phrasing; the record does not support that characterization, because only No. 14 uses the phrase and Nos. 15 through 18 are each tied to a single, specified contention of AAA NCNU's own.

All objections to Nos. 1 through 21 are overruled.

D. Privilege Log, Section 2031.230 Statements, and the Verification

AAA NCNU represents that no privilege log is required because it withholds nothing, yet its verified responses to Nos. 14, 17, 18, 19, 20, and 21 promise only the documents "to which no objection was made," language that reserves a right to withhold, and an objection is construed as an implicit refusal to produce. (Standon Co. v. Superior Court (1990) 225 Cal.App.3d 898, 901.) AAA NCNU must either serve a privilege log conforming to section 2031.240, subdivision (c)(1) (Lopez v. Watchtower Bible & Tract Society of New York, Inc. (2016) 246 Cal.App.4th 566, 596-597), or confirm in a verified response that nothing is withheld and remove the qualifier.

Its representations of inability to comply as to Nos. 2, 12, 13, and 19 do not affirm a diligent search, specify why the documents are unavailable, or identify any person believed to have them, as section 2031.230 requires. And the verification served with the amended responses, executed March 4, 2026 before the responses were served on March 12, 2026, is defective. (§§ 2031.250, 2015.5; Appleton, supra, 206 Cal.App.3d at p. 636.)

E. The Call #672 Records; No Evidence Establishes the Native Record's Existence or Loss

AAA NCNU's amended response to No. 20 promised to produce all documents relating to Call #672, but no native record followed; Plaintiff received only three screenshots (Bates AAA_NCNU_000304, 000308, and 000309) bearing a 2025 "Report Created" date, in contrast to the contemporaneous native "Print Call Details" report produced for Call #679. AAA NCNU's verified response states that all responsive Call #672 documents have been produced, while its opposition brief states that AAA NCNU migrated from its "D3" system to "Tableau," no longer has a native record, and that Plaintiff should subpoena it from AAA NCNU's former vendors. These positions are irreconcilable, and the explanation on which AAA NCNU relies appears only

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 in an unverified brief, supported by no verified response and no declaration on personal knowledge; the sole declaration is that of an associate assigned in June 2026, which does not address the configuration, migration, or retention of AAA NCNU's dispatch systems.

On this record there is no evidence establishing either that a native Call #672 record still exists or that it has been lost or destroyed. The Court therefore does not order production of a document the record does not establish exists; it orders AAA NCNU to produce the complete native records for Call #672 and Call #679 if they exist in any form within its possession, custody, or control, and, as to any such record it cannot produce, to serve a verified statement complying with section 2031.230.

A party does not discharge its obligation by directing its opponent to subpoena the party's own records from a former vendor. (Padron v. Watchtower Bible & Tract Society of New York, Inc. (2017) 16 Cal.App.5th 1246, 1266.)

F. Sanctions on the Set One Motion

AAA NCNU has not shown substantial justification; the deficiencies reflect drafting choices made in the July 10, 2026 further amended responses served after successor counsel appeared, and the substantive explanations appear only in an unverified brief. The Court nonetheless gives some credence to the disruption caused by the mid-litigation departure of AAA NCNU's former lead counsel in June 2026, and finds it a mitigating circumstance that renders imposition of the full amount partially unjust under section 2031.310, subdivision (h).

Plaintiff's papers request $9,836 in the notice and conclusion, though the memorandum's body once states $9,936; the Court treats $9,836 as the sum requested. Applying an approximately 40 percent reduction ($9,836 less $3,934.40), the Court awards $5,901.60 against AAA NCNU and its counsel, jointly and severally, subject to substantiation of the supporting time and rate at the hearing.

II. Marlin Scott's Motion to Compel Responses to Requests for Production, Set Two

A. AAA NCNU Waived Its Objections and Has Not Sought Relief

Because AAA NCNU served no response to Set Two by the final extended deadline of May 20, 2026, it waived every objection, including privilege and work product, by operation of law before the July 10, 2026 response was drafted. (§ 2031.300, subd. (a); Leach, supra, 111 Cal.App.3d at pp. 905-906.) This is a section 2031.300 motion; no good cause, separate statement, or 45-day limit applies, and AAA NCNU's reliance on the section 2031.310 furtherresponse standard is misplaced. Relief from the waiver is available only on a noticed motion, on an evidentiary showing of both substantial compliance and mistake, inadvertence, or excusable neglect.

AAA NCNU stated in its opposition, on an August 13, 2026 call, and in an August 17, 2026 email that it would move for relief, but as of the reply it had filed nothing. A stated intention to seek relief is not relief, and the Court cannot grant on an opposition brief what the statute permits only on motion.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518

B. The Late Response Does Not Moot the Motion and Is Not in Substantial Compliance

A late response does not moot the motion, and denial as unnecessary is available only where the late response contains no objections and sets forth legally valid answers. (Sinaiko, supra, 148 Cal.App.4th at pp. 408-409.) The July 10 response does not qualify. It promises only the documents "to which no objection was made" and compliance "in part" on Nos. 1, 3, 5, 6, 8, 9, 10, and 11, without stating whether anything is withheld; it asserts a full block of objections, already waived, on Nos. 11 through 15; it is unaccompanied by any privilege log; and its statements of inability to comply omit what section 2031.230 requires, stating as to Nos. 2, 4, and 5 that contact information for vendor "Bringg" is "to be determined."

On the event recorder, AAA NCNU's verified response states the tow truck had no event data recorder, while its opposition concedes the Samsara dash camera "records EDR-like data"; the only item produced was the publicly available Samsara CM32 datasheet, which contains none of the incidentspecific data that Request Nos. 2, 3, and 4 seek. And its answer to Request No. 7 that responsive documents "have never existed" is difficult to reconcile with its own account that Call #672 was cancelled because no driver could be found.

C. Sanctions on the Set Two Motion

Sanctions are mandatory against a party that unsuccessfully opposes a motion to compel a response, absent substantial justification. (§ 2031.300, subd. (c).) The factual premises of AAA NCNU's opposition, its system migration, the asserted absence of a native record, and its vendors' contact information, appear only in an unverified brief and in no declaration on personal knowledge, and cannot support a substantial-justification finding. As with the Set One motion, however, the Court gives some credence to the June 2026 departure of former lead counsel as a mitigating circumstance and reduces the award accordingly. Plaintiff requests $2,186 (five hours at $425, or $2,125, plus a $61 filing fee). Applying an approximately 40 percent reduction ($2,186 less $874.40), the Court awards $1,311.60 against AAA NCNU and its counsel, jointly and severally.

III. Marlin Scott's Motion to Compel Responses to Special Interrogatories, Set One

A. AAA NCNU Waived Its Objections and the Option to Produce Writings

Because AAA NCNU served no response by the May 20, 2026 deadline, it waived every objection and, as to interrogatories, the option to produce writings under section 2030.230, by operation of law. (§ 2030.290, subd. (a); Leach, supra, 111 Cal.App.3d at pp. 905-906.) AAA

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 NCNU has filed no motion for relief from that waiver. Its August 10, 2026 responses, served 129 days after service and 82 days after the deadline, do not moot the motion. (Sinaiko, supra, 148 Cal.App.4th at pp. 407-409.)

B. The August 10 Responses Are Not in Substantial Compliance

Several answers are not code-compliant on their face. AAA NCNU answered Interrogatory Nos. 3(c) and 4(c) (timestamps) by referring to "documents previously provided," and Nos. 5 through 7 by referring to the Samsara CM32 datasheet; answering an interrogatory by a general crossreference to documents is improper, and the option to produce writings was in any event waived. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783-784; § 2030.230.) AAA NCNU answered Nos. 5, 6, and 7, and subparts (b), (d), and (e) of No. 3, with "N/A" or "Not Applicable," which is not a permitted response. (Deyo, supra, 84 Cal.App.3d at p. 783.)

It answered as to an "event data recorder," a narrower term than the defined term "EVENT RECORDER," which expressly includes a dash camera, and then acknowledged the Samsara dash camera; a party may not silently substitute a narrower definition of its own. The contention interrogatories, Nos. 8 through 11, drew objections that a contention interrogatory is expressly authorized and not objectionable as calling for a legal conclusion or as premature. (§ 2030.010, subd. (b); Burke v. Superior Court (1969) 71 Cal.2d 276, 281-282; see Rifkind v.

Superior Court (1994) 22 Cal.App.4th 1255, 1262 [contention questions belong in interrogatories, even though a party deponent may not be compelled to state the facts supporting a contention].) AAA NCNU's answers to those interrogatories state conclusions, such as that it "followed all its protocols" and "was not negligent," without stating supporting facts, and its answer to No. 11 addresses "staff" generally while saying nothing about the operator, Kevin Musyoka Mului. Nos. 3 and 4 also supply coordinates for only two of the four identified timestamps, omitting the roughly thirtyminute interval between the responding truck going en route and arriving.

C. AAA NCNU's Timing Argument, and No Evidence Supports the Unsworn Explanations

AAA NCNU's principal affirmative argument, that Plaintiff waited too long to serve the interrogatories, has no bearing on the thirty-day duty to respond and identifies no authority excusing a default on that basis; it is also inaccurate, as the interrogatories were served under twenty months after the complaint and followed the December 2025 production that prompted them. As with the other motions, the factual explanations AAA NCNU offers appear only in an unverified brief and in no declaration on personal knowledge. The Court's rulings rest on the deficiencies apparent on the face of the responses; it makes no finding that AAA NCNU altered or destroyed any record.

D. Sanctions on the Special Interrogatories Motion

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518

Sanctions are mandatory against a party that unsuccessfully opposes the motion, absent substantial justification. (§ 2030.290, subd. (c).) AAA NCNU has shown none, for the reasons stated. Giving the same credence to the June 2026 departure of former lead counsel as a mitigating circumstance, the Court applies an approximately 40 percent reduction to the $2,186 requested ($2,186 less $874.40) and awards $1,311.60 against AAA NCNU and its counsel, jointly and severally.

MEET AND CONFER AND DISCOVERY REFEREE

Darian Scott's further-response motion required a meet-and-confer, and Plaintiff satisfied it, as Part I.A explains. Marlin Scott's two motions, addressed to a complete failure to respond, required none. (Sinaiko, supra, 148 Cal.App.4th at p. 404; Leach, supra, 111 Cal.App.3d at pp. 905-906.) The volume of discovery motion practice in this case, and the parties' evident inability to resolve routine disputes without judicial intervention, nonetheless lead the Court to direct the parties to be prepared to address at the hearing whether the appointment of a discovery referee under Code of Civil Procedure section 639, subdivision (a)(5), is appropriate. Such an appointment requires exceptional circumstances specific to the case. (Code Civ. Proc., § 639, subd. (d)(2).)

CONCLUSION

Motion to Compel Further Responses to Requests for Production, Set One. GRANTED IN PART. Within twenty (20) days of this order, AAA NCNU shall serve further verified responses to Nos. 1 through 21, without objection, in substantial compliance with Code of Civil Procedure sections 2031.210 through 2031.280, accompanied by a verification dated on or after the date of service. Within the same period, AAA NCNU shall also (1) produce all responsive documents, identified by the request number to which they respond, including the complete native records for Call #672 and Call #679 if they exist in any form within its possession, custody, or control, (2) as to any responsive record it cannot produce, serve a statement conforming to section 2031.230, and (3) as to any document withheld, serve a privilege log conforming to section 2031.240, subdivision (c)(1), or, if nothing is withheld, so state in the verified response and remove the "to which no objection was made" qualifier.

The motion is DENIED IN PART to the extent it seeks production of a native Call #672 record the record does not establish presently exists. Monetary sanctions of $5,901.60 are GRANTED against AAA NCNU and its counsel, jointly and severally, payable within thirty (30) days.

Motion to Compel Responses to Requests for Production, Set Two. GRANTED IN PART. Within twenty (20) days of this order, AAA NCNU shall serve verified responses to Nos. 1 through 15, without objection, in substantial compliance with Code of Civil Procedure sections 2031.210 through 2031.280, and produce all responsive documents, identified by the request

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518 number to which they respond, including the GPS metadata, event-recorder data, and associated metadata sought by Nos. 2, 3, and 4, or serve statements of inability to comply conforming to section 2031.230. AAA NCNU's request for relief from waiver is DENIED without prejudice. Monetary sanctions of $1,311.60 are GRANTED against AAA NCNU and its counsel, jointly and severally, payable within thirty (30) days.

Motion to Compel Responses to Special Interrogatories, Set One. GRANTED IN PART. Within twenty (20) days of this order, AAA NCNU shall serve responses to Nos. 1 through 11, without objection, in substantial compliance with Code of Civil Procedure sections 2030.210, 2030.220, 2030.230, and 2030.240, signed and verified as required by section 2030.250, including complete answers to the contention interrogatories (Nos. 8 through 11) stating the facts supporting each contention. AAA NCNU's request for relief from waiver is DENIED without prejudice. Monetary sanctions of $1,311.60 are GRANTED against AAA NCNU and its counsel, jointly and severally, payable within thirty (30) days.

AAA NCNU's requests for monetary sanctions against Plaintiffs are DENIED.

PLEASE NOTE: Pursuant to California Rule of Court 3.1308, subdivision (a)(1), this tentative ruling will become the order of the Court unless it is contested before 4:00 PM on the court day preceding the noticed hearing.

To contest a tentative ruling, a party should do the following:

First, the party must notify Department 518, by email at Dept518@alameda.courts.ca.gov and copy all counsel of record and self-represented parties. The contesting party must state in the subject line of the email the case name, case number and motion.

Second, the party shall log into the eCourt Public Portal, search for this case (e.g., by case number), select the case name, select the "Tentative Rulings" tab, click the "Click to Contest this Ruling" button, enter the party's name and a brief statement of the party's reason for contesting the tentative, and click "Proceed."

Please note the Court does not permit remote appearances for motions for summary judgment that are contested. If you contest a Motion for Summary Judgment, you must appear in person.

For all other motions (unless otherwise noted in the tentative ruling), Parties may appear via videoconference, using the Zoom.com website or application. TO CONNECT TO ZOOM: Department 518 is inviting you to a scheduled ZoomGov meeting.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV086445: SCOTT, et al. vs AMERICAN AUTOMOBILE ASSOCIATION OF NORTHERN CALIFORNIA, NEVADA & UTAH ("AAA NCNU"), A CORPORATION, et al. 08/25/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by Marlin Scott (Plaintiff) CRS# 206075350532 in Department 518

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