Jimmy Lee Jackson Jr. v. FCA US, LLC

(Inglewood Courthouse: Dept. 5) August 26, 2026 DEPARTMENT 5 LAW AND MOTION RULINGS

Superior Court of California County of Los Angeles - SOUTHWEST District Department 5 JIMMY LEE JACKSON JR.; Plaintiff, vs. FCA US, LLC; Defendant. | Case No.: |

| | | Hearing Date: | August 26, 2026 | | | Time: | 8:30 a.m. | | | [tentative] Order RE: (1) DEFENDANT FCA US, LLC'S MOTION TO COMPEL PLAINTIFF JIMMY LEE JACKSON JR. TO PROVIDE FURTHER RESPONSES, WITHOUT OBJECTIONS, TO DEFENDANT'S FORM INTERROGATORIES

(2) DEFENDANT FCA US, LLC'S MOTION TO COMPEL PLAINTIFF JIMMY LEE JACKSON JR. TO PROVIDE FURTHER RESPONSES TO DEFENDANT'S FORM INTERROGATORIES (3) DEFENDANT FCA US, LLC'S REQUESTS FOR MONETARY SANCTIONS | MOVING PARTY: Defendant, FCA US, LLC RESPONDING PARTY: No opposition.

(1) Defendant FCA US, LLC's Motion to Compel Plaintiff Jimmy Lee Jackson Jr. to Provide Further Responses, without Objections, to Defendant's Form Interrogatories is DENIED to Code of Civil Procedure section 2030.300, subdivision (b)(1).

(2) Defendant FCA US, LLC's Motion to Compel Plaintiff Jimmy Lee Jackson Jr. to Provide Further Responses to Defendant's Special Interrogatories is DENIED to Code of Civil Procedure section 2030.300, subdivision (b)(1).

(3) Defendant FCA US, LLC's Requests for Monetary Sanctions are DENIED pursuant to Code of Civil Procedure section 2030.300, subdivision (b)(1).

The Court considers the moving papers filed on June 30, 2026. To date, no opposition brief has been filed.

BACKGROUND

Factual Background

On September 16, 2024, plaintiff Jimmy Lee Jackson Jr. ("Plaintiff") filed the Complaint against defendants FCA US, LLC ("Defendant") and DOES 1 through 10. The Complaint includes the following causes of action: (1) Violation of Subdivision (D) of Civil Code Section 1793.2; (2) Violation of Subdivision (B) of Civil Code Section 1793.2; (3) Violation of Subdivision (A)(3) of Civil Code Section 1793.2; (4) Breach of the Implied Warranty of Merchantability (Civ. Code, Sec.Sec. 1791.1, 1794, 1795.5); and (5) Fraudulent Inducement - Concealment.

On November 7, 2024, Defendant propounded Form Interrogatories, Set One, and Special Interrogatories, Set One, on Plaintiff. (Declaration of Samantha M. Geraghty re: FROG ("FROG Geraghty Decl."), P. 3, Exh. B; Declaration of Samantha M. Geraghty re: SROG ("SROG Geraghty Decl."), P. 3, Exh. B.)

On December 10, 2024, Plaintiff served responses that were composed entirely of objections. (FROG Geraghty Decl., P. 4, Exh. C; SROG Geraghty Decl., P. 4, Exh. C.)

On May 5, 2025, Defendant's counsel sent a meet-and-confer letter to address the deficiencies in Plaintiff's responses. (FROG Geraghty Decl., P. 5, Exh. D; SROG Geraghty Decl., P. 5, Exh. D.) However, Plaintiff failed to respond to this correspondence or to provide any supplemental responses. (FROG Geraghty Decl., P.P. 6-7; SROG Geraghty Decl., P.P. 6-7.)

On May 26, 2026, the Court signed the Stipulation and Protective Order - Confidential Designation Only.

On July 30, 2026, Plaintiff's counsel filed a motion to be relieved as counsel.

On August 20, 2026, Plaintiff's counsel filed the Ex Parte Application to Advance the Hearing on Motion to Be Relieved as Counsel, or, Alternatively, for an Order Enforcing Motion to Be Relieved as Counsel.

On August 24, 2026, the Court granted the ex parte application, advancing the hearing on the motion to the same day. The Court subsequently granted the motion to be relieved as counsel. Consequently, Plaintiff is now self-represented.

LEGAL STANDARD

Code of Civil Procedure section 2030.300 provides that "[o]n receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that" the responses contain: (1) answers that are evasive or incomplete; (2)¿an unwarranted or insufficiently specific exercise of an option to produce documents in lieu of a substantive response; or (3) unmerited or overly generalized objections. (Code Civ. Proc., Sec.¿2030.300, subd. (a).)

"[N]otice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the propounding party and the responding party have agreed in writing, the propounding party waives any right to compel a further response to the interrogatories." (Code Civ. Proc., Sec.¿2030.300, subd. (c).)

Moreover, "[a] motion under subdivision (a) shall be accompanied by a meet and confer declaration under Section 2016.040." (Code Civ. Proc., Sec.¿2030.300, subd. (b)(1).)

Additionally, "Unless otherwise limited by order of the court in accordance with this title, any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence." (Code of Civ. Proc., Sec. 2017.010.)

For discovery purposes, information is regarded as relevant "if it might reasonably assist a party in evaluating the case, preparing for trial, or facilitating settlement thereof." (City of Los Angeles v. Superior Court (2017) 9 Cal.App.5th 272, 288.)

"The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust." (Code Civ. Proc., Sec.¿2030.300, subd. (d).)

Under Code of Civil Procedure section 2023.030, subdivision (a), "The court may impose a monetary sanction ordering that one engaging in the misuse of the discovery process, or any attorney advising that conduct, or both pay the reasonable expenses, including attorney's fees, incurred by anyone as a result of that conduct. The court may also impose this sanction on one unsuccessfully asserting that another has engaged in the misuse of the discovery process, or on any attorney who advised that assertion, or on both. If a monetary sanction is authorized by any provision of this title, the court shall impose that sanction unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust." (Code Civ. Proc., Sec. 2023.030, subd. (a).)

"Misuses of the discovery process include ... (d) Failing to respond or to submit to an authorized method of discovery. .... (h) Making or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery." (Code Civ. Proc., Sec. 2023.010, subds. (d), (h).)

"The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed." (Cal. Rules of Court, rule 3.1348(a).)

MEET AND CONFER REQUIREMENT

Defendant must meet and confer with Plaintiff before bringing these motions. (Code Civ. Proc., Sec. 2030.300, subd. (b)(1).)

Code of Civil Procedure section 2016.040 states that 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." (Code Civ. Proc., Sec. 2016.040.)

" 'The parties must present to each other the merits of their respective positions with the same candor, specificity and support during informal negotiations as during the briefing of discovery motions. Only after all the cards have been laid on the table, and a party has meaningfully assessed the relative strengths and weaknesses of its position in light of all available information, can there be a 'sincere' effort to resolve the matter.' " (In re Marriage of Moore (2024) 102 Cal.App.5th 1275, 1293-1294, quoting Townsend v. Superior Court (1998) 61 Cal.App.4th 1431, 1435.)

On November 7, 2024, Defendant propounded Form Interrogatories, Set One, and Special Interrogatories, Set One, on Plaintiff. (FROG Geraghty Decl., P. 3, Exh. B; SROG Geraghty Decl., P. 3, Exh. B.)

On December 10, 2024, Plaintiff served responses that were composed entirely of objections. (FROG Geraghty Decl., P. 4, Exh. C; SROG Geraghty Decl., P. 4, Exh. C.)

On May 5, 2025, Defendant's counsel sent a meet-and-confer letter to address the deficiencies in Plaintiff's responses. (FROG Geraghty Decl., P. 5, Exh. D; SROG Geraghty Decl., P. 5, Exh. D.) However, Plaintiff failed to respond to this correspondence or to provide any supplemental responses. (FROG Geraghty Decl., P.P. 6-7; SROG Geraghty Decl., P.P. 6-7.)

The Court finds that Defendant did not adequately meet and confer in accordance with Code of Civil Procedure section 2016.040. Defendant's counsel failed to make an effort to meet in person, by telephone, or via video conference to discuss the issues at hand. Instead, Defendant's counsel sent a singular meet-and-confer letter, which the Court observes fails to address the individual interrogatories or to provide a rationale as to why Plaintiff's objections are meritless. (FROG Geraghty Decl., P. 5, Exh. D; SROG Geraghty Decl., P. 5, Exh. D.)

Consequently, the Court does not consider this a sufficient attempt to meet and confer prior to bringing these motions. Accordingly, the Court DENIES Defendant's motions to compel further responses and the accompanying requests for sanctions.

ORDERS

1) Defendant FCA US, LLC's Motion to Compel Plaintiff Jimmy Lee Jackson Jr. to Provide Further Responses, without Objections, to Defendant's Form Interrogatories is DENIED.

2) Defendant FCA US, LLC's Motion to Compel Plaintiff Jimmy Lee Jackson Jr. to Provide Further Responses to Defendant's Special Interrogatories is DENIED.

3) Defendant FCA US, LLC's Requests for Monetary Sanctions are DENIED.

4) Defendant is ordered to give notice of this Court's ruling.

IT IS SO ORDERED.

DATED: August 26, 2026 _____________________________ Tamara Hall Judge of the Superior Court

Case Number: 25TRCV02670 Hearing Date: August 26, 2026 Dept: 5 Superior Court of California County of Los Angeles - SOUTHWEST District Department 5 PRODUCTION SERVICES INC., et al.; Plaintiffs, vs. RIVIAN AUTOMOTIVE LLC