Sedaghati v. Tesla, Inc.

(Stanley Mosk Courthouse: Dept. 517) August 26, 2026 DEPARTMENT 517 LAW AND MOTION RULINGS

Plaintiff Arshia Sedaghati ("Sedaghati") sued Defendant Tesla, Inc. ("Tesla") for alleged violations of the Song-Beverly Consumer Warranty Act and the Tanner Consumer Protection Act. Pending before the Court are three discovery motions that Sedaghati filed seeking orders compelling Tesla to provide objection-free responses to special interrogatories ("SROGs"), form interrogatories ("FROGs"), and requests for production of documents ("RFPs") that Sedaghati propounded on Tesla but to which Tesla has not responded. Also pending before the Court is a fourth discovery motion that Sedaghati filed: a motion for an order deeming admitted the matters in requests for admissions ("the RFAs") that Sedaghati propounded on Tesla but to which Tesla has not responded.

The Court is granting all four of Sedaghati's motions. Tesla must provide objection-free responses to the SROGs, FROGs, and RFPs within 14 days of this order. And the matters in the RFAs are deemed admitted, as Sedaghati requested.

Sedaghati served Tesla with all of the discovery at issue here on October 15, 2025. Per the Code of Civil Procedure's timetable, Tesla's responses to the discovery were due thirty days thereafter, or November 14, 2025. Tesla did not meet that deadline. Having not received any responses, on December 1, 2025, Sedaghati filed the four discovery motions that are before the Court today.

Tesla contends that, in a telephone conversation on November 14, 2025, Sedaghati's counsel orally agreed to the request of Tesla's counsel made during the conversation for a 30-day extension of the due date for Tesla's responses to the discovery, thus making the due date December 14, 2025. According to Tesla, Sedaghati's filing of the four discovery motions on Decemer 1, 2025 contravened the parties' oral argreement to extend the due date of Tesla's responses to the discovery. Sedaghati's counsel denies that he agreed to any extension of the due date for Tesla's responses to the discovery during the November 14, 2025 phone conversation with Tesla's counsel. Tesla has failed to present any writing -- an email or text message, for example -- confirming the purported agreed-upon extension of the due date for Tesla's responses to the discovery.

Perhaps T esla's initial failure to respond to the discovery by the November 14, 2025 due date was justified based on a belief of Tesla's counsel, even if that belief was mistaken, that Sedaghati's counsel orally agreed during the November 14, 2025 phone conversation to a 30-day extension of the due date. What is not justified, however, is Tesla's failure to provide responses to any of the discovery by the 30-day extension date (December 14, 2025) and its continued failure to this day to provide responses to any of the discovery. Indeed, Tesla does not contend that it has provided responses.

Because Tesla has not responded at all to the SROGs, FROGs, and RFPs, it has waived any objections it may have had to that discovery. Tesla thus must provide Sedaghati with objection-free responses to the SROGs, FROGs, and RFPs. And because Tesla has not responsed to the RFAs, the matters in them are deemed admitted, per Code of Civil Procedure section 2033.280, subdivision (c).

Tesla has filed a motion for an order seeking relief from waiver of its objections to the discovery that Sedaghati propounded; the motion is set for hearing on December 1, 2026. The Court is advancing Tesla's motion to today and denying it. For a party to obtain relief from a waiver of its objections to discovery based on a failure to timely respond to the discovery, the party must show that (1) its failure to respond on time was the result of mistake, inadvertence, or excusable neglect and (2) it has subsequently served responses to the discovery that substantially comply with the requirements of the Code of Civil Procedure. (Code Civ. Proc., Sec. 2030.290, subd. (a) [interrogatories]; Sec. 2033.300, subdivision (a) [requests for production of documents]; 2033.280, subdivision (a) [requests for admission].)

Even if Tesla's failure to respond to the discovery that Sedaghati propounded by the November 14, 2025 due date reflects a mistake, inadvertence, or excusable neglect stemming from Tesla's understanding of what was said about a possible extension of the due date in the phone conversation with Sedaghati's counsel that day, Tesla would not be entitled to relief from a waiver of its objections to the discovery. That is because (as indicated above), Tesla has offered no evidence whatsoever that it has subsequently provided any responses to the discovery.

Case Number: 25STCV36639 Hearing Date: August 26, 2026 Dept: 517 Plaintiff Andres Hector Gomez ("Gomez") sued Defendant Toyota Motor Sales, USA, Inc. ("Toyota) under the Song Beverly Consumer Warranty Act ("the SBA") breaches of the express and implied warranties associated with a motor vehicle that Toyota distributed and that Gomez purchased. Pending before the Court is Gomez's motion for an order compelling Toyota to provide further responses to requests for production of documents that Gomez propounded on Toyota. In resolving disputes over plaintiffs' requests to defendant automobile manufacturers/distributors for the production of documents in SBA cases, this Court has relied on the template set forth below as a guide on what is discoverable.

1. The Warranty Policy and Procedure Manual published by Defendant and provided to its authorized repair facilities, within the State of California, from the date of purchase of the subject vehicle to the present.

2. Any internal analysis or investigation regarding defects alleged in plaintiff's complaint in vehicles of the same year, make, and model as the subject vehicle purchased in California. This includes Recall Notices and Technical Service Bulletins.

3. Policies and procedures used to evaluate customer complaints relating to defects alleged in plaintiff's complaint in vehicles purchased in California of the same year, make and model as the subject vehicle.

4. Policies and procedures used to evaluate customer requests for repurchase pursuant to the Song-Beverly Consumer Warranty Act, from the date of purchase to the present.

5. Repair orders and invoices concerning the subject vehicle.

6. Communications with dealer, factory representative and/or call center concerning the subject vehicle.

7. Warranty claims submitted and/or approved by Defendant concerning the subject vehicle.

The Court directs counsel for Gomez and Toyota to meet and confer regarding this template as a way to resolve their discovery dispute. The Court is continuing the hearing on Gomez's motion to January 25, 2027 at 8:30. The case is already on the Court's calendar that day for other matters. At least one week prior to the continued hearing date, the parties shall file a joint status report on which requests for production of document remain at