MARQUEZ, AN INDIVIDUAL, et al. vs CABEZAS, AN INDIVIDUAL, et al.

24CV100519: MARQUEZ, AN INDIVIDUAL, et al. vs CABEZAS, AN INDIVIDUAL, et al. 08/27/2026 Hearing on Motion to Compel Further Discovery Responses filed by Vadim Ceban, an individual (Defendant) + CRS# 335236256505 in Department 520

Tentative Ruling - 08/19/2026 Jamilah A. Jefferson

The Motion to Compel Further Discovery Responses filed by Victoria Amoroso-Ceban, an individual, Vadim Ceban, an individual, Jose Najarro Cabezas, an individual on 07/02/2026 is Denied.

For similar reasons indicated in the Court's ruling on the concurrent Motion to Compel Further as to Plaintiff Rafael Marquez, the unopposed Motion to Compel Further as to Plaintiff Bianca Marquez ("Plaintiff") is also DENIED WITHOUT PREJUDICE.

DISCUSSION From the Notice of Motion, the subject discovery requests appear to include: (1) FROGS 10.1, 11.1 and 20.4; (2) SPROGS 1-2, 8-9, 13-14, 17-21, 24 and 30-31; (3) RFAs 15, and 19-20; and (4) RPDs 2, 5-6, 17, 21-23, and 25-29. (Separate Statement; Lowe Decl., ¶¶ 2-5, Exs. A-H.) On October 23, 2025, Defendants served their first set of discovery requests consisting of Form Interrogatories – General (“FROGS - General”); Special Interrogatories (“SPROGS”); Requests for Admission (“RFAs”), and Requests for Production of Documents (“RPDs”). (Lowe Decl., ¶¶ 2-5, Exs.

A, C, E.) On December 23, 2025, Plaintiff served verified responses to the FROGS, SPROGS and RFAs. (Id. at Exs. B, D, F.) It is unclear when Plaintiff served his initial responses to the RPDs, as Defendants do not specify or attach them, but on April 29, 2026, Plaintiff served verified amended responses to the RPDs after the parties met and conferred. (Id. at ¶ 13, Ex. H.) On February 12, 2026, Plaintiff served amended verified responses to the FROGS. (Id. at ¶ 7, Ex. K.) From Defendants’ Separate Statement, there are three versions of responses to the FROGS; however, only the initial and first amended responses are attached to counsel’s supporting declaration.

As far as the Court can tell, there were only two versions of responses to the FROGS. Although Defendants state “On April 29, 2026, Plaintiffs provided further responses to Defendants’ first set of written discovery," it is not clear what these consist of, as nothing dated April 29, 2026 is attached except for the responses to the RPDs. (Id. at ¶ 13.) As it is unclear what the content of the subject discovery responses at issue are, the Motion is DENIED WITHOUT PREJUDICE. If necessary after meeting-and-conferring further, Defendants may refile the motion after clearly identifying each discovery request at issue and ensuring that it matches up across the Notice of Motion; Memorandum of Points and Authorities; Separate Statement; and Proposed Order, and attaching all relevant responses.

It is also helpful for the timeline of the parties’ discovery dispute to be expressly laid out for clarity.

The Court notes that it is inclined to deem relevant prior medical providers, specific identification of injuries, healthcare insurance, and specification of dates related to injuries. Further, the Court is inclined to award sanctions for unreasonable refusal to disclose or provide 24CV100519: MARQUEZ, AN INDIVIDUAL, et al. vs CABEZAS, AN INDIVIDUAL, et al. 08/27/2026 Hearing on Motion to Compel Further Discovery Responses filed by Vadim Ceban, an individual (Defendant) + CRS# 335236256505 in Department 520 information and documents that are unquestionably relevant.

NOTICE: This tentative ruling will automatically become the court’s final order on August 20, 2026 unless, by no later than 4:00 P.M. on August 19, 2026, a party to the action notifies BOTH: 1) the court by emailing Dept520@alameda.courts.ca.gov; AND 2) all opposing counsel or selfrepresented parties (by telephone or email) that the party is contesting this tentative ruling.

The subject line (RE:) of the email must state: “Request for CONTESTED HEARING: [the case name], [number].” When a party emails to contest a tentative ruling, the party must identify the specific holding(s) within the ruling they wish to contest via oral argument.

The court does not provide court reporters for hearings in civil departments. A party who wants a record of the proceedings must engage a private court reporter. (Local Rule 3.95.) Any privately retained court reporter must also participate via video conference. Their email must be provided to the court at the time the Notice of Contest is emailed.

ALL CONTESTED LAW AND MOTION HEARINGS ARE CONDUCTED VIA REMOTE VIDEO unless an in person appearance is required by the court. Invitations to participate in the video proceeding will be sent by the court upon receipt of timely notice of contest. A party may give email notice they will appear in court in person for the hearing, however all other counsel/parties and the JUDGE MAY APPEAR REMOTELY.