MENOR, et al. vs CHANEL, INC., et al.

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

Tentative Ruling - 08/25/2026 Patrick McKinney

The Motion to Compel NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT CALVIN KLEIN COSMETICS CORPORATION TO PROVIDE FURTHER, VERIFIED, CODECOMPLIANT RESPONSES TO PLAINTIFFS’ SPECIAL INTERROGATORIES, SET ONE, AND REQUESTS FOR PRODUCTION OF DOCUMENTS, SET TWO; REQUEST FOR MONETA filed by BERNARD MENOR, JOVY MENOR on 07/30/2026 is Granted in Part.

Plaintiffs Jovy Menor (“Mrs. Menor”) et al.’s Motion to Compel (“MTC”) defendant Calvin Klein Cosmetics Corp.’s (“Defendant” or “CKC”) Further Responses to Special Interrogatories (“SROG”) Nos. 1-54 and Requests for Production of Documents (“RFPD”) Nos. 31-154 and for Monetary Sanctions is GRANTED IN PART and DENIED IN PART, as set forth below.

In the Reply papers, Plaintiffs present evidence that Defendant has still not provided verifications for its initial responses. The Court ORDERS Defendant to serve verifications to its initial Responses no later than 5:00 p.m. Tuesday, 9/8/2026.

Defendant shall serve Plaintiffs with verified Further Responses to SROG Nos. 16-21 and 36 and to RFPD Nos. 31-55, 64-82, 84, 88-101, 107, 110, 112, 118-120, 122, 128-130 and 134, to the extent Ordered below, no later than 5:00 p.m. Monday, 9/14/2026.

The Court AWARDS Plaintiff a monetary sanction in the amount of $1,000 payable by Defendant for failing to provide verifications for its initial Responses by the due date of Defendant’s Opposition on this Motion.

ANALYSIS OF MTC FURTHER SROG RESPONSES

In Reply, Plaintiffs limit the at issue SROG to Nos. 1-36 and 43-54.

The Court SUSTAINS Defendant’s Objections that SROG Nos. 1-15 are overbroad and unduly burdensome. These SROG make no attempt to limit the information sought to the specific products attributable to Defendant that Mrs. Menor testified at deposition she used, nor are the SROG limited to the periods in which Mrs. Menor testified she used such products. There is no evidence in the record that Plaintiffs offered to so limit these requests during the meet and confer process before these MTC were filed. This Court has previously admonished Plaintiffs’ counsel regarding their obligation to meet and confer in good faith about narrowing the scope of their overbroad written discovery requests before bringing Motions to Compel.

Wherefore, the Court DENIES Plaintiff’s MTC Further Responses to SROG Nos. 1-15. 26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18 The Court OVERRULES all of Defendant’s Objections to SROG Nos. 16 though 21 and ORDERS Defendant to provide Further Verified Responses to SROG Nos 16 through 21.

The Court OVERRULES all of Defendant’s Objections to SROG Nos. 22-28. However, the Court finds Defendant’s substantive responses to these SROG acceptable under the circumstances. Therefore, the Court ORDERS STRICKEN all of Defendant’s Objections to SROG Nos. 22-28, but the Court DENIES Plaintiffs’ Requests for Further Responses to SROG Nos. 22-28.

The Court SUSTAINS Defendant’s Objections that SROG Nos. 29-35 are overbroad and unduly burdensome. These SROG make no attempt to limit the information sought to the specific products attributable to Defendant that Mrs. Menor testified at deposition she used, nor are the SROG limited to the periods in which Mrs. Menor testified she used such products.

Wherefore, the Court DENIES Plaintiff’s MTC Further Responses to SROG Nos. 29-35.

The Court OVERRULES Defendant’s Objections to SROG No. 36 and ORDERS Defendant to provide a Further Verified Response to SROG No.

36. The SROG calls for a yes or no answer, and Defendant can reasonably provide a substantive response to this SROG.

The Court OVERRULES all of Defendant’s Objections to SROG Nos. 43-53. However, the Court finds Defendant’s substantive responses to these SROG acceptable under the circumstances. Therefore, the Court ORDERS STRICKEN all of Defendant’s Objections to SROG Nos. 43-53, but the Court DENIES Plaintiffs’ Requests for Further Responses to SROG Nos. 43-53.

The Court SUSTAINS Defendant’s attorney-client and work product privilege objections with respect to SROG No. 54 and DENIES Plaintiff’s MTC a further response to SROG No.

54. Plaintiffs have had a reasonable opportunity to take Defendant’s person most qualified deposition to discover the identities of Defendant’s employees with personal knowledge of facts relevant to Plaintiffs’ claims in this action.

ANALYSIS OF MTC FURTHER RFPD RESPONSES

In their Reply, Plaintiffs appear to limit their Requests for Further Responses to RFPD Nos. 31- 55, 58-61 and 64-154.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 31 and 32 are overbroad and unduly burdensome. However, Defendant has provided a statement of compliance. These Responses do not comply with the requirements of CCP §§ 2031.240(b) and 2031.280(a). If the Responses are limited to the products and time periods regarding which Mrs. Menor testified, the Responses should clearly so state. Further, the Responses must identify the specific pages in

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18 Defendant’s 2,257-page document production that are responsive to each of these RFPD. Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 31 and 32 that comply with the requirements of §§ 2031.240(b) and 2031.280(a).

The Court SUSTAINS Defendant’s Objection that RFPD Nos. 33-36 are overbroad and unduly burdensome. However, the Responses do not comply with the requirements of § 2031.230, specifically a particularized statement of the reasons why no responsive documents can be produced.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 33-36 that comply with the requirements of § 2031.230.

The Court OVERRULES all of Defendant’s Objections to RFPD Nos. 37-49. Further, the initial Responses do not comply with the requirements of CCP § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 37-49 without objections that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 50 and 51 are overbroad and unduly burdensome. However, Defendant has provided a statement of compliance. These Responses do not comply with CCP §§ 2031.240(b) and 2031.280(a). If the Responses are limited to the products and time periods regarding which Mrs. Menor testified, the Responses should clearly so state. Further, the Responses must identify the specific pages in Defendant’s 2,257-page document production that are responsive to each of these RFPD.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 50 and 51 that comply with the requirements of §§ 2031.240(b) and 2031.280(a).

The Court OVERRULES all of Defendant’s Objections to RFPD Nos. 52-53. Further, the initial Responses do not comply with the requirements of CCP § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 52-53 without objections that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 54 and 55 are overbroad and unduly burdensome. However, the statement of inability to comply with the request does not meet the requirements of § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 54 and 55 that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 58-61 are overbroad, unduly

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18 burdensome and not reasonably calculated to lead to the discovery of admissible evidence in this trial preference action.

Wherefore, the Court DENIES Plaintiffs’ Request for Further Responses to RFPD Nos. 58-61.

The Court OVERRULES all of Defendant’s Objections to RFPD Nos. 64-76. Further, the initial Responses do not comply with the requirements of CCP § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 64-76 without objections that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 77-83 are overbroad and unduly burdensome. However, the statement of inability to comply with the request does not meet the requirements of § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 77-82 that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objection that RFPD No. 83 is not reasonably calculated to lead to the discovery of admissible evidence and is unduly burdensome.

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No.

83.

The Court OVERRULES Defendant’s Objections to RFPD No.

84. Further, the initial Response does not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to provide a verified Further Response to RFPD No. 84 without objections that complies with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 85-87 are overbroad and unduly burdensome.

Wherefore, the Court DENIES Plaintiffs’ request for a further Response to RFPD Nos. 85-87.

The Court OVERRULES all of Defendant’s Objections to RFPD Nos. 88 and 89.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 88 and 89 without objections that comply with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 90-92 are overbroad and unduly burdensome. However, the statements of inability to comply with these Request do not meet the requirements of § 2031.230.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 90-92 that comply with the requirements of § 2031.230.

The Court OVERRULES all of Defendant’s Objections to RFPD Nos. 93-99. Further, the initial Responses do not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to provide verified Further Responses to RFPD Nos. 93-99 without objections that complies with the requirements of § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD No. 100 and 101 are overbroad and unduly burdensome. However, the Responses contain a statement of compliance but which does not comply with the requirements of § 2031.280(a).

Wherefore, the Court ORDERS Defendant to provide verified Further Response to RFPD Nos. 100 and 101 that comply with § 2031.280(a) and that contains a statement of compliance with respect to any and all record retention policies or efforts to preserve evidence in effect from the date on which Mrs. Menor testified she first began using talcum powder products attributable to Defendant through the present.

The Court SUSTAINS Defendant’s Objections that RFPD No. 102 is overbroad and unduly burdensome. Further, the Court finds that RFPD No. 102 is unnecessarily duplicative of RFPD No.

89.

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No. 102.

The Court finds RFPD No. 103 unduly repetitive of RFPD No.

99.

Wherefore, the Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 103.

The Court SUSTAINS Defendant’s Objections that RFPD No. 104 is vague and ambiguous, overbroad and unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Wherefore, the Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 104.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 105 and 106 are overbroad and unduly burdensome. It is also unclear to the Court what discrete groups of documents these RFPD seek.

Wherefore, the Court DENIES Plaintiff’s Request for Further Responses to RFPD Nos. 105 and 106.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

The Court SUSTAINS Defendant’s Objections that RFPD No. 107 is overbroad and unduly burdensome. However, the Response to RFPD No. 107 does not comply with the requirements of § 2031.230.

Wherefore, the Court ORDERS Defendant to provide a verified Further Response to RFPD No. 107 that complies with § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD No. 108 is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Further, the term “packaging specifications” is vague and ambiguous.

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No. 108.

The Court SUSTAINS Defendant’s Objections that RFPD No. 109 is overbroad and unduly burdensome.

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No. 109.

The Court SUSTAINS Defendant’s Objections that RFPD No. 110 is overbroad and unduly burdensome. However, the Response to RFPD No. 110 does not comply with the requirements of § 2031.230.

Wherefore, the Court ORDERS Defendant to provide a verified Further Response to RFPD No. 110 that complies with § 2031.230.

The Court SUSTAINS Defendant’s Objections that RFPD No. 111 is overbroad, unduly burdensome and not reasonably calculated to the discovery of admissible evidence in this trial preference action.

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No. 111.

The Court SUSTAINS Defendant’s Objections that RFPD No. 112 is overbroad and unduly burdensome. However, the Response contains a statement of compliance that does not comply with the requirements of §§ 2031.240(b) and 2031.280(a).

Wherefore, the Court ORDERS Defendant to serve a verified Further Response to RFPD No. 112 that complies with §§ 2031.240(b) and 2031.280(a).

The Court SUSTAINS Defendant’s Objections that RFPD No. 113 is overbroad, unduly burdensome and not reasonably calculated to the discovery of admissible evidence in this trial preference action.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

Wherefore, the Court DENIES Plaintiffs’ Request for a Further Response to RFPD No. 113.

The Court SUSTAINS Defendant’s Objections that RFPD Nos. 114-117 are overbroad and unduly burdensome.

Wherefore, the Court DENIES Plaintiffs’ Request for Further Responses to RFPD Nos. 114-117.

The Court SUSTAINS Defendant’s Objections that RFPD No. 118 is overbroad and unduly burdensome. However, the Court finds that the Response does not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to serve a verified Further Response to RFPD No. 118 that complies with § 2031.230.

The Court OVERRULES Defendant’s Objections to RFPD Nos. 119 and 120. Further, the Response does not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to serve verified Further Responses to RFPD Nos. 119-120 without objections that comply with § 2031.230.

The Court DENIES Plaintiffs’ Request for a further Response to RFPD No. 121 as unduly repetitive of RFPD No. 119.

The Court OVERRULES Defendant’s Objections to RFPD No. 122. Further, the initial Response does not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to serve a verified Further Response to RFPD No. 122 without objections that complies with § 2031.230.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 123. Plaintiffs do not allege that Mrs. Menor has talcosis. Thus, the request is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 124 as unduly repetitive of RFPD No. 122.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 125. Plaintiffs do not allege that Mrs. Menor has talcosis. Thus, the request is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 126 as unduly repetitive of RFPD No. 122.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 127. Plaintiffs do not allege that Mrs. Menor has talcosis. Thus, the request is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The Court OVERRULES Defendant’s Objections to RFPD Nos. 128-130. Further, the initial Responses do not comply with § 2031.230.

Wherefore, the Court ORDERS Defendant to serve verified Further Responses to RFPD Nos. 128-130 without objections that comply with § 2031.230.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 131. Plaintiffs do not allege that Mrs. Menor has talcosis. Thus, the request is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD Nos. 132 and 133 as unduly repetitive of RFPD Nos. 66-69.

The Court OVERRULES Defendant’s Objections to RFPD No. 134. Further, the Response does not comply with the requirements of § 2031.230.

Wherefore, the Court ORDERS Defendant to serve verified Further Responses to RFPD No. 134 without objections that comply with § 2031.230.

The Court DENIES Plaintiff’s Request for a Further Response to RFPD No. 135. Plaintiffs do not allege that Mrs. Menor has talcosis. Thus, the request is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The Court summarily DENIES Plaintiffs’ Requests for Further Responses to RFPD Nos. 136- 154. 135 RFPD is more than enough in this trial preference action, particularly where CCP § 2031.210 et seq. has been amended in recent years to require substantially more information than previously required. Further, the Court expressly finds that the present set of 154 RFPD served on Defendant constitute a misuse of the discovery process pursuant to CCP § 2023.010(c).

Further, discovery motions of this volume and this lacking in merit or necessity in a trial preference action are a misuse of the Court’s limited judicial resources.

The Court AWARDS Plaintiffs a monetary sanction payable by Defendant in the amount of $1,000 based on Defendant’s failure to serve verifications for its initial responses by the due date for its Opposition on this Motion. No further sanctions are warranted. However, the Court admonishes Defendant that failure to comply with this Order is likely to result in more severe sanctions if Defendant’s non-compliance is timely raised by Plaintiffs.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/27/2026 Hearing on Motion to Compel Plaintiffs Motion to Compel Calvin Klein Cosmetics re SROG1 and RPD2; filed by JOVY MENOR (Plaintiff) + CRS# 237870327347 in Department 18

The Court admonishes Plaintiffs’ counsel for the second time that they and their clients should reasonably anticipate delays in selecting and seating a jury until all of Plaintiffs’ many voluminous motions have been fully adjudicated, if necessary after preliminary trial proceedings have begun. At least one motion in this action presently scheduled for hearing on 8/27/2026 will need to be continued due to the judicial resources required to adjudicate Plaintiffs’ voluminous discovery motions.