Chang vs. County of Orange

4. Chang vs. County of Orange

25-01481350

Motion to Compel Production

Plaintiff Marivel Chang’s motion to compel further responses to her first set of requests for production is DENIED IN PART and CONTINUED IN PART, as follows.

This motion concerns requests for production (RFP) Nos. 21-23, 25, 28, 31-33, 58, 63, 66, 70, and 80.

The motion is DENIED as to RFP Nos. 31-33. Plaintiff has failed to show good cause for the discovery sought by these egregiously overbroad demands. (Code Civ. Proc., § 2031.310, subd. (b)(1) [good cause requirement]; Glenfed Develop. Corp. v. Superior Court (1997) 53 Cal.App.4th 1113, 1117 [good cause].) Plaintiff claims RFP Nos. 31-33 seek “me too” evidence, but they go far beyond seeking such evidence, and plaintiff has failed to show how the information sought may otherwise assist her in evaluating this case, preparing for trial, or facilitating settlement. (See Code Civ.

Proc., § 2017.010 [scope of discovery]; Lopez v. Watchtower Bible & Tract Society of New York, Inc. (2016) 246 Cal.App.4th 566, 590-591 [relevance for purposes of discovery]; see also Pinter-Brown v. Regents of University of California (2020) 48 Cal.App.5th 55, 89, 96-98 [me too evidence]; Calcor Space Facility, Inc. v. Superior Court (1997) 53 Cal.App.4th 216, 224; Steiner Decl., in passim.)

The motion is CONTINUED as to RFP Nos. 21-23, 25, 28, 58, 63, 66, 70, and 80, and the request for sanctions, to October 20, 2026, at 9:00 a.m. in Department CM02.

On 4/14/26, just prior to the filing of this motion, defendant County of Orange served a substantive supplemental response to RFP No. 58, along with a substantial production and a second privilege log. (See Chmura Decl. ¶ 5, Ex. C.)

On 8/17/26, long after this motion was filed, defendant also attempted to “moot” the motion (and avoid having to justify its responses and objections) to most of the RFPs at issue by serving another set of supplemental responses, which do not correct any of the deficiencies in its prior responses. (See Nguyen Decl. ¶ 5, Ex. E.) These new 8/17/26 “supplemental” responses do not meaningfully differ from defendant’s prior responses and remain inadequate (indeed, some are worse); most simply rephrase and reiterate the same prior response to the subject request. (See ibid.) This reeks of gamesmanship and is not well taken. (See County of San Benito v. Superior Court (2023) 96 Cal.App.5th 243, 256.)

The court is therefore continuing the hearing on this matter to order the parties to engage in a further, face-to-face, meet and confer conference as to defendant’s most recent responses to the RFPs that remain at issue, and to allow defendant a full and fair opportunity to address the sufficiency/propriety of those responses.

As such, the court hereby ORDERS all of the following:

(1) By no later than Wednesday 9/23/26, the parties shall engage in a further, good faith, face-to-face meet and confer effort (inperson or videoconference) regarding defendant’s most recent supplemental responses to RFP Nos. 21-23, 25, 28, 58, 63, 66, 70, and 80, including, without limitation, the 4/14/26 supplemental response to RFP No. 58 and the 8/18/26 supplemental responses to RFP Nos. 21-23, 25, 63, 66, 70. (2) By no later than Wednesday 9/30/26, the parties shall file a joint separate statement as to the RFPs that remain at issue after the court-ordered meet and confer conference above, if any. This joint separate statement shall fully comply with Cal. Rules of Court, rule 4.1345(c)(1)-(6), and shall additionally include a statement of the factual and legal reasons why a further response should not be compelled as to each matter in dispute.

Plaintiff shall give notice.

5. Padilla Hernandez vs. Pacific Specialty Insurance Company

26-01537689

Motion to Compel Answers to Form Interrogatories

Defendant Pacific Specialty Insurance Company’s motion to compel responses to its first set of form interrogatories is GRANTED. (See Code Civ. Proc., § 2030.290.)

Plaintiff Mario Padilla Hernandez is ORDERED to serve verified responses without objections to defendant’s first set of form interrogatories, within 30 days of notice.

Sanctions in the amount of $960 are GRANTED in favor of defendant and against plaintiff, payable within 30 days of notice.

Defendant shall give notice of all of the above.

6. Gombu, LLC vs. Do Builder and Design, Inc.

23-01367281 Motion to Compel Further Responses to Special Interrogatories

CONTINUED to September 4, 2026. ROA 193