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Notice Of Motion And Motion To Compel Further Responses To Request For Production Of Documents, Set Two, Against Defendant Mobile Products, Inc., Request For Monetary Sanctions
Matter on the Law & Motion / Discovery calendar for Tuesday, October 7, 2025, Line 1. [Part 1 of 2 of the tentative ruling.] PLAINTIFFS BEATRICE CEJA, ALEXIS PELAYO, ARMANI PELAYO, ESMERELDA PELAYO, AND EMMANUEL CEJA's Motion To Compel Further Responses To Request For Production Of Documents, Set Two, Against Defendant Mobile Products, Inc., Request For Monetary Sanctions.
Plaintiffs Beatrice Ceja et al.'s ("Ceja") motion to compel further responses to requests for production of documents, set two, from defendant Mobile Products Inc. is granted in part as stated herein. Discovery is liberally granted and Ceja's requests are reasonably calculated to lead to the discovery of admissible evidence. Ceja has the burden of setting forth specific facts showing good cause for production of each disputed category of document or thing. (Code Civ. Proc., section 2031.310, subd. (b)(1).)
But she need not prove her case in order to obtain discovery to prove her case. (See Williams v. Superior Court (2017) 3 Cal.5th 531, 551 ["The Legislature was aware that establishing a broad right to discovery might permit parties lacking any valid cause of action to engage in fishing expeditions, to a defendant's inevitable annoyance. It granted such a right anyway, comfortable in the conclusion that mutual knowledge of all the relevant facts gathered by both parties is essential to proper litigation."] [citation simplified].)
No. 25: Ceja seeks an exemplar unit (a defined term) to inspect. This is a proper subject of discovery. Mobile Products never states whether it has a unit in its possession. It must so state on amendment, and it if does it must provide the requested inspection within a reasonable time after amending. Questions about whether a particular unit is an exemplar or not should be resolved through meet and confer efforts, not through objections.
No. 26: Only if no exemplar unit is in Mobile Products' possession, Ceja seeks information to locate an exemplar. Mobile Products' objections lack merit.
No. 27: The request is not proper. If Mobile Products has made a statement of compliance in response to a prior set of discovery, Ceja may demand compliance and make an appropriate motion if Mobile Products does not comply with its statement of compliance. (See Code Civ. Proc., section 2031.320, subd. (a).) No further response to this RFP is ordered.
Nos. 28-29: Mobile Products' objections lack merit. It is ordered to amend with a statement that it has no such documents (in compliance with Code Civ. Proc. section 2031.230) or a statement of compliance.
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Nos. 31, 33, 34, 36, 37, 39, 40, 41, 42, 43: These document requests relate to the LayMor Sweepmaster 300, a successor design to the one that Ceja's decedent was using. The court concludes that Ceja has stated sufficient facts about why the successor design is relevant to her claims; it is a potential alternative safer design. Mobile Products' relevance objections lack merit. Mobile Products generally asserts overbreadth claims. This ordinarily presents questions of fact and parties are often required to provide declarations about the extent of a burden before such objections are sustained. Here, however, the court exercises its discretion to narrow some of the requests at first pass. Nothing in this order precludes Ceja from serving additional targeted discovery requests for documents that were covered by this order where the court has narrowed the request.
Mobile Products' objections are overruled to the following requests: 31, 39, 40, 41. Mobile Products shall make a statement of compliance but may withhold attorney-client and other privileged documents. It must provide a privilege log. It may condition production on entry of an appropriate protective order but is ordered to meet and confer forthwith about a protective order. [End of part 1 of 2 of the tentative ruling]. =(301/CVA) | |