PATEL, et al. vs WALMART, INC., et al.

25CV002180: PATEL, et al. vs WALMART, INC., et al. 01/07/2026 Hearing on Motion to Compel Further Responses to Request Production of Documents in Department 25

Tentative Ruling

NOTICE:

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25CV002180: PATEL, et al. vs WALMART, INC., et al. 01/07/2026 Hearing on Motion to Compel Further Responses to Request Production of Documents in Department 25

and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

TENTATIVE RULING

Plaintiffs Dilshad Patel, Azita Patel, Mehreen Patel, and Benita Patel’s (“Plaintiffs”) Motion to Compel Further Responses to Requests for Production of Documents from Defendant Walmart, Inc.’s (“Defendant”) is CONTINUED to February 25, 2026 to permit the parties to engage in further meet-and-confer efforts.

Plaintiffs served the at issue discovery requests on July 28, 2025. (Cloyd Decl., ¶ 3.) Following an extension of time to respond, Defendant timely served responses on September 26, 2025. (Cloyd Decl., ¶¶ 5, 6.) The parties engaged in meet and confer efforts regarding the use of a protective order but were unable to come to an agreement regarding the terms of such. (Cloyd Decl., ¶¶ 7-11.)

Plaintiffs now move to compel further responses to requests for production of documents, set one, nos. 1-15. Defendant opposes. In opposition, Defendant argues, inter alia, that Plaintiffs failed to meet their meet and confer obligation prior to bringing the instant motion. The Court agrees.

In bringing a motion to compel pursuant to Code of Civil Procedure section 2031.310, the motion must include a meet and confer declaration which “shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” (See also Code Civ. Proc. § 2016.040.)

Here, Plaintiffs represent that the parties were discussing responses and Defendant “withdrew from its end of the parties’ agreement,” and that Defendant “rejected Plaintiffs’ both proposals without explanation.” (Cloyd Decl., ¶¶ 10, 11.) Defendant has attached email correspondence between the parties which show that Defendant provided a redline version of a proposed protective order, to which counsel for Plaintiffs responded stating that Plaintiffs would not agree to a protective order until Defendant agreed to “amend the responses (for both interrogatories and document requests) with codecompliant responses that remove the inapplicable objections; agree to provide those responses by a date certain (how about October 31); and identify which documents you will produce no later than October 31 regardless of the entry of a protective order,” and

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV002180: PATEL, et al. vs WALMART, INC., et al. 01/07/2026 Hearing on Motion to Compel Further Responses to Request Production of Documents in Department 25

until that time declined to engage in any further meet-and-confer efforts on the subject of the protective order. (Colbert Decl., ¶ 19, Ex. 11.) The Court finds that Plaintiffs have not shown that they have sufficiently engaged in the meet-and-confer process in a good faith effort to resolve all issue raised in the instant motion.

The Court must remind counsel that given the number of motions such as this which must be addressed on a daily basis, there are simply not enough judicial resources available to resolve each and every discovery dispute that could have and should have been resolved informally. This serves to highlight the critical need for all counsel's legitimate, reasonable and good faith meet-and-confer efforts before filing any discovery motion. Although it dealt with a motion to compel answers to deposition questions, the decision of Townsend v. Superior Court (1998) 61 Cal.App.4th 1431 is instructive in that it clarifies that the meet-and-confer process is not intended to be some perfunctory formality but rather it 'requires...a serious effort at negotiation and informal resolution.' (Id., at 1438.)

Having reviewed the moving and opposing papers, it is apparent to the Court that counsel must engage in the meet-and-confer process in good faith. Counsel for the parties are thus ordered to engage in the meet-and-confer process in order to resolve or substantially narrow their discovery dispute. In order to encourage a meaningful dialogue and improve the prospects for resolution, the meet-and-confer efforts shall be conducted either in person or via telephone, rather than by the mere exchange of letters or emails.

Counsel shall meet and confer in person no later than January 28, 2026. After thoroughly meeting and conferring in an attempt to resolve each and every discovery request that the motion currently encompasses, and no later than February 11, 2026, counsel shall file a joint statement indicating which discovery requests or pending issues have been resolved, and which requests (if any) remain outstanding. For each outstanding issue, counsel shall set forth in the joint statement their respective positions, citing the relevant facts and authorities. Boilerplate or cut-and-paste arguments are strongly discouraged. The parties are advised that the failure to comply with their meet-and-confer obligations may result in sanctions.

The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.

On the Court's own motion, the Hearing on Motion to Compel Further Responses to Request

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV002180: PATEL, et al. vs WALMART, INC., et al. 01/07/2026 Hearing on Motion to Compel Further Responses to Request Production of Documents in Department 25

Production of Documents scheduled for 01/07/2026 is continued to 02/25/2026 at 01:30 PM in Department 25 at Gordon D. Schaber Superior Court.