MANN vs MANN, et al.

23CV013483: MANN vs MANN, et al. 02/17/2026 Hearing on Motion for Leave of Court to File a Fourth Amended Complaint in Department 54

Tentative Ruling

Plaintiff Maninderjit Kaur Mann’s (“Plaintiff”) motion for leave to file a fourth amended verified complaint is DENIED, without prejudice.

This is a quiet title action. Plaintiff seeks leave to file a fourth amended verified complaint to “clarify and strengthen allegations of standing to bring this quiet title action.” (Memorandum at 1:18.) Plaintiff appears to seek leave to attach three exhibits to the complaint. Defendant Hardip Singh Mann (“Defendant”) opposes. No trial is set.

Pursuant to California Rules of Court, rule 3.1324(a), a motion to amend a pleading before trial must:

(1) Include a copy of the proposed amendment or amended pleading, which must be serially numbered to differentiate it from previous pleadings or amendments;

(2) State what allegations in the previous pleading are proposed to be deleted, if any, and where, by page, paragraph, and line number, the deleted allegations are located; and

(3) State what allegations are proposed to be added to the previous pleading, if any, and where, by page, paragraph, and line number, the additional allegations are located.

The motion must also include a separate declaration that must specify:

(1) The effect of the amendment;

(2) Why the amendment is necessary and proper;

(3) When the facts giving rise to the amended allegations were discovered; and

(4) The reasons why the request for amendment was not made earlier.

(Cal. Rules of Court, rule 3.1324(b).)

Plaintiff’s motion fails to comply with Rule 3.1324(a), in that it does not state what allegations in the previous pleading are to be added or deleted by page, paragraph, and line number. For example, the Court observes that changes were made to paragraph 10 of the complaint, but such changes were not described in the motion. Additionally,

23CV013483: MANN vs MANN, et al. 02/17/2026 Hearing on Motion for Leave of Court to File a Fourth Amended Complaint in Department 54

Plaintiff’s proposed fourth amended verified complaint, attached as Exhibit A to the memorandum, does not include the three exhibits described in the motion.

A review of Ms. Wood’s declaration reveals that the supporting declaration also does not comply with Rule 3.1324(b). The declaration does not state the effect of the amendment, why the amendment is necessary and proper, when the facts giving rise to the amended allegations were discovered, or why the request for amendment was not made earlier. To the extent Plaintiff argues the moving papers set forth the relevant facts, the Court notes that the requirements of Rule 3.1324 are mandatory and therefore such statements must be contained in the supporting declaration. Moreover, Plaintiff’s moving papers do not explain when the facts giving rise to the amended allegations were discovered or why the request for amendment was not made earlier.

Accordingly, the motion is denied without prejudice.

Defendant’s request for sanctions is denied. Defendant presents no legal authority that would authorize sanctions in connection with the instant motion.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.)

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Law and Motion Oral Argument Request Line at (916) 874-2615 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

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SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

23CV013483: MANN vs MANN, et al. 02/17/2026 Hearing on Motion for Leave of Court to File a Fourth Amended Complaint in Department 54

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