SAHAKYAN VS. BMW OF NORTH AMERICA, LLC

specifying that error or irregularity at least three calendar days prior to the date for which the deposition is scheduled, on the party seeking to take the deposition and any other attorney or party on whom the deposition notice was served.”

As discussed above, Defendants objected to the notices on the grounds they were unilaterally noticed and defense counsel and/or the witnesses were unavailable. (Byrne Decl., ¶ 3, Kim Decl., Exs. B, D.) As Defendants did not previously object on the grounds Plaintiff’s notices failed to specify a defendant or to comply with section 2025.230, those objections are waived.

Under Code of Civil Procedure section 2025.450, however, a party may compel a deponent’s testimony if the deponent fails to appear “without having served a valid objection under Section 2025.410.”

Though Plaintiff contends Defendants objections were made in bad faith, Plaintiff does not dispute they were timely served in response to each of the deposition notices and thus cannot rely on section 2025.450 to compel Defendants’ attendance.

Moreover, to the extent Plaintiff relies on section 2025.480, that section applies where the deponent “fails to answer any question or to produce any document, electronically stored information, or tangible thing under the deponent’s control that is specified in the deposition notice or a deposition subpoena.” The motion “shall be made no later than 60 days after the completion of the record of the deposition, and shall be accompanied by a meet and confer declaration under Section 2016.040.” As no deposition took place section 2025.480 is also inapplicable.

2. SAHAKYAN VS. BMW OF NORTH AMERICA, LLC 2025-01531402 1. MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES

Plaintiff Grigor Sahakyan’s motion to compel defendant BMW of North America, LLC (“BMW”) to provide further responses to Form Interrogatories 12.1, 15.1 and 17.1 (Set One), is CONTINUED to 10/13/26 at 9:00 a.m., in Dept. C32.

BMW failed to participate in the meet and confer process in good faith. Although in response to Plaintiff’s initial meet and confer letter dated February 13, 2026, BMW’s counsel engaged in a telephonic conference with Plaintiff’s counsel, BMW’s counsel failed to respond to the meet and confer letters subsequently sent by Plaintiff’s counsel on February 26, 2026 and March 11, 2026. (Faulk Decl., ¶¶ 5, 6, 8, 9.)

BMW is ordered to meet and confer in good faith either telephonically or in-person with Plaintiff to attempt to resolve each issue presente d by Plaintiff’s Motion. No later than 9 court days prior to the continued

hearing, the parties are to file a Joint Statement which shall (1) describe the parties’ attempts to meet and confer pursuant to this order, (2) identify each discovery request that remains in dispute, and (3) each party’s position on the discovery request that remains in dispute.

Plaintiff to give notice.

2. MOTION TO COMPEL FURTHER RESONSES TO SPECIAL INTERROGATORIES

Plaintiff Grigor Sahakyan moves to compel defendant BMW of North America, LLC (“BMW”), to provide further responses to Special Interrogatories 2, 5, 9-13, 15-18, 21, 22, 25-29, 32 and 36 (Set One), is CONTINUED to 10/13/26 at 9:00 a.m., in Dept. C32.

The rule requiring a good faith effort to meet and confer about discovery disputes “is designed to encourage the parties to work out their differences informally so as to avoid the necessity for a formal order . . . [t]his, in turn, will lessen the burden on the court and reduce the unnecessary expenditure of resources by litigants through promotion of informal, extrajudicial resolution of discovery disputes.” (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1016.) “A reasonable and good -faith attempt at informal resolution entails something more than bickering . . . Rather, the law requires that counsel attempt to talk the matter over, compare their views, consult, and deliberate. ” (Townsend v. Superior Court (1998) 61 Cal. App. 4th 1431, 1439.)

BMW failed to participate in the meet and confer process in good faith. Although in response to Plaintiff’s initial meet and confer letter dated February 13, 2026, BMW’s counsel engaged in a telephonic conference with Plaintiff’s counsel, BMW’s counsel failed to respond to the meet and confer letters subsequently sent by Plaintiff’s counsel on February 26, 2026 and March 11, 2026. (Faulk Decl., ¶¶ 5, 6, 8, 9.)

BMW is ordered to meet and confer in good faith either telephonically or in-person with Plaintiff to attempt to resolve each issue presente d by Plaintiff’s Motion. No later than 9 court days prior to the continued hearing, the parties are to file a Joint Statement which shall (1) describe the parties’ attempts to meet and confer pursuant to this order, (2) identify each discovery request that remains in dispute, and (3) each party’s position on the discovery request that remains in dispute.

Plaintiff to give notice.

3. MOTION TO COMPEL PRODUCTION

Plaintiff Grigor Sahakyan moves to compel defendant BMW of North America, LLC, to provide further responses to Requests for Production 9, 10, 24, 26, 27 and 32 (Set One), is CONTINUED to 10/13/26 at 9:00 a.m. in Dept. C32.

BMW failed to participate in the meet and confer process in good faith. Although in response to Plaintiff’s initial meet and confer letter dated February 13, 2026, BMW’s counsel engaged in a telephonic conference with Plaintiff’s counsel, BMW’s counsel failed to respond to the meet and confer letters subsequently sent by Plaintiff’s counsel on February 26, 2026 and March 11, 2026. (Faulk Decl., ¶¶ 5, 6, 8, 9.)

BMW is ordered to meet and confer in good faith either telephonically or in-person with Plaintiff to attempt to resolve each issue presente d by Plaintiff’s Motion. No later than 9 court days prior to the continued hearing, the parties are to file a Joint Statement which shall (1) describe the parties’ attempts to meet and confer pursuant to this order, (2) identify each discovery request that remains in dispute, and (3) each party’s position on the discovery request that remains in dispute.

Plaintiff to give notice.

3. REVENUE CORP. VS. CORTEZ 2025-01531657 1. MOTION TO COMPEL ANSWERS TO FORM INTERROGATORIES 2. MOTION TO COMPEL ANSWERS TO SPECIAL INTERROGATORIES 3. MOTION TO COMPEL PRODUCTION 4. MOTION TO COMPELRESPONSE TO REQUESTS FOR ADMISSIONS

Plaintiff Revnue Corp.’s motions to compel defendant John Cortez to provide further responses to Plaintiff’s (1) Special Interrogatories, Set One; (2) Form Interrogatories, Set One; (3) Requests for Admission, Set One; and (4) Requests for Production of Documents, Set One, is COTINUED to 10/6/26 at 9:00 a.m., in Dept. C32.

The Court will rule on Defendants Demurrer first and determine whether this action is subject to abatement or a stay before ruling on the discovery issues which may be mooted by the court’s ruling on the Demurrer.

Plaintiff to give notice.

4. MORRIS VS. ASSA ABLOY ENTRANCE SYSTEMS US, INC. 2025-14998712 MOTION FOR LEAVE TO FILE AMENDED COMPLAINT

Plaintiff Tisa Morris’ Motion for Leave to File a First Complaint is DENIED without prejudice.