JOSEPH SIGUIG VS. WEHOPE

September 8, 2026 Law and Motion Calendar PAGE 18 Judge: HONORABLE NANCY L. FINEMAN, Department 04 ________________________________________________________________________

2:00 PM LINE 7 25-CIV-09945 JOSEPH SIGUIG VS. WEHOPE

JOSEPH SIGUIG JASON M ERLICH WEHOPE

PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES (GENERAL AND EMPLOYMENT); REQUEST FOR SANCTIONS

TENTATIVE RULING:

Plaintiff Joseph Siquig’s Motion to Compel Further Responses to Form Interrogatories (General and Employment) is ruled upon as follows:

On December 19 2025, Plaintiff filed his complaint. Thereafter on March 21, 2026, Plaintiff propounded Form Interrogatories (General), Set One, and Form Interrogatories (Employment), Set One. (Lacques Decl., ¶2, Exhs. 1, 2.)

Defendant WeHope, Inc. served its initial responses to both sets of Form Interrogatories on May 2, 2026. (Id., at ¶3, Exhs. 3, 4.) The parties met and conferred by email regarding the discovery responses after Plaintiff determined that responses to General Form Interrogatories Nos. 4.1, 12.2, 12.3, 13.1, and 13.2 and Employment Form Interrogatories Nos. 200.4, 209.2, 211.1, and 214.1 were insufficient, and Defendant through counsel agreed to provide amended responses to only Employment Form Interrogatories Nos. 211.1 and 214.1 by May 19, 2026 and extend the deadline to file a motion to compel from the statutory deadline to July 8, 2026.. (Id., at ¶¶3-8.) Defendant served supplemental responses on May 19, 2026. (Id., at ¶10, Exh. 8.)

As an initial matter, the Court notes that defendant WeHope, Inc. has not yet filed a responsive pleading in the action. A plaintiff may propound interrogatories to a party without leave of court, however, at any time that is ten days after the service of the summons on, or appearance by, that party, whichever occurs first.” (Code Civ. Proc., § 2030.020, subd. (b).) Plaintiff was therefore entitled to propound interrogatories, and the present Motion is authorized. Plaintiff filed a Proof of Service by substitute service of the amended Summons and Complaint on March 6, 2026, and Defendant has not moved to quash that service.

Additionally, Defendant served initial and amended discovery responses to Plaintiff’s propounded discovery which did not include objections to the court’s jurisdiction and did include substantive responses. (Lacques Decl., ¶¶3, 10-11.) This participation in the merits of the action recognizes the court’s authority and independently amounts to a general appearance. (See, e.g. Roy v. Superior Court (2005) 127 Cal.App.4th 337, 341, citing Creed v. Schultz (1983) 148 Cal.App.3d 733, 740.) The Court therefore has personal jurisdiction over Defendant WeHope, Inc.

Plaintiff’s Reply brief references an Opposition, but that Opposition is not in the court file. Instead, on August 18, 2026, the court clerk rejected the filing because there had not been a first

September 8, 2026 Law and Motion Calendar PAGE 19 Judge: HONORABLE NANCY L. FINEMAN, Department 04 ________________________________________________________________________ appearance fee paid. However, defendant provided a courtesy copy to Department 4, which the court has reviewed.

Based upon the court’s review of the pleadings, the court concludes that the parties have not had sufficient meet-and-confer regarding the discovery disputes. Defendant raises legitimate objections to the form interrogatories regarding the scope of the definitions. While generally, when a defendant thinks a term, like “incident” is vague and ambiguous or unintelligible, the proper procedure is to object and respond as best as the responding party can. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783 [“Indeed, where the question is somewhat ambiguous, but the nature of the information sought is apparent, the proper solution is to provide an appropriate response.”].) However, in this case, it appears due to the number of potentially adverse actions, the scope of the interrogatories should have been worked out through meaningful meet-andconfer.

The court reminds the parties that, “The statute requires that there be a serious effort at negotiation and informal resolution. . . . Argument is not the same as informal negotiation; that attempting informal resolution means more than the mere attempt by the discovery proponent to persuade the objector of the error of his [or her] ways; and that a reasonable and good faith attempt at informal resolution entails something more than bickering with opposing counsel. Rather, the law requires that counsel attempt to talk the matter over, compare their views, consult, and deliberate.” (Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1294 (cleaned up); Obregon v. Superior Court (1998) 67 Cal.App.4th 424.)

The court finds that the meet-and-confer in this case was insufficient. Simply sending meet-andconfer letters is not meaningful. Especially early in the case, as is the case here, counsel need to talk via Zoom or the telephone. Otherwise, the parties’ default is simply to file motions to compel and request sanctions—here Plaintiff is seeking $13,860.00 in sanctions for issues that should have been resolved during meaningful meet-and-confer.

Accordingly, the court defers ruling on the motion and orders the parties to have meet-and-confer in person or by Zoom by September 24, 2026 to see if they can resolve their differences. They shall email to Department 4 in a joint letter the result of their meet-and-confer, including any unresolved issues by October 1, 2026. If there are any unresolved issues then the parties shall personally appear for an informal discovery conference (IDC) with Judge Fineman on October 6, 2026 at 10:30 a.m. at the Hall of Justice, 400 County Center, Courtroom 4C, Redwood City, CA 94063. The parties shall meet-and-confer in person at the courthouse beginning at 9:00 a.m. on October 6, 2026 prior to the conference with Judge Fineman. If there are issues remaining after the IDC, the court will set a hearing date, allow supplemental briefing, and then the court will rule on this motion to compel.

If the tentative ruling is uncontested, it shall become the order of the court. Thereafter, counsel for Plaintiff shall prepare a written order consistent with the court’s ruling for the court’s signature, pursuant to California Rules of Court, rule 3.1312, and provide written notice of the ruling to all parties who have appeared in the action, as required by law and the California Rules of Court.