Plaintiff’s Motion to Compel Further Responses to Plaintiff’s Request for Production of Documents, Set One
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Cassandra Diaz v. Volkswagen Group of America, Inc.
Hearing date: April 24, 2026
MOTION: Plaintiff’s Motion to Compel Further Responses to Plaintiff’s Request for Production of Documents, Set One (“Motion”) Pursuant to Code of Civil Procedure sections 2031.210, 2031.220, 2031.230, 2031.20; 2031.281, 2031.300, 2031.310 and 128 Cassandra Diaz, (“Plaintiff”) requests the court compel Volkswagen Group of America, Inc. (“Defendant”) serve further verified code-compliant responses to Plaintiff’s Requests for Production of Documents, Set One, Nos 1-74 and produce verifications to all Requests for Production of Documents of Documents 1-74.
BACKGROUND: Plaintiff’s Complaint filed November 19, 2024, alleges statutory violations under the Song-Beverly Act related to her purchase of a new 2022 Volkswagen Jetta (“Vehicle”).
Plaintiff propounded Requests for Production of Documents, Set One (“Requests”) on November 12, 2025. (Vaziri Decl. ¶ 3).
Written responses, asserting objections were served by Defendant on January 6, 2026.
The details of the meet and confer show that Plaintiff has complied with their meet and confer responsibilities and further allowed additional time for Defendant to respond, which further time was neglected by Defendant.
DISCUSSION: A motion to compel further responses to a demand for inspection or production of documents must set forth specific facts showing “good cause” justifying the discovery sought by the demand. (Code Civ. Proc., § 2031.310, subd. (b)(1).)
If the moving party has shown good cause for the production of documents, the burden is on the objecting party to justify the objections. (Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98.)
The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further responses to a demand for inspection or production of documents or a motion to compel compliance with a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make it unjust to impose sanctions. (
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Plaintiff generally argues that good cause exists for the Requests as they regard repair records, internal investigations, warranty policies, repair guidance, and similar defects in vehicles of the same make, model, and year that are relevant to Defendant’s knowledge, repair efficacy, and willfulness under the Song-Beverly Act.
Defendant does not appear to justify their objections and only oppose the Motion as moot.
Defendant claims they have now agreed to provide further responses to the Requests. Objection, pg. 2, line 5-8.
The Motion to Compel Further Responses to Plaintiff’s Request for Production of Documents, Set One is GRANTED.
Defendants’ objections are overruled (and cannot be asserted again in the supplemental responses).
Defendant to provide verified documents responsive to P’s requests within 10 calendar days of the Court’s order.
No sanctions are ordered as there is no request for sanctions in the Motion.
NOTE RE: TENTATIVE RULING This tentative ruling becomes the court’s order, and no hearing shall be held unless one of the parties contests it by complying with Rule 3.1308 of the California Rules of Court and Monterey County Local Rule 7.9.
Those parties wishing to present an oral argument must notify all other parties and the Court no later than 4:00 p.m. on the court day before the hearing; otherwise, NO ORAL ARGUMENT WILL BE PERMITTED, AND THE TENTATIVE RULING WILL BECOME THE ORDER OF THE COURT AND THE HEARING VACATED.
You must notify the court by emailing TentativeRulings@monterey.courts.ca.gov or by telephoning the Calendar Department at (831) 647-5800, extension 3040, before 4:00 p.m. on the court day before the hearing.