Adams vs. Colliers International Group, Inc.

# Case Name Tentative 1 25-01453685 1) Motion to Appear Pro Hac Vice 2) Motion to Compel Production Adams vs. Colliers International Group, Plaintiffs Irene Adams and West Palmyra Ltd.’s motion to compel Inc. Defendant Colliers International Group Inc. to serve further responses to Plaintiffs’ Requests for Production of Documents, Set One, and to produce all responsive, non-privileged documents is CONTINUED to ________.

Plaintiffs seek to compel a further response to Request Nos. 1-82.

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.) “The level of effort at informal resolution which satisfies the ‘reasonable and good faith attempt’ standard depends upon the circumstances. In a larger, more complex discovery context, a greater effort at informal resolution may be warranted. In a simpler, or more narrowly focused case, a more modest effort may suffice.” (Obregon v. Superior Court (1998) 67 Cal.App.4th 424, 431.)

Despite efforts by Plaintiff to meet and confer, Defendant failed to meaningfully meet and confer with Plaintiff. Plaintiff has shown on December 18, 2025, Plaintiffs’ counsel sent a meet and confer letter to Defendant’s counsel of record, Larissa G. Nefulda. (Dardashti Decl., ¶ 7, Ex. C.) Plaintiffs’ counsel did not receive a response, and on December 30, 2025, Plaintiffs’ counsel forwarded the email to Kristian Nelson also representing Defendant. (Dardashti Decl., ¶ 8.) On December 31, 2025, Nelson responded to Plaintiffs’ counsel’s email and requested search terms and custodians to search for responsive documents which Plaintiffs’ counsel provided the same day. (Dardashti Decl., ¶¶ 9-10.)

Plaintiff’s counsel’s sent follow-up emails in an effort to continue to meet and confer on February 2, February 6, and February 17, 2026. (Dardashti Decl., ¶¶ 12-14.) On February 27, 2026, Defendant’s counsel finally responded to Plaintiffs’ counsel’s emails stating that “Our client has searched the custodians you provided and the amount of data is over a TB.” (Dardashti Decl., ¶ 15, Ex. I.) Defendant’s counsel did not provide any proposal or timeline for production of responsive documents or supplemental responses.

Although Defendant’s sent a meet and confer letter regarding its demurrer, Defendant’s counsel did not at any point respond to Plaintiffs’ meet and confer letter dated December 18, 2025, other than to discuss search terms and custodians.

Although Defendant did not sufficiently meet and confer, it has shown it has been working on collecting responsive documents. Defendant contends that the total universe of electronic communications potentially responsive to Plaintiff’s Requests encompasses over 2,370,000

documents and the delay in production has been due to the fact that Defendant has had to dedicate substantial time and resources to figuring out how to efficiently and cost-effectively review and produce these documents. (Levine Decl., ¶ 4.) Defendant states it is working with a vendor and has narrowed the pool of possible responsive documents to 213,000. (Levine Decl., ¶ 7.) Defendant has now produced 3,809 documents and intends to continue to produce documents on a rolling basis with an additional production planned for Thursday, May 14, 2026. (Opp., 4:19-21.) Since Defendant is producing documents on a rolling basis it is unclear which of the 82 requests remain in dispute.

Since Defendant has shown it is working towards producing responsive documents, the court finds further conferences between counsel would be productive. Therefore, the parties are ordered to engage in additional attempts to meet and confer regarding the issues that remain in dispute, including a telephonic or in-person conference (not email). 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.

MOTION NO. 2: The Application of Shamoor Anis to Appear Pro Hac Vice for defendants Brent Smith and Millrock Investment Fund 1, LLC is GRANTED.

Moving attorney has satisfied all the requirements of California Rules of Court, Rule 9.40.

Moving attorney to give notice. 2 24-01401853 Motion to Compel Further Responses to Form Interrogatories

Anderson vs. Upward Defendants Richard Upward, Shirlene Upward and Katherine Mojarro’s Motion to Compel Further Responses to Form Interrogatories, and Request for Monetary Sanctions is DENIED.

A party may move to compel further responses to interrogatories where the party deems the responses are evasive or incomplete, an exercise of the option to produce documents is unwarranted or the required specification of those documents is inadequate, and/or an objection in the response is without merit or too general. (Code Civ. Proc. § 2030.300(a); see Best Products, Inc. v. Sup.Ct. (Granatelli Motorsports, Inc.) (2004) 119 Cal.App.4th 1181, 1189-90 [motion to compel proper to challenge “boilerplate” responses].)

The motion must be served within 45 days after verified responses or any verified supplemental responses are served, unless the parties agree in writing to extend the time. (Code Civ. Proc., § 2030.300, subd. (c).) The motion must be accompanied by a separate statement (Cal. Rules of Court, rule 3.1345(c).) The motion must also be accompanied by a