RAMIREZ vs ROSS STORES, INC.

25CV154861: RAMIREZ vs ROSS STORES, INC. 05/28/2026 Hearing on Motion to Compel Further Discovery Responses CRS# 235914266680 in Department 512

Tentative Ruling - 05/27/2026 Jenna Whitman

The Motion to Compel Further Discovery Responses filed by ROSS STORES, INC. on 04/21/2026 is Granted in Part.

This Tentative Ruling addresses defendant Ross Dress for Less, Inc. (“Defendant”) Motions to Compel plaintiff’ Mary Ramirez’s (“Plaintiff”) Further Responses to Special Interrogatories (“SROG”) No. 47 and 48 and For Monetary Sanctions; and (2) Further Responses to Requests for Production of Documents (“RFPD”) Nos. 20 and 24 and for Monetary Sanctions

ANALYSIS OF MOTION TO COMPEL FURTHER RESPONSES TO SROG

The Court GRANTS IN PART Defendant’s Motion to Compel Further Responses to SROG.

The Court ORDERS Plaintiff to serve a verified Further Response No. 48 no later than 3:00 p.m. on Friday, 6/04/2026. Plaintiff’s Second Further Response is incomplete in that it does not contain addresses and telephone numbers as requested. Plaintiff’s Further Response shall provide business addresses and telephone numbers for the medical providers named in Plaintiff’s Second Further Responses.

Plaintiff has not demonstrated that her position is substantially justified. The Court ORDERS Plaintiff to pay Defendant a monetary sanction in the reasonable amount of $1,000 on the Motion to Compel Further SROG Responses. This amount is reasonable, considering the scope and issues involved in the motion. Further, the Court considers that Defendant’s moving declaration was unnecessarily voluminous, covering matters that are not relevant to the present Motion to Compel. This work is not compensable and unnecessarily burdens the Court. Further, the moving Wohlfeil Declaration at ¶ 19 admits Defendant rushed to file this Motion to Compel even after Plaintiff had agreed to provide Further Responses by 4/24/2026. The Court nonetheless awards sanctions because one of Plaintiff’s Second Further Responses is still not fully responsive.

ANALYSIS OF MOTION TO COMPEL FURTHER RESPONSES TO RFPD

The Court GRANTS IN PART Defendant’s Motion to Compel Plaintiff’s Further Responses to RFPD Nos. 20 and 24.

The Court ORDERS Plaintiff no later than 3:00 p.m. on 6/5/2026 to provide Defendant with Plaintiff’s cell phone number at the time of the incident so that Defendant may seek to subpoena those records directly from Verizon Wireless, if Defendant wishes to do so. The Court otherwise DENIES Defendant’s request for a further Response to RFPD No.

20. Defense counsel has not explained why they cannot themselves determine the appropriate address for service of subpoenas regarding the telephone records of Verizon’s California customers. 25CV154861: RAMIREZ vs ROSS STORES, INC. 05/28/2026 Hearing on Motion to Compel Further Discovery Responses CRS# 235914266680 in Department 512

The Court DENIES Defendant’s Request for a Further Response to RFPD No.

24. The Court finds Plaintiff’s second further response adequate.

The Court ORDERS Plaintiff to pay Defendant a monetary sanction of $1,500 on the Motion to Compel Further RFPD Responses, as a reasonable sanction under the circumstances.

The moving Wohfeil Declaration at ¶ 18 evidences that Plaintiff refused to provide further responses to the RFPD based on Plaintiff’s objections until this Motion to Compel was filed.

CONTESTING TENTATIVE RULINGS

PLEASE NOTE: If any party contests the tentative ruling, the hearing on the motion will occur remotely via the court's own video-conferencing system.

Pursuant to California Rule of Court 3.1308, subdivision (a)(1), this tentative ruling will become the order of the Court unless it is contested before 4:00 PM on the court day preceding the noticed hearing date.

To contest a tentative ruling, a party should do the following:

First, the party must notify Department 512, by email at Dept512@alameda.courts.ca.gov and copy all counsel of record and self-represented parties. The contesting party must state in the subject line of the email the case name, case number and motion.

Second, the party shall log into the eCourt Public Portal, search for this case (e.g., by case number), select the case name, select the "Tentative Rulings" tab, click the "Click to Contest this Ruling" button, enter the party's name and a brief statement of the party's reason for contesting the tentative, and click "Proceed."

Parties may appear via videoconference, using the Zoom.com website or application.

TO CONNECT TO ZOOM:

Join the meeting using the following link: https://www.zoomgov.com/j/16057661931 Join the meeting by Phone:

Meeting ID: 160 5766 1931

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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV154861: RAMIREZ vs ROSS STORES, INC. 05/28/2026 Hearing on Motion to Compel Further Discovery Responses CRS# 235914266680 in Department 512