FERDINAND CAHAYAG VS. CASA FLYNN LLC ET AL

Set for Law and Motion/Discovery Calendar on Monday, June 01, 2026, Line 6. 3 - Plaintiff Ferdinand Cahayag's unopposed Motion To Compel Further Production Of Document Responses (Set One) To Defendant 35 Casa Way LLC, And Request For Monetary Sanctions is GRANTED IN PART AND DENIED IN PART.

The motion is granted as to RFP nos. 1, 2, 5, 25, 26, 27, 30, 31, 33, 34, 35, 40, 41, 42, 43. Further responses within 20 days of notice of this order. The motion is denied as to RFP nos. 12, 15, 16, 17, 32, 38 & 39. As to these requests, the motion is based on a misreading and misunderstanding of the Civil Discovery Act.

ALL PARTIES ARE ORDERED TO MEET AND CONFER REGARDING APPOINTMENT OF A DISCOVERY REFEREE.

The parties are advised stacked motions are disfavored and, most often, improper. Parties generally may not stack separate motions into a single filing; instead, each distinct motion should typically be presented in a separate, properly captioned document. (See Weil & Brown et al., Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2024) 9:24.3.) ["Each motion or demurrer should normally be set forth in a separate document."].) This rule applies equally to discovery motions. This means generally a separate motion per discovery vehicle addressed to a particular individual.

Distinct motions preserve clarity for both opposing parties and the court. Distinct motions, as well, allow the court to manage its resources (e.g., staggering or deferring motions), which is a compelling interest in oversubscribed courts such as this one. Yes, sometimes a stacked motion is appropriate because the issues are closely related, and clarity is preserved. But counsel and parties must use reasonable judgment, recognizing stacked motions are the exception, not the rule. Going forward, improperly stacked motions, like this one, will be taken off calendar.

The court does not find that Defendant 35 Casa Way LLC's actions in connection with this discovery were substantially justified. Defendant 35 Casa Way LLC shall pay to Plaintiff Ferdinand Cahayag $2,260 in sanctions, payable by June 15, 2026. (See Code of Civil Procedure sections 2023.010, 2023.030, 2031.310(h).) To the extent Plaintiff seeks different or additional relief, the motion is denied. Prior to the time set for hearing, Plaintiff shall lodge by email to contestdept302tr@sftc.org a proposed order containing the above text verbatim.

For the 9:00 a.m. calendar, all attorneys and parties may appear in Department 302 remotely or in person. Remote hearings will be conducted by videoconference using Zoom. (Dept. 302 Zoom ID 160 409 7690; Passcode 516287.) To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing.