Motion to Compel Production of Documents Withheld on Grounds of Attorney-Client Privilege; Motion for Monetary Sanctions
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 24CV084829: DEEPROUTE.AI, LTD. vs RENCO PROPERTIES, INC., et al. 06/03/2026 Hearing on Motion to Compel Production of Documents Withheld on Grounds of Attorney-Client Privilege; filed by Deeproute.ai, LTD. (Plaintiff) CRS# 111371404624 in Department 17 Tentative Ruling - 06/01/2026 Chad A. Stegeman The Motion to Compel PLAINTIFF’S AMENDED NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS WITHHELD ON GROUNDS OF ATTORNEY- CLIENT PRIVILEGE; MEMORANDUM OF POINTS AND AUTHORITIES filed by Deeproute.ai, LTD. on 04/14/2026 is Granted in Part.
The Motion of Plaintiff Deeproute.AI Ltd (Plaintiff) to Compel Production of Documents Withheld on Grounds of Attorney-Client Privilege and Monetary Sanctions is GRANTED IN PART. DISCUSSION The Motion concerns (1) native files ordered to be produced in the Courts February 5, 2026 Order granting in part Plaintiffs Motion to Compel Compliance as to RFPs; and (2) documents and communications between Defendants and former counsel Peter Rehon that have been withheld based on objections related to attorney-client privilege.
The Motion is GRANTED as to the native files as well as original emails for RENCO_001496- 001532, RENCO_001559-001581, RENCO_001606-001608, RENCO_001905-001908, RENCO_003073-003074, RENCO_003111-003120, RENCO_003147, and RENCO_003371- 003377. In Defendants counsels supporting declaration, counsel states that he is informed and believe[s] that at least a portion of the emails for only Renco_001496-001520 have been previously produced, which suggests that not all of the files Plaintiff identifies have been provided. (Rossi Decl., ¶ 3; Oppo., p. 4:24-25.)
As for the latter subject matter of the Motion, the Court is unable to consider the merits of Plaintiffs arguments without the production of a privilege log. If any documents broadly responsive to the requests for production are being withheld on the basis of privilege, a privilege log is required. To be clear, documents must first be responsive to a request, then the assertion of privilege requires a detailed privilege log. Conversely, the assertion of privilege requires the assumption that a determination has been made that documents are responsive.
With this in mind, contrary to Defendants assertion, a privilege log is not optional if Defendants are asserting that they cannot produce communications with their (former) attorney that are plainly confidential. (Oppo., p. 9:2-12.) A blanket assertion of privilege over responsive documents is not allowed. The privilege log shall provide the identity and capacity of all individuals who authored, sent, or received the allegedly privileged document, the document’s date, a brief description of the document and its contents or subject matter sufficient to determine whether the privilege applies, and the precise privilege or protection asserted. (Catalina Island Yacht Club (2015) 242 Cal.App.4th 1116, 1130.)
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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 24CV084829: DEEPROUTE.AI, LTD. vs RENCO PROPERTIES, INC., et al. 06/03/2026 Hearing on Motion to Compel Production of Documents Withheld on Grounds of Attorney-Client Privilege; filed by Deeproute.ai, LTD. (Plaintiff) CRS# 111371404624 in Department 17 privilege log by no later than June 17, 2026. (CCP § 2031.240(c).) As to the matter of sanctions, some measure of sanctions is merited here to compensate Plaintiff for having to bring this motion to compel, and the Court does not find substantial justification for Defendants failure to produce native files ordered to be disclosed previously.
Accordingly, monetary sanctions in the amount $2,060 are awarded to cover the reasonable cost of bringing the motion and the filing fee associated therewith. The sanctions will be paid within 10 days of this order. The cross-request for sanctions is denied. The parties and Court will discuss whether a discovery referee should be appointed at the next conference with the court, and the parties shall outline their position on this matter in their conference statements.
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