SEALES-PERKINS, et al. vs SACRAMENTO CITY COLLEGE, et al.

“Any party may obtain discovery within the scope [of the Civil Discovery Act] by propounding to another party to the action written interrogatories to be answered under oath.” (Code Civ. Proc., § 2030.010, subd. (a).) “An interrogatory may relate to whether another party is making a contention, or to the facts, witnesses, and writings upon which a contention is based.” (Code Civ. Proc., § 2030.010, subd. (b).)

A response to an interrogatory may consist of answers, objections, and/or the election to allow the inspection and copying of records. (Code Civ. Proc., § 2030.210, subd. (a).)

Responses must be “as complete and straightforward as the information reasonably available to the responding party permits.” (Code Civ. Proc., § 2030.220(a).) When an interrogatory cannot be answered completely, it must be answered to the extent possible. (Code Civ. Proc., § 2030.220(b).) Further, if the responding party does not have sufficient personal knowledge to fully respond to an interrogatory, the party may so state, but only after making a reasonable and good faith effort to obtain the information by asking other people and organizations, unless the information is equally available to the propounding party. (Code Civ.

Proc., § 2030.220(c); Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 406.) Responses should include all information that is then available to the responding party. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 782.)

The propounding party may move to compel further responses to interrogatories if they deem that “[a]n answer to a particular interrogatory is evasive or incomplete[,]” and/or “[a]n objection to an interrogatory is without merit or too general.” (Code Civ. Proc., § 2030.300(a).) “If a timely motion to compel [is] filed, the burden is on the responding party to justify any objection or failure to fully answer the interrogatories.” (Weil & Brown, Cal. Practice Guide: Civ. Procedure Before Trial (The Rutter Group 2025

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO 24CV023830: SEALES-PERKINS, et al. vs SACRAMENTO CITY COLLEGE, et al. 06/04/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One in Department 16C

Update) ¶ 8:1179 [citing cases].)

Further, the belated service of responses does not render a motion to compel discovery moot. The moving party is entitled to a ruling once the motion is made. (See Code Civ. Proc., § 1005.5; see also Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 407 [“[S]ection 2030.290 does not preclude the trial court from granting a motion to compel responses under subdivision (b), even if the responding party serves untimely interrogatory responses after the propounding party has served the motion.”].)

Discussion

Defendant moves to compel further responses to SIs Nos. 1, 3, 7-11, 13, and 15-23 because “Plaintiff’s objections are meritless; her responses are evasive and incomplete; Plaintiff improperly ‘re-wrote’ certain interrogatories; and Plaintiff completely failed to respond (and thus waived objections to) several interrogatories.” (Def.’s Not. of Mot. & Mot. 2:8-10.) Defendant further requests monetary sanctions totaling $1,288.00 as reasonable attorney fees incurred in connection with the motion. (Id. at 2:11-14.)

The Court agrees that Plaintiff’s responses to the subject SIs were deficient for each of the reasons stated in Defendant’s Separate Statement filed in support of the motion.

First, the Court finds that Plaintiff’s vague, ambiguous, overly broad, and duplicative objections are without merit and are overruled. (See, e.g., Deyo v. Kilbourne, supra, 84 Cal.App.3d at p. 783 [stating that even “where the question is somewhat ambiguous, but the nature of the information sought is apparent, the proper solution is to provide an appropriate response”].) Plaintiff’s overly burdensome objections are also overruled. Undue burden objections must be accompanied by a specific factual showing setting forth the amount of work necessary to respond to the subject discovery. (West Pico Furniture Co. v. Superior Court (1961) 56 Cal.2d 407, 417-418.) Plaintiff’s opposition lacks any such showing.

Next, the Court agrees that several of Plaintiff’s responses incorrectly state the text of the interrogatories asked. For example, SI No. 8 asks Plaintiff to “State each and every fact in support of YOUR allegation as set forth on page 10 of the Amended Complaint in

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO 24CV023830: SEALES-PERKINS, et al. vs SACRAMENTO CITY COLLEGE, et al. 06/04/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One in Department 16C

this action that Defendants “contribut[ed] to a hostile educational environment.” (Def.’s SIs at p. 2, attached as Ex. 2 to the Murphy Decl. [emphasis added].) Whereas Plaintiff’s response to this SI states the request as: “State each and every fact in support of your allegations set forth on page 10 of the Amended Complaint that Defendants continued to foster a hostile educational environment.” (Pl.’s Resps. to Def.’s SIs at p. 4, attached as Ex. 3 to the Murphy Decl. [emphasis added].) Although a party is not required to repeat the text of an interrogatory in its response thereto (Weil & Brown, Cal.

Practice Guide: Civ. Procedure Before Trial (The Rutter Group 2025 Update) ¶ 8:1044), the Court finds that if a party chooses to do so, it must correctly state the interrogatory. Otherwise, the party’s response to the interrogatory may be evasive and/or not responsive to the interrogatory asked by the moving party.

Also, the Court agrees that several of Plaintiff’s responses to the SIs are evasive and/or incomplete. For example, Defendant asks several contention interrogatories, in which he asks Plaintiff to state each and every fact that supports certain allegations Plaintiff makes in her Amended Complaint. (See, e.g., SI No. 1 [“State each and every fact in support of YOUR . . . allegation as set forth on page 8 of the Amended Complaint in this action that Andre Coleman ‘failed to respond’ to a request for a ‘safety plan.’”]; SI No. 11 [“State each and every fact in support of . . . allegation as set forth on page 10 of the Amended Complaint in this action that Defendants ‘fail[ed] to address legitimate concerns […].’”].)

After stating objections, Plaintiff simply repeats the allegation instead of stating any responsive facts. (See Pl.’s Resp. to SI No. 1 [“Subject to and without waiving objections: Plaintiff alleges that Andre Coleman failed to respond to Plaintiffs request for a safety plan regarding Plaintiffs minor child, Colin P.”]; Pl.’s Resp. to SI No. 11 [“Subject to and without waiving objections: Plaintiff alleges that Defendants failed to address Plaintiffs concerns.”].) Such responses are evasive and unresponsive.

And Plaintiff’s response to SI No. 9, only provides the name of the witnesses she identifies as responsive to the interrogatory, whereas the interrogatory asks for their names, addresses, and telephone numbers. This response is incomplete.

Finally, Plaintiff’s original responses to Defendant’s SIs did not include responses to SIs Nos. 15-23. Accordingly, Plaintiff waived any objections to those interrogatories. Moreover, the fact that Plaintiff later served supplemental responses to these interrogatories does not moot the motion as to SIs Nos. 15-23 because, as stated above, a moving party is entitled to a ruling on a discovery motion once the motion is made.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO 24CV023830: SEALES-PERKINS, et al. vs SACRAMENTO CITY COLLEGE, et al. 06/04/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One in Department 16C

For the stated reasons, Defendant’s motion to compel is granted. Plaintiffs’ responses to SIs Nos. 1, 3, 7-11, 13, and 15-23 are insufficient for the reasons stated in Defendants’ Separate Statement.

Plaintiff shall serve further verified responses, without objections, to SIs Nos. 1, 3, 7-11, 13, and 15-23 no later than June 22, 2026, unless Defendant agrees in writing to a later deadline.

Defendant’s request for monetary sanctions is denied as the Court finds that the imposition of a monetary sanction would be unjust under the circumstances.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.) NOTICE: Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure: To request limited oral argument, on any matter on this calendar, you must call the Law and Motion Oral Argument Request Line at (916) 874-2615 by 4:00 p.m. the Court day before the hearing and advise opposing counsel.

At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings. The Department 16C Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16030877014 and the Zoom Meeting ID is 160 3087 7014.

To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO 24CV023830: SEALES-PERKINS, et al. vs SACRAMENTO CITY COLLEGE, et al. 06/04/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One in Department 16C

ACCEPTED. Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.pdf.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list. Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away.

Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.