Motion to Compel Discovery
25CV111737: CHEN vs WANG, et al. 06/05/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by May Chen (Plaintiff) CRS# 355770694855 in Department 520
Tentative Ruling - 06/05/2026 Jamilah A. Jefferson
The Motion to Compel Discovery (not Further Discovery) - 1 moving party, 1 motion filed by May Chen on 04/14/2026 is Granted in Part.
The unopposed Motion of Plaintiff May Chen (Plaintiff) to Compel (not Further) as to Defendants Meiying Wang and Wei Jiang is GRANTED IN PART. (Code Civ. Proc., §§ 2030.220, subd. (a), 2030.290, subd. (b); 2031.210, subd. (a); 2033.280, subd. (b).) As of the posting of this tentative ruling, there is no opposition filed. The ex-parte application to file an untimely opposition was denied.
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This defamation case was brought by Plaintiff against Defendants Meiying Wang; Meetco International LLC; Wei Jiang and Cheng Jun Fu. On November 7, 2025, Plaintiff propounded by email Form Interrogatories (FROGS), Special Interrogatories (SPROGS), Requests for Admission, and Requests for Production of Documents (RPDs). (Chen Decl. ¶ 2, Exs. 1-2.) Although Plaintiff granted two extensions upon request after the initial due date, no responses have been provided as of the date this Motion was filed. (Id. at ¶¶ 5, 16-17, 21.)
Defendants are ordered to serve Plaintiff with code-compliant responses to Plaintiffs SPROGS, FROGS, and RPDs (Set One) without objection within seven (7) days of the date of this Order.
As to the RFAs, as Defendants have failed to respond altogether, they have not satisfied the requirements set forth in C.C.P. § 2033.280(a)(1) and (2) to permit waiver of objections to them. Accordingly, the RFAs are deemed admitted.
Plaintiff does not identify an amount sought for monetary sanctions - instead, Plaintiff requested a separately noticed hearing on sanctions. The Court does not typically set hearings on sanctions for discovery motions - particularly unopposed motions to compel initial discovery. In light of the Courts order denying Defendants Ex Parte Application to Late File an Opposition, the Court considers that there was a lack of substantial justification in the failure to timely file responses. Thus, sanctions are awarded in the amount of $760 for each motion against Defendants and Defendants counsel jointly and severally, payable to Plaintiff forthwith for a total of $2,280.
Although Plaintiff argued at the hearing that this amount was significantly less than the time spent on each motion, the Court finds this amount to be reasonable for an unopposed motion to compel initial discovery where no responses were 25CV111737: CHEN vs WANG, et al. 06/05/2026 Hearing on Motion to Compel Discovery (not "Further Discovery") filed by May Chen (Plaintiff) CRS# 355770694855 in Department 520 served prior to the motion filing.
NOTICE TO DEFENDANTS: Defendants are advised that failure to comply with this Order may result in the imposition of future sanctions, including evidentiary, monetary, or terminating sanctions.
NOTICE: This tentative ruling will automatically become the courts final order on June 4, 2026 unless, by no later than 4:00 P.M. on June 3, 2026, a party to the action notifies BOTH: 1) the court by emailing Dept520@alameda.courts.ca.gov; AND 2) all opposing counsel or selfrepresented parties (by telephone or email) that the party is contesting this tentative ruling.
The subject line (RE:) of the email must state: Request for CONTESTED HEARING: [the case name], [number]. When a party emails to contest a tentative ruling, the party must identify the specific holding(s) within the ruling they wish to contest via oral argument.
The court does not provide court reporters for hearings in civil departments. A party who wants a record of the proceedings must engage a private court reporter. (Local Rule 3.95.) Any privately retained court reporter must also participate via video conference. His/Her email must be provided to the court at the time the Notice of Contest is emailed.
ALL CONTESTED LAW AND MOTION HEARINGS ARE CONDUCTED VIA REMOTE VIDEO unless an in person appearance is required by the court. Invitations to participate in the video proceeding will be sent by the court upon receipt of timely notice of contest. A party may give email notice he/she will appear in court in person for the hearing, however all other counsel/parties and the JUDGE MAY APPEAR REMOTELY.
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