Motion to compel further responses to form interrogatories; Motion to compel further responses to requests for production
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SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 10 Honorable Jeffrey B. El-Hajj Blanca Than, Courtroom Clerk 191 North First Street, San Jose, CA 95113 Telephone: 408-882-2210
DATE: June 4, 2026 TIME: 9:00 A.M. / 9:01 A.M. To contest the ruling, call (408) 808-6856 before 4:00 P.M. Make sure to let the other side know before 4:00 P.M. that you plan to contest the ruling. (Cal. Rules of Court, rule 3.1308(a)(1); Local Rule 8.D.)
**Please specify the issue to be contested when calling the Court and counsel**
Line 5 25CV460436 Fang Xia v. Park Click LINE 5 or scroll down for ruling. Townsend Homeowners Association Line 6 25CV460436 Fang Xia v. Park Click LINE 5 or scroll down for ruling. Townsend Homeowners Association Line 7 25CV467350 Martin Willerford v. Click LINE 7 or scroll down for ruling. Ford Motor Company et al.
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9:01 A.M. LINE # CASE # CASE TITLE RULING Line 1 24CV433661 LVNV Funding, LLC v. Claim of exemption by judgment debtor Mein Nguyen related to Mein Nguyen wage garnishment. Notice is proper, and the judgment debtor has the burden of proof. The claim is DENIED IN PART and GRANTED IN PART. Judgment debtor’s financial statement shows sufficient non-exempt funds to withhold the judgment debtor’s proposed withholding of $164.35 per month. Judgment creditor to submit proposed order.
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Calendar Lines 5-6 Case Name: Fang Xia v. Park Townsend Homeowners Association Case No.: 25CV460436
At issue are two motions to compel filed by plaintiff Fang Xia: a motion to compel further responses to form interrogatories, set one; and a motion to compel further responses to requests for production, set one. Notice is proper and the motions are opposed by defendant Park Townsend Homeowners Association. The case involves a dispute over liability for damage to commercial property as a result of a water leak from a burst pipe.
Motion to Compel Further Responses to Form Interrogatories, Set One
Plaintiff moved to compel further responses to form interrogatory No. 15.1(A) and (C), which request facts and documents supporting “each denial of a material allegation and each special or affirmative defense.” (Code Civ. Proc., § 2030.300
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Motion to Compel Further Responses to Requests For Production, Set One
Plaintiff moved to compel further responses to requests for production, set one, Nos. 1 through 36. (Code Civ. Proc., § 2031.310.) Defendant has since supplemented its responses to those requests for production. The court finds the majority of defendant’s responses are now code-compliant. Plaintiff’s reply argues defendant’s responses are deficient as to the following items responsive to request Nos. 8 through 21: copies of work orders, proposals, and estimates from contractors. (Reply at 4:19-21.)
A supplemental declaration by plaintiff’s counsel includes excerpts from e-mail messages apparently produced by defendant in response to the requests for production. One refers to a reconstruction/build back proposal attached to the email, but no proposal was apparently provided to plaintiff. (Jiang dec., 5/27/26, exh. 10.) To the extent defendant has that and other responsive attachments to e-mail messages, those must be produced. The court acknowledges defendant’s contention in its supplemental response that it produced all responsive documents in its possession and that other documents may be in the possession of Grayson Community Management.
The court also notes defendant indicated a willingness to subpoena Grayson for any responsive records to facilitate discovery.
The motion to compel is GRANTED IN PART as follows. As to RFP Nos. 8 through 21, defendant must produce any copies in its possession of responsive work orders, proposals, and estimates from contractors. Defendant must further subpoena Grayson Community Management for responsive records, and must produce those records to plaintiff upon receipt.
The parties’ requests for discovery sanctions related to this motion are DENIED.
Order to Submit Other Pending Discovery Disputes to a Discovery Facilitator
The parties have reserved at least seven additional discovery-related motion hearings. The parties are ordered to submit those and all other pending discovery disputes to a discovery facilitator through the Santa Clara County Superior Court Discovery Facilitator Program. 11
(https://santaclara.courts.ca.gov/divisions/civil-division/civil-adr-providers/discoveryfacilitator-program) A stipulation regarding the parties’ agreement to participate in that program must be filed no later than July 1, 2026. The court will consider the parties’ good faith participation (or lack thereof) in that process in determining whether to grant discovery sanctions, if those motions are not resolved informally.
The court will prepare the order.
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