DYAL vs MIRANDA, et al.

Later that month, after meeting and conferring on what Dyal considered deficient responses (see id. ¶¶ 7–12), Dyal moved (1) to compel further responses from Pauline to form interrogatories 24CV104059: DYAL vs MIRANDA, et al. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Navkiran Dyal (Plaintiff) CRS# 301642661998 in Department 16 2.11 through 2.13, 6.1 through 6.7, 8.3 through 8.8, 12.1 through 12.7, 13.2, 14.1, 14.2, 15.1, 16.1 through 16.3, 17.1, and 50.1; special interrogatories 1, 8, 11, 13, 15, 17, 21, 24, 28, and 31; and admission requests 4 through 10, 12 through 17, 19 through 35; (2) to compel further responses from Marian to form interrogatories 2.11 through 2.13, 6.1 through 6.7, 8.3 through 8.8, 9.1, 9.2, 12.1 through 12.7, 13.2, 14.1, 14.2, 15.1, 16.1 through 16.3, 17.1, and 50.1; special interrogatories 1, 8, 10 11, 13 through 15, 17, 18, 20 through 24, 28 through 30, 32 through 35; and admission requests 4, 5, 8 through 10, 12, 13 through 17, 19 through 24, and 26 through 35; and (3) for a $4,140.00 sanction upon the Mirandas and their counsel. (Mot., Apr. 21, 2026; see also Mem.

Supp. Mot. 13:12–13, Apr. 21, 2026 (identifying amount of requested sanction).)

A few days after filing their Motion, Dyal filed a First Amended Complaint. (See 1st Am. Compl., Apr. 27, 2026.)

The Mirandas opposed the Motion. (Mem. Opp’n Mot., May 26, 2026.)

II.

Legal Standard

An asking party may move to compel further responses to an interrogatory if they deem that “[a]n answer to a particular interrogatory is evasive or incomplete,” “[a]n exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate,” or “[a]n objection to an interrogatory is without merit or too general.” (Cal. Civ. Proc. Code § 2030.300(a)(1)–(3).) Similarly, a requesting party may move to compel further responses if they deem that “[a]n answer to a particular request is evasive or incomplete” or “[a]n objection to a particular request is without merit or too general.” (§ 2033.290(a)(1), (2).)

In both situations, the court must impose a monetary sanction unless it finds that the subject to be sanctioned acted with “substantial justification” or “other circumstances” make the sanction unjust. (Accord § 2030.300(d); § 2033.290(d).)

III.

Discussion

The Court partly grants the Motion and orders the Mirandas to further respond to the form interrogatories, special interrogatories, and admission requests. The Court also partly grants Dyal’s request for sanctions and denies the Mirandas’s cross-request for sanctions.

The Court separates its discussion of Pauline and Marian’s responses to the interrogatories, admission requests, and sanctions to the greatest practical extent for clarity.2

A. Interrogatories The Court finds that Pauline’s responses to form interrogatories 2.11, 2.12, 2.13, 6.1 through 6.7, 8.3 through 8.8,12.1 through 12.7, 14.1, 14.2, 15.1, 16.1through 16.3, 17.1, and 50.1 are incomplete. Similarly, the Court finds that Marian’s responses to form interrogatories 2.11 through 2.13, 6.1 through 6.7, 8.3 through 8.8, 9.1, 9.2, 12.1 through 12.7, 14.1, 14.2, 15.1, 16.1

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV104059: DYAL vs MIRANDA, et al. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Navkiran Dyal (Plaintiff) CRS# 301642661998 in Department 16 through 16.3, 17.1, and 50.1 are incomplete. To these, the Mirandas take issue with the definition of “incident.” (See, e.g., Defs.’ Separate Stmt. Opp’n Mot. 7:5–10, May 26, 2026 (“[I]t is impossible to respond properly to this interrogatory as there are no dates or incidents specified in the complaint as to this responding party.”).)

In its general form interrogatories, the Judicial Council defined “incident” as “includ[ing] the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” (See Jud. Council of Cal., Form Interrogs.—Gen. § 4(a)(1).) Read together with the Complaint, the definition is not so ambiguous as to render it “impossible” to respond. But even if the Mirandas believed the definition was not as informative as they would have liked, they still had a duty to answer each interrogatory as completely and directly as reasonably possible. (Cal.

Civ. Proc. § 2030.220(a), (b).) Here, the Mirandas responses fell short of their obligations; and accordingly, their responses are incomplete.

The Court was unpersuaded by the Mirandas’s argument that they could not completely and directly respond to the interrogatories as Dyal’s Complaint was inadequate; and that this Motion is moot as Dyal has filed a First Amended Complaint since they responded. The Mirandas did not provide any legal authority to support their arguments. (See Opp’n Mem. 1:8–27.) Further, their arguments miss the point of discovery. The Civil Discovery Act’s definition of relevance is not necessarily tied to the operative pleading, rather it is tied to the “subject matter involved in the pending action.” (Cal.

Civ. Proc. Code § 2017.010.) Here, Dyal’s initial Complaint adequately defined the “subject matter” of this action for the purposes of discovery. (See supra § I (laying out the subject matter of this action).) Accordingly, the Mirandas should have completely and directly responded to the interrogatories even if they disputed the adequacy of the Complaint.

The Court also finds that the Mirandas’s responses to form interrogatory 13.2 are evasive. To this interrogatory, the Mirandas simply responded: “Irrelevant.” The Mirandas must completely and directly answer this interrogatory asking for a written report concerning surveillance of an individual involved in the incident.

*** The Court finds that Pauline’s responses to special interrogatories 1, 8, 11, 13, 15, 17, 21, 24, 28, and 31 are incomplete. Similarly, the Court finds that Marian’s responses to special interrogatories 1, 8, 10 11, 13 through 15, 17, 18, 20 through 24, 28 through 30, 32 through 35 are incomplete. As discussed above, the Mirandas had a duty to completely and directly answer each interrogatory. Reviewing the pleadings and the text of the interrogatories, the Court notes that none are so ambiguous, vague, or unintelligible as to preclude them from reasonably responding.

B. Admission Requests The Court finds that the Pauline’s responses to admission requests 4 through 10, 12 through 17, 19 through 35 are evasive. Similarly, the Court finds that Marian’s responses to admission

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV104059: DYAL vs MIRANDA, et al. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Navkiran Dyal (Plaintiff) CRS# 301642661998 in Department 16 requests 4, 5, 8 through 10, 12, 13 through 17, 19 through 24, and 26 through 35 are evasive.3 Reviewing the pleadings and the text of the requests, the Mirandas’s responses are not as complete and direct as reasonably possible. (See § 2033.220(a) (“Each answer in a response to requests for admission shall be as complete and straightforward as the information reasonably available to the responding party permits.”).)

C. Monetary Sanctions The Court finds that a $1,660.00 sanction against the Mirandas and their counsel is appropriate as they acted without substantial justification in breaching their obligations under the Civil Discovery Act to answer each interrogatory and request as completely and directly as reasonably possible. Additionally, the Court noted unnecessary ad hominem attacks in their filings, further showing that the Mirandas acted without substantial justification in opposing this Motion. (See, e.g., Defs.’ Separate Stmt. Opp’n Mot. 23:10–12 (“Again this illustrates that the plaintiff is mindlessly propounding irrelevant discovery and does not bother to read her own motion.”).) This sanction represents four hours of work at $400.00 an hour, plus the $60.00 filing fee.

IV. Orders The Motion is granted in part.

The Court denies the Mirandas’ cross-request for sanctions.

Pauline must serve further verified responses to form interrogatories 2.11, 2.12, 2.13, 6.1 through 6.7, 8.3 through 8.8,12.1 through 12.7, 13.2, 14.1, 14.2, 15.1, 16.1through 16.3, 17.1, and 50.1, without further objection.

Pauline must serve further verified responses to special interrogatories 1, 8, 11, 13, 15, 17, 21, 24, 28, and 31, without further objection.

Pauline must serve further verified responses to admission requests 4 through 10, 12 through 17, 19 through 35, without further objection.

Marian must serve further verified responses to form interrogatories 2.11 through 2.13, 6.1 through 6.7, 8.3 through 8.8, 9.1, 9.2, 12.1 through 12.7, 13.2, 14.1, 14.2, 15.1, 16.1 through 16.3, 17.1, and 50.1, without further objection.

Marian must serve further verified responses to special interrogatories 1, 8, 10 11, 13 through 15, 17, 18, 20 through 24, 28 through 30, 32 through 35, without further objection.

Marian must serve further verified responses to admission requests 4, 5, 8 through 10, 12, 13 through 17, 19 through 24, and 26 through 35, without further objection.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV104059: DYAL vs MIRANDA, et al. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Navkiran Dyal (Plaintiff) CRS# 301642661998 in Department 16 The Mirandas must serve their further verified responses no later than 20 days after Dyal serves notice of entry of this order.

The Court imposes a $1,660.00 sanction upon the Mirandas and their counsel, jointly, payable to Abraham & Gautam, LLP no later than 20 days after Dyal serves notice of entry of this order. 1 As the Mirandas share a last name, the Court refers to them individually by their first

name for clarity. The Court intends no disrespect. 2 The Court found the Mirandas’s claim of “prejudice” and “chaos” unfounded. (See

Opp’n Mem. 6:3–11.) Given the similarity of the interrogatories and the admission requests and the similarity of Pauline’s and Marian’s responses, the Court found no issue with Dyal’s decision to combine these issues in a single Motion. 3 While Dyal seemingly requested a further response to admission request 1 in their

moving papers, in the separate statement they wrote: “Plaintiff does not challenge [admission request] 1 to Marian Miranda and withdraws any request to compel further response to it.” (Defs.’ Separate Stmt. Opp’n Mot. 122:7–9, May 26, 2026.) Accordingly, the Court does not address this admission request.

***

The Motion to Compel Further Discovery Responses filed by Navkiran Dyal on 04/21/2026 is Granted in Part.

The Court orders sanctions against the Mirandas and their counsel, jointly, in the sum of $1,660.00 payable to Abraham & Gautam, LLP by no later than 20 days after Dyal serves notice of entry of this order.

Gautam Jagannath (Attorney) representing Navkiran Dyal (Plaintiff) must forthwith serve a copy of this order on all counsel of record and self-represented parties, and file proof of service.

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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

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