FATIMA vs LUCID GROUP, INC.

25CV129063: FATIMA vs LUCID GROUP, INC. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Iraj Fatima (Plaintiff) CRS# 899453246323 in Department 520

Tentative Ruling - 06/11/2026 Jamilah A. Jefferson

The Motion to Compel Further Discovery Responses filed by Iraj Fatima on 03/18/2026 is Granted in Part.

The Motion of Plaintiff Iraj Fatima (“Plaintiff”) to Compel Further Requests for Production of Documents is GRANTED IN PART.

To the extent granted, Defendant is ORDERED to provide verified supplemental or amended responses and responsive documents with statements of compliance as detailed in this order within 60 (sixty) days. (Code Civ. Proc., § 2031.310, subd. (a)(1).)

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LEGAL STANDARD

Where the party propounding written discovery deems the responses unsatisfactory, the party may move to compel further responses. (Code Civ. Proc., § 2031.310.)

A motion to compel further responses to requests for production of documents “shall set forth specific facts showing good cause justifying the discovery sought by the demand.” (Code Civ. Proc., § 2031.310, subd. (b); see also Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98 [stating that once good cause is shown, the burden shifts to the responding party to justify the objection].) Where electronically stored information is “not readily accessible,” the responding party bears the burden of demonstrating the burden. (Code Civ. Proc., § 2031.310, subd. (d).)

“[D]iscovery regarding any matter, not privileged, that is relevant to the subject matter involved... if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” (Code Civ. Proc., § 2017.010.)

DISCUSSION

The Court finds that the categories of documents sought are not overreaching but described with reasonable particularity and directly relevant to this litigation. (Code Civ. Proc., §§ 2017.010; 2031.030, subd. (c).) The categories are largely for the purpose of (1) relating to Defendant’s discussions, internal investigations and analysis of Plaintiff’s car defects based on Defendant’s warranty, and corresponding policies and procedures; and (2) establishing that Defendant 25CV129063: FATIMA vs LUCID GROUP, INC. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Iraj Fatima (Plaintiff) CRS# 899453246323 in Department 520 previously knew of the defects based on similar issues for vehicles of the same year, make and model but nevertheless refused to repurchase the vehicle. (Lara Decl. ¶ 4, Ex. 1; Separate Statement.)

Defendant generally objects to each on a similar basis that they are irrelevant and/or overly broad and burdensome. (Defendant’s Responses to Separate Statement.) Defendant indicates that it is willing to supplement responsive documents for RPD 9 and it is therefore moot or should be denied. However, Defendant does not state that in said response or offer a declaration in support thereof. On the other hand, Plaintiff does not address Defendant’s contention. Thus, the Motion is denied as to RPD 9.

For RPD 3, the Parties dispute whether certain documents have or have not been produced, albeit in arguments only; for instance, Plaintiff claims that Defendant is withholding documents related to the subject vehicle’s warranty. (Reply, p. 2:21-22.) Defendant claims that it has produced “documents reflecting the Subject Vehicle’s warranty repair history” “through its broader vehicle-specific production[.]” (Oppo., p. 3:3-10.) Given this vague representation and regardless of how many pages were produced, the Motion is granted as to RPD 3.

Contrary to Defendant’s claims, RPDs 37-129 as to “other vehicles” are not “improper[]” and do appear calculated to lead to the discovery of relevant and admissible evidence. (Oppo., p. 11:24-26.) Thus, the Motion is granted for these RPDs to the extent that responsive documents have not already been produced. The Court notes that, at the hearing on the motion, the Court recognized that, while it disagrees that any and all discovery related to "other vehicles" is irrelevant, it does not necessarily agree that 100 separate requests are reasonable and narrowly targeted to seek this potentially relevant evidence.

The parties are urged and encouraged to continue to meet and confer to narrow the requests and/or agree on more precise phrases in the requests to generate the least burdensome and most productive/helpful production possible. Defendant is not foreclosed from bringing a subsequent motion if the parties are unable to agree on a reasonable narrowing of requests/terms.

As to the remaining RPDs - 31 and 139, Defendant alleges that the motion should be denied because of how burdensome it would be in that it would require “(1) an extensive search through its files and records to identify all responsive documents, and (2) an extensive review of any such responsive documents to redact the personal information of other consumers.” (Oppo., p. 7:21- 25.) However, this is not a quantifiable burden nor does the Court find that the burden Defendant would suffer should it be compelled to supplement its responses to the Requests overcome or “clearly outweigh[]” the probative value of the information sought. (CCP Section 2017.020.)

Thus, the Court finds that there is good cause to GRANT IN PART Plaintiff’s Motion to Compel Further RPDs.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV129063: FATIMA vs LUCID GROUP, INC. 06/11/2026 Hearing on Motion to Compel Further Discovery Responses filed by Iraj Fatima (Plaintiff) CRS# 899453246323 in Department 520

To the extent that Defendant seeks to withhold any responsive documents on the basis of privilege or confidentiality, Defendant shall provide a detailed privilege log that identifies with particularity the legal basis for the party’s claim of privilege as well as facts sufficient for the court to determine whether the asserted privilege applies. (Catalina Island Yacht Club v. Superior Court (2015) 242 Cal.App.4th 1116, 1130; Code Civ. Proc., § 2031.240.)

NOTICE: This tentative ruling will automatically become the court’s final order on June 11, 2026 unless, by no later than 4:00 P.M. on June 10, 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. Their 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 that they will appear in court in person for the hearing, however all other counsel/parties and the JUDGE MAY APPEAR REMOTELY.