MOLLINS vs RELIANCE, INC., et al.

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/17/2026 Hearing on Motion to Compel Reliance, Inc., Further Responses to Form Interrogatories - Employment Law, Set One in Department 8D

Tentative Ruling

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 8D Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16113421868 and the Zoom Meeting ID is 161 1342 1868. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE 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 on the Court Reporter Services webpage available on the Sacramento Superior Court website at https://saccourt.ca.gov/general-information/court-reporter-services-transcripts. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000.

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

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/17/2026 Hearing on Motion to Compel Reliance, Inc., Further Responses to Form Interrogatories - Employment Law, Set One in Department 8D

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.

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G. ST. SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 25 WILL BE HEARD IN DEPARTMENT 8D OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION AND WILL NOT BE ACCEPTED AT THE HALL OF JUSTICE OR GORDON D. SCHABER COURTHOUSE. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION.***

Plaintiff’s Notice of Motion stated the procedure for the Court’s Presiding Judge calendar tentative ruling system pursuant to Local Rule 1.05. The Court’s Law & Motion Departments use the procedures in Local Rule 1.06, which differ from those in Rule 1.05. Moving counsel is directed to contact opposing counsel immediately and advise of Local Rule 1.06 and the appropriate tentative ruling procedure and manner to request a hearing. If moving counsel is unable to contact opposing counsel prior to the hearing, moving counsel is ordered to appear at the hearing in person, by Zoom or by telephone in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

TENTATIVE RULING:

Plaintiffs Ryan Mollins and Talia Mollins’s (“Plaintiffs”) motion to compel Defendant Reliance, Inc.’s (“Defendant”) further responses to form interrogatories is ruled upon as follows.

This case arises out of Plaintiff Ryan Mollins’s employment with Defendants Reliance, Inc. and American Metals Corporation. Plaintiffs allege in their Third Amended Complaint (“TAC”) causes of action for: (1) defamation; (2) violation of Labor Code section 1050, et seq.; (3) violation of Labor Code section 1102.5; (4) violation of Labor Code sections 6310 and 6311; (5) wrongful termination; and (6) loss of consortium. On June 6, 2025, the Loss of Consortium Cause of Action as to Defendant Karla Lewis was dismissed.

Plaintiffs propounded their Form Interrogatories – Employment Law, Set One, (“EROGs”) on December 5, 2024. (Brouwer Decl., ¶ 4.). At issue in this motion is EROG No. 215.1:

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/17/2026 Hearing on Motion to Compel Reliance, Inc., Further Responses to Form Interrogatories - Employment Law, Set One in Department 8D

Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the ADVERSE EMPLOYMENT ACTION? If so, for each individual state: (a) the interview, the name, ADDRESS, and telephone number of the individual interviewed; (b) the date of the interview; and (c) the name, ADDRESS, and telephone number of the PERSON who conducted the interview.

(Separate Statement.[1]) Defendant responded to this EROG on May 14, 2025, with a lengthy list of objections:

Defendant incorporates its Preliminary Statement and General Objections above, as though fully set forth herein. Defendant objects to this interrogatory on the grounds that it is overbroad, vague and ambiguous, including as to “interviewed,” “concerning,” and “ADVERSE EMPLOYMENT ACTION.” Defendant objects to the extent that the interrogatory calls for a legal conclusion or presents questions of law. Defendant further objects to this interrogatory to the extent that it seeks information protected from disclosure by the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege, immunity, or doctrine.

Defendant objects on the grounds that the interrogatory seeks sensitive and confidential business information. Defendant objects to this interrogatory on the ground that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this interrogatory to the extent that it seeks disclosure of information in violation of privacy rights of individuals under Article 1, Section 1 of the California Constitution, or any other constitutional, statutory, or common law right of privacy of any person.

Defendant further objects to this interrogatory on the ground that it is duplicative of Interrogatory No. 12.2 of Plaintiffs’ Form Interrogatories— General, Set One. Defendant objects to this interrogatory on the ground that Plaintiff Ryan Mollins was never employed by Defendant. Defendant objects on the grounds that discovery is ongoing, and as such, reserves the right to supplement its response as additional facts and/or documents are discovered.

(Separate Statement; Brouwer Decl., ¶ 8.) Defendant subsequently served supplemental responses to some of Plaintiffs’ other discovery demands but did not supplement their response to EROG No. 215.1. (Brouwer Decl., ¶¶ 12, 14, 26.)

Plaintiffs now ask the Court to compel a further response on the basis that Defendant

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/17/2026 Hearing on Motion to Compel Reliance, Inc., Further Responses to Form Interrogatories - Employment Law, Set One in Department 8D

has waived any privilege by putting the investigations at issue in this case. (Memo. of Points & Authorities [“MPA”], at p. 14–16.) Defendant opposes the motion, arguing that the discovery request demands protected materials that it has not put at issue.[2] (Opp., at pp. 10–13.) Defendant further states that it is willing to produce the factual investigation materials sought by this request. (Id., at pp. 14–15.)

A party may move for an order compelling further responses to interrogatories if the party deems objections to be without merit or too general. (Code Civ. Proc., § 2030.300.) Generally, parties may obtain discovery regarding any relevant matter that is not privileged. (Code Civ. Proc., § 2017.010.) An attorney’s work product is either absolutely or qualifiedly privileged from discovery. (Id., § 2018.030.) Confidential communications between a client and lawyer are also privileged from discovery. (Evid. Code, § 954.)

EROG No. 215.1 seeks basic factual information about interviews Defendant performed related to Plaintiff Ryan Mollins’s firing on July 20, 2023. (See TAC, ¶¶ 78–79.) Defendant admits that it performed at least two investigations related to this event. Defendant’s in-house legal department began an investigation on or around July 10, 2023 (“internal investigation”). (McBride Decl., ¶ 4.) Defendant declares that this investigation was “for the purposes of gathering facts necessary to provide legal advice to Reliance concerning the complaint, Mr. Mollins’ employment, potential employment action, and related legal issues.” (Ibid.)

Defendant hired outside counsel to perform another investigation (“outside investigation”). (McBride Decl., ¶ 6.) The outside investigation began on July 12, 2023, and concluded on August 2, 2023. (Id., ¶¶ 6–9.) The purpose was to assist in-house counsel in “provid[ing] legal advice to Reliance concerning the complaint, Mr. Mollins’ employment, potential employment action, and related legal issues.” (Id., ¶ 6.) At least the outside investigation involved interviewing witnesses. (Id., ¶ 7.)

A list of witnesses interviewed by an attorney is potentially attorney work product protected from discovery. (Coito v. Super. Ct. (2012) 54 Cal.4th 480, 501–502 (Coito).) The party resisting discovery bears the burden to demonstrate that the information would reveal the attorney’s “tactics, impressions, or evaluation of the case.” (Id. at p. 502)

Although Defendant generally asserts that the information is protected, Defendant has not attempted to argue specifically that the basic factual information sought by EROG No. 215.1 will reveal the attorney’s though process or undeservedly advantage Plaintiff’s counsel. Instead, Defendant has offered to provide the information.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV014460: MOLLINS vs RELIANCE, INC., et al. 06/17/2026 Hearing on Motion to Compel Reliance, Inc., Further Responses to Form Interrogatories - Employment Law, Set One in Department 8D

The Court finds that for purposes of this motion it need not determine whether Defendant has waived privileges by putting the investigations at issue. It is sufficient that Defendant has not made a showing of attorney work product according to Coito. The Court further finds that in providing this information Defendant does not waive any privileges or protections beyond the scope of this discovery issue.

Accordingly, the Court GRANTS Plaintiffs’ motion to compel a further response to EROG No. 215.1. Defendant shall serve a verified response no later than July 17, 2026.

Neither party sought monetary sanctions, and none are awarded.

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.)

[1] “Separate Statement” in this Order refers to Plaintiffs’ filing. Defendant filed a

Separate Statement with its opposition papers. No statute or court rule authorizes such a filing. (See Cal. Rules of Court, rule 3.1345.) [2] Based on Defendant’s arguments, the Court understands Defendant to have

abandoned its objections to EROG No. 215.1 other than attorney-client privilege and/or attorney work product protection.