O’LOUGHLIN vs AHRARI ENTERPRISES LLC, et al.

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

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 06/17/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, 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.***

The notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06(D). Moving counsel is directed to contact opposing counsel forthwith to advise of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing. If moving counsel is unable to contact opposing counsel prior to the hearing, moving counsel shall be available at the hearing, in person or remotely, in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

TENTATIVE RULING:

Plaintiff Matthew O’Loughlin’s (“Plaintiff”) Motion to Compel Further Reponses to Form Interrogatories, Set One, is CONTINUED to August 19, 2026, to permit the parties to further meet and confer.[1]

At the outset, the Court reminds counsel that given the number of motions such as this which must be addressed on a daily basis, there are simply not sufficient judicial resources available to resolve each and every discovery dispute that could have and should have been resolved between the parties. This serves to highlight the critical need for all counsels’ legitimate, reasonable and good faith meet-and-confer efforts before filing any discovery motion. Although it dealt with a motion to compel answers to deposition questions, Townsend v. Superior Court (1998) 61 Cal.App.4th 1431 is instructive in that it clarifies that the meet-and-confer process is not intended to be some perfunctory formality but rather it “requires a serious effort at negotiation and informal resolution.” (Id. at p. 1483.)

Furthermore, as of January 1, 2026, California statutory law now requires parties to declare a reasonable and good faith attempt to meet and confer “either in person, by

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018807: O'LOUGHLIN vs AHRARI ENTERPRISES LLC, et al. 06/17/2026 Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One in Department 8D

telephone, or by videoconference.” (Code Civ. Proc., § 2016.040, subd. (a).) An exchange of letters or emails is no longer sufficient, to the extent it ever was.

Moving counsel filed this motion after receiving some further responses. (Quirk Decl., ¶ 6.) Counsel declares that because the responses did not meet his expectations, he deemed further efforts to meet and confer “to be a waste of time.” (Id., ¶ 8.)

The Court could reasonably interpret this declaration as stating that moving counsel did not make any good faith attempt to meet and confer before filing the instant motion. This is grounds for denying the motion outright. But having reviewed the moving and opposing papers and the numerous discovery requests that the parties dispute, it is apparent to the Court that further progress could be made if counsel continues to engage in the meet-and-confer process in good faith. For example, Defendant asserts in opposition that it has now prepared further responses. Counsel for the parties are thus ordered to meet and confer in order to resolve or substantially narrow their discovery disputes.

In compliance with statute and to encourage meaningful dialogue, counsel shall meet and confer in person or via telephone or videoconference no later than July 29, 2026. After thoroughly meeting and conferring in an attempt to resolve each and every discovery request that the motion currently encompasses, and no later than August 5, 2026, counsel shall file a joint statement indicating clearly which discovery requests have been resolved and which, if any, requests remain outstanding. For each outstanding request, counsel shall set forth concisely in their joint statement their respective positions, citing relevant facts and authorities. Boilerplate or cut-and-paste arguments are strongly discouraged. In the case that all the discovery disputes related to this motion are resolved, moving counsel shall promptly inform the court clerk to vacate the hearing.

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] Plaintiff filed a request for judicial notice on Friday June 12, well after all deadlines for

filing papers relevant to this motion. Furthermore, the Court fails to see the relevance of the documents. Plaintiff’s request is DENIED.

On the Court's own motion, the Hearing on Motion to Compel Further Discovery Responses to Form Interrogatories, Set One scheduled for 06/17/2026 is continued to 08/19/2026 at 01:30 PM in Department 8D at Tani G. Cantil-Sakauye Courthouse.