MEAD vs SORIANO, et al.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D

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 be 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. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION****

TENTATIVE RULING

Plaintiff June Mead’s (“Plaintiff”) Motion to Compel Further Responses to Requests for Admission from Defendant Wilson Soriano (“Defendant”) is ruled upon as follows.

Factual Background

Plaintiff served the at issue discovery requests on September 30, 2025. (Ali Decl., ¶ 2.) Defendant served responses on November 17, 2025. (Manzoor Decl., ¶ 4.)

Plaintiff moves to compel further responses to requests for admission, set one, nos. 3- 12, 14-21, 23-30. Defendant opposes.

This matter was previously from June 1, 2026 to permit the Court to rule on the merits of the motion.

Defendant's objections to Plaintiff's reply are overruled.

Discussion

In opposition to the instant motion, Defendant argues, inter alia, that the motion is untimely and that Plaintiff failed to properly meet and confer prior to filing.

Timeliness

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D

As the Court noted at hearing, the Court finds that the instant motion was timely filed.

Defendant served his responses, by mail and facsimile, on November 17, 2026. (Manzoor Decl. ¶ 4, Exh. 4.) Therefore, any motion to compel was required to be filed by January 1, 2026, plus 2 Court days for service by facsimile. (Code of Civil Procedure section 1013(e).) As January 1, 2026 was a Thursday (and a holiday), the last day to file the instant motion was Monday, January 5, 2026, the same day the motion was filed and served by mail. (See Code of Civil Procedure section 1013(a) [“Service is complete at the time of deposit.”].)

Meet and Confer

The Court further notes that Plaintiff’s meet-and-confer efforts made prior to filing this motion do not appear to satisfy the current version of Code of Civil Procedure section 2016.040(a), which requires “a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion.” (Code Civ. Proc. § 2016.040(a), emphasis added.)

Here, the meet-and-confer efforts amounted to a single letter by each party, and there is no indication of an attempt to confer in person, by telephone, or by videoconference. However, as the meet-and-confer efforts occurred prior to the change in Code of Civil Procedure section 2016.040 and the motion was filed only shortly after the effective date of the statute, the Court will address the merits of the motion.

The Court notes that it has serious doubts regarding the seriousness of the meet-andconfer efforts in this matter. The Civil Discovery Act requires a serious effort at negotiation and informal resolution – counsel must “attempt to talk the matter over, compare their views, consult and deliberate.” (Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1294; see Townsend v. Superior Ct. (1998) 61 Cal.App.4th 1431, 1433 [informal resolution requirement not fulfilled by bickering between counsel during deposition].)

The meet and confer requirement is designed “to encourage the parties to work out their differences informally so as to avoid the necessity for a formal order.... This, in turn, will lessen the burden on the court and reduce the unnecessary expenditure of resources by litigants through promotion of informal, extrajudicial resolution of discovery disputes.” (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1016, quotations and citations omitted.)

Nevertheless, under the circumstances before the Court finds the meet-and-confer correspondence to be sufficient for the purposes of the instant motion, given the limited

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D

issues raised in the motion. However, Plaintiff’s counsel is advised to ensure proper compliance with section 2016.040 in the future and cautioned that failure to engage in serious and good faith meet-and-confer efforts prior to filing of a motion may result in a continuance of the motion to do so or denial of the motion.

Code Compliance

Code of Civil Procedure section 2033.210 states that responses to requests for admission “shall answer the substance of the requested admission, or set forth an objection to the particular request.” Code of Civil Procedure section 2033.220(b) provides that each answer to a request for admission shall:

(1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party. (2) Deny so much of the matter involved in the request as is untrue. (3) Specify so much of the matter involved in the request as to the truth of which the responding party lacks sufficient information or knowledge.

Defendant responded to request nos. 4-8, 10, 14, 19, 20, 21, 25-28, and 30 with a denial, without any objections.

Plaintiff argues that “A bare denial without identification of supporting facts, witnesses, or documents violates CCP § 2033.220(b)-(c).” Plaintiff further argues that the responses are not code complaint because they do not “not state that a reasonable inquiry was conducted and provides no basis for the denial.

Defendant’s responses to these requests are code compliant. Plaintiff cites to no authority to support her position that a denial must include facts to support the denial or statement regarding a reasonable inquiry; to the extent Plaintiff cites section 2033.220(c), the provision applied to where a responding party cites lack of information or knowledge as a reason for a failure to admit all or party of a request. (Code of Civil Procedure section 2033.220(c) [“If a responding party gives lack of information or knowledge as a reason for a failure to admit all or part of a request for admission, that party shall state in the answer that a reasonable inquiry concerning the matter in the particular request has been made, and that the information known or readily obtainable is insufficient to enable that party to admit the matter.”].)

As such, Plaintiff’s motion to compel is DENIED as to request nos. 4-8, 10, 14, 19, 20, 21, 25-28, and 30.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D

Plaintiff argues that Defendant’s response to request no. 3, is improper, as Defendant admits the request to the extent that “Responding Party remained in possession of the premises after October 15, 2018, on a month-to-month basis while awaiting to sign the new two-year lease agreement that was agreed with the Plaintiff.” Plaintiff argues that this response is improper, because Defendant qualifies the response with narrative explanations, as opposed to providing an unqualified admission. Code of Civil Procedure section 2033.220 permits a responding party to “Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as reasonably and clearly qualified by the responding party.” The Court finds that Defendant’s response is code complaint. Plaintiff’s motion to compel is DENIED as to request no.

3.

Plaintiff moves to compel further responses to request for admission nos. 9, 12, 15, 16, and 18 on the grounds that objection only responses are not permitted in response to requests for admission. As noted above, Code of Civil Procedure section 2033.210 provides that in response to requests for admissions, a party shall answer the substance of the requested admission or object to the request. Plaintiff cites to no authority which would persuade the Court that objection only responses are not permitted in response to requests for admission. Accordingly, Plaintiff’s motion to compel is DENIED as to these requests with respect to code-compliance; the Court addresses arguments relating to the objections, below.

Objections

As the party resisting discovery, Defendant has the burden to justify objections. (Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255 citing Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221.) However, Plaintiff must still place the objections at issue by identifying which specific objections are being challenged.

Defendant responded to request nos. 11, 15, and 16, stating “Objection asked and answered.” Plaintiff argues, inter alia, that “asked and answered” is not a valid objection to a request for admission. In response, Defendant argues that “compound requests for admission are not permitted. Each request for admission must address only a single fact and be complete in and of itself.” However, Defendant did not raise such an objection in response to request nos. 11, 15, and 16, and therefore any objection of compound is waived. Defendant makes no argument to justify his objection of asked and answered. Therefore, the objection is overruled and Plaintiff’s motion to compel is GRANTED as to these requests.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D

Defendant responded to request nos. 9, 12, 17, 18, 23, 24, and 29, objecting on the grounds that “this Request assumes facts not in evidence, overly broad, and compound. (Code Civ. Proc., § 2033.060).” The Court does not find the objections to be well-taken. As such, Defendant’s objections are overruled, and Plaintiff’s motion to compel is GRANTED as to these requests.

Request no. 29 states: “Admit that you requested a reduction or abatement of rent citing COVID-19.” Plaintiff argues that the objections of overly broad and compound in response to request no. 29 are improper and should be overruled.

In opposition, Defendant argues that compound requests are not permitted. Defendant presents no specific argument as to why he believes the request to be compound. The Court will overrule Defendant’s objections of overbroad and compound, and GRANT the motion with respect to request no.

29.

Sanctions

Given the mixed result, the Court will deny the Parties’ dueling requests for sanctions.

Disposition

As set forth above, Plaintiff’s motion to compel is GRANTED as to request nos. 9, 11- 12, 15-18, 23-24, and 29, and DENIED as to all other requests. Defendant shall serve verified amended responses by no later than July 20, 2026.

The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV007870: MEAD vs SORIANO, et al. 07/06/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Admissions, Set One in Department 8D