MEAD vs SORIANO, et al.

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

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***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 Form Interrogatories 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 form interrogatories, set one, nos. 3.7, 4.1, 4.2, 7.2, 7.3, 12.1, 12.2, 12.3, 12.4, 12.6, 12.7, 14.1, 14.2, 15.1, 16.1, 16.2, 16.3, 16.6, 16.7, 16.8, 16.9, 17.1, 50.1, 50.2, 50.3, 50.4, 50.5, and 50.6. 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 Form Interrogatories, 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. 5.) 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 motion was filed on December 31, 2025 and served, by mail on January 2, 2026. (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

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 Form Interrogatories, Set One in Department 8D

correspondence to be sufficient for the purposes of the instant motion, given the limited 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

Defendant responded to form interrogatories nos. 7.2, and 7.3, stating, “Not Applicable. (See Defendant’s Responses at approx. p. 11.)” Plaintiff argues that this response is improper. In opposition, Defendant argues that “This request is nonsensical. Defendant in his 7.0 responses objected then the logical answer to 7.1 would be non-applicable. Then how can Plaintiff ask for further information on 7.1.”

Code of Civil Procedure section 2030.220 requires that responses to Interrogatories be as “complete and straightforward” as the information reasonably available to the responding party permits, and “if an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220(a), (b); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 788-89.) Plaintiff has a duty to obtain responsive information and must furnish it from sources under its control. (Ibid.) If Plaintiff is not aware of any specific facts, witnesses or documents that are responsive to these interrogatories, then Plaintiff must state as much. (Code Civ. Proc. § 2030.220.)

While Defendant responded to interrogatory no. 7.1 with objections, Defendant raised no such objections in response to interrogatories nos. 7.2 or 7.3. Nor does Defendant’s opposition provide any explanation which would persuade the Court that objections to interrogatory no. 7.1 are sufficient to warrant a refusal to respond to interrogatories nos. 7.2 or 7.3. This response is not code complaint. Plaintiff’s motion to compel is GRANTED as to interrogatories nos. 7.2 and 7.3.

Defendant responded to interrogatory nos. 12.1-12.4, 12.6, 12.7, 15.1, 50.1-50.4, and 50.6, stating:

It is difficult for Defendant to answer this question since the case is not at issue. The Defendants have filed a Demurrer, because Defendants believe that Plaintiff complaint [sic] lack legal standing and is vague and thus it is difficult for the Defendant to understand the allegations against him in the complaint and in turn file his answer with his affirmative defense. Once the case is at issue then

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 Form Interrogatories, Set One in Department 8D

Defendant have a better understanding of the time period that is at issue and he will be able to answer this questions regarding witnesses and he will amend his answer. Defendant reserves the right to amend his answer

This response is not code complaint. Defendant does not raise any objections, nor does he provide a substantive response. Nor would an objection that a demurrer is pending constitute a valid objection to a discovery request.[1] Plaintiff’s motion to compel is GRANTED as to interrogatories nos. 12.1-12.4, 12.6, 12.7, 15.1, 50.1-50.4, and 50.6.

The Court notes that Plaintiff’s motion fails to comply with California Rules of Court, rule 3.1345 with respect to form interrogatory 17.1. California Rules of Court, rule 3.1345(c)(2) requires a separate statement contain “The text of each response, answer, or objection, and any further responses or answers.” Plaintiff’s separate statement provides with respect to form interrogatory 17.1 only a “summary of verbatim responses.” The Court further notes that while Plaintiff argues that Defendant’s response to this interrogatory “frequently states” or “repeatedly recycles identical explanations,” she fails to place any specific objections at issue.

Further, while Plaintiff calls into question Defendant’s responses, she appears to take issue with the content of the responses, as opposed to identifying a specific basis for which a motion to compel may be granted. Plaintiff’s motion to compel is DENIED as to interrogatory no. 17.1, for failure to comply with California Rules of Court, rule 3.1345(c)(2).

Objections

Defendant provided objection only responses to interrogatories nos. 3.7, 4.1, 4.2, 14.1, 14.2, 16.1-6.3, 16.6-16.9, and 50.5.

The party seeking to resist discovery based upon objections has the burden to justify its objections. (Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255 [citing Coy v. Superior Court (1962) 58 Cal.2d 220-221].)

Form interrogatory No. 3.7 seeks identification of Defendant’s businesses registered by a public entity in the past five years. Defendant responded to interrogatory No. 3.7:

Responding party objects that this interrogatory is vague and ambiguous as to the term “INCIDENT,” is irrelevant, invades privacy, and is not applicable because this is not a motor vehicle collision case. No substantive response is provided. (See Defendant’s Responses at approx. p. 9.)

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 Form Interrogatories, Set One in Department 8D

Plaintiff argues that she seeks information pertaining to “basic information regarding business licensure or registration within the past five years, which is directly relevant to Defendant’s business operations during the lease term at issue in this commercial dispute.” Plaintiff further argues that business licenses and registrations are public records, and therefore do not implicate privacy rights. Defendant argues that his objections of privacy and relevance are proper.

Plaintiff’s operative second amended complaint (“SAC”) alleges that Defendant, while doing business as “Stone Tile Evolution,” and while acting in an alter ego capacity with Defendants STE Stone Countertops and Stone Tile Evolution LLC, entered into an agreement with Plaintiff by which Plaintiff leased a commercial property located at 1717 Kathleen Ave, Suite 1, Sacramento, CA 95835 (the “Property”) to Defendant. The SAC alleges that Defendant operates a number of businesses as a sole proprietor, a number of which utilized the Property.

“Unless otherwise limited by order of the court . . . any party may obtain discovery 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.)

Information is relevant “if it might reasonably assist a party in evaluating its case, preparing for trial, or facilitating a settlement. [citations omitted.] Admissibility is not the test and information, unless privileged, is discoverable if it might reasonably lead to admissible evidence.” (Lipton v. Superior Court (1996) 48 Cal.App.4th 1599, 1611-1612 [emphasis in original].) “Any doubts regarding relevance are generally resolved in favor of allowing the discovery.” (Mercury Interactive Corp. v. Klein (2007) 158 Cal.App.4th 60, 98.)

“The party asserting a privacy right must establish a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious.” (Williams v. Superior Court (2017) 3 Cal.5th 531, 553.) Where all three factors are met, the privacy interests must then be balanced against the right of discovery.

The Court is not persuaded that Defendant has established a legally protected privacy interest with respect to documents publicly filed with the California Secretary of State. Further, given the allegations of the SAC, the Court finds the interrogatory to be reasonably calculated to lead to the discovery of admissible evidence.

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 Form Interrogatories, Set One in Department 8D

Accordingly, Plaintiff’s motion to compel is GRANTED as to interrogatory no. 3.7.

Defendant responded to interrogatories nos. 14.1, 14.2, 16.2, 16.3, 16.6, 16.9:

Responding Party objects that the term “INCIDENT” is vague, ambiguous, and inapplicable in this breach of contract action. Objection is further raised that this is not a personal injury case/motor vehicle accident case. [citation omitted in 14.1 and 14.2]

Defendant raised the same objections in response to form interrogatories no. 16.1, but added “Defendant reserves the right to amend his answer.” Defendant also raised the same objections in response to form interrogatories nos. 16.7 and 16.8, but added “Furthermore, to date of signing of these responses Plaintiff has not disclosure [sic] any property damage.”

Code of Civil Procedure section 2030.220 requires that responses to interrogatories be as “complete and straightforward” as the information reasonably available to the responding party permits, and “if an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220(a), (b); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 788-89.) Plaintiff has a duty to obtain responsive information and must furnish it from sources under its control. (Ibid.) If Plaintiff is not aware of any specific facts, witnesses or documents that are responsive to these interrogatories, then Plaintiff must state as much. (Code Civ. Proc. § 2030.220.)

Defendant’s objections of vague and ambiguous are overruled, as Defendant makes no attempt to justify these objections. (See Fairmont Ins. Co. v. Superior Court, supra, 22 Cal.4th at p. 255.)

To the extent that Defendant’s response states that the interrogatories are inapplicable and that this is not a personal injury case, the Court construes this to be an objection of relevance. As noted above, discovery is relevant if it might reasonably assist a party in evaluating its case, preparing for trial, or facilitating a settlement. The Court finds that form interrogatories nos. 16.2, 16.3, and 16.9 are not relevant, given the facts of the case, as these interrogatories pertain specifically to personal injuries, which Plaintiff is not alleging.

However, the remainder are reasonably calculated to lead to the discovery of admissible evidence. To the extent that Defendant may argue that the entire 16 series is

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 Form Interrogatories, Set One in Department 8D

irrelevant, interrogatories 16.1, 16.6, 16.7, and 16.8 may be construed to involve property damage to or loss of earnings in relation to the Property, which are certainly relevant to the instant case.

Accordingly, Plaintiff’s motion to compel is GRANTED as to form interrogatories nos. 14.1, 14.2, 16.1, 16.6, 16.7, 16.8; and DENIED as to form interrogatories nos. 16.2, 16.3, and 16.9.

Finally, in response to form interrogatories nos. 4.1 and 4.2, which seek information related to any insurance policies held by Defendant, Defendant responded:

Responding Party objects to this interrogatory on the grounds that the term 'INCIDENT' is vague, ambiguous, relevance and not applicable to this breach of contract action, as it generally refers to a physical accident or occurrence in personal injury matters. Responding Party further objects that this interrogatory seeks information protected by the attorney-client privilege and attorney work- product doctrine to the extent it calls for disclosure of communications with counsel or analysis of coverage issues.

Responding Party further objects that it is overbroad and seeks information not relevant to the subject matter of this action, except as provided under California Code of Civil Procedure section 2017.210, which permits disclosure of the existence and contents of any insurance agreement under which an insurer may be liable to satisfy part or all of a judgment. Finally, invasion of privacy.

Defendant argues only that the interrogatory is not relevant and subject to Constitutional privacy rights. Accordingly, all other objections are overruled.

The Court finds that Defendant has not articulated a legally protected privacy right with respect to his insurance policies. Further, given that Plaintiff’s complaint alleges damages to the Property, the existence of an insurance policy or insurance policies which cover such damage is certainly relevant to the instant action.

Accordingly, Plaintiff’s motion to compel is GRANTED as to form interrogatories nos. 4.1 and 4.2.

Sanctions

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

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 Form Interrogatories, Set One in Department 8D

Disposition

As set forth above, Plaintiff’s motion to compel is granted as to interrogatories nos. 3.7, 4.1, 4.2, 7.2, 7.3, 12.1-12.4, 12.6, 12.7, 15.1, 14.1, 14.2, 16.1, 16.6, 16.7, 16.8, 50.1- 50.4, and 50.6; and denied as to 16.2, 16.3, 16.9, 17.1.

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.

[1] The Court further notes that while Defendant has reserved a date for a demurrer to Plaintiff’s second

amended complaint, no such demurrer has been filed before the Court.