GARZA, et al. vs KRAVICH, et al.

(1) An answer to a particular interrogatory is evasive or incomplete.

(2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate.

(3) An objection to an interrogatory is without merit or too general.

(b)(1) A motion under subdivision (a) shall be accompanied by a meet and confer declaration under Section 2016.040.

(d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.

CCP § 2030.220 provides:

(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.

Discussion

This motion concerns Plaintiffs’ contention Special Interrogatories, Set Two, Nos. 1- 7.

Plaintiff’s stance is that Defendants served identical responses to each contention interrogatory but fail to state all their observations and responsive facts, like those in Beattie’s declaration. Defendants assert that anything regarding whether certain physical conditions are indicative of illegally manufactured drugs requires an expert opinion and is not a matter for a lay witness.

As to Special Interrogatory No. 1, Defendants response to this interrogatory is not code

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV103309: GARZA, et al. vs KRAVICH, et al. 07/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by LUIS VAZQUEZ (Plaintiff) + CRS# 568837016638 in Department 518 compliant as it does not plainly state if each Defendant does or does not have any facts that support their belief that Plaintiff engaged in illegal drug activity as required by CCP § 2030.220. Defendants’ failure to answer the question is unacceptable. For example, Sean Beattie’s declaration seems to provide examples of facts that he may believe show drug activity. This declaration also supports the notion that all Defendants may not have the exact same responses, and individual responses may be warranted.

The response to Special interrogatory No. 2 is incomplete in that no addresses are given regarding the listed witnesses.

Similarly, Special interrogatory No. 3 is also incomplete as Defendants cannot refer to all photographs, documents and full transcripts.

“Answers must be complete and responsive. Thus, it is not proper to answer by stating, ‘See my deposition’, ‘See my pleading’, or ‘See the financial statement’. Indeed, if a question does require the responding party to make reference to a pleading or document, the pleading or document should be identified and summarized so the answer is fully responsive to the question.” (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783–784.)

The answers to special interrogatories 4 – 7 are not complete and straight forward as required by CCP § 2030.220 (see above). Defendants must respond regarding whether any steps were taken to address any illicit activity, who they communicated with regarding the belief that illicit activity was taking place (i.e. telling the Plaintiff, police, other parties, etc.), when and how they first became aware of the illegal/illicit activity. The response that the investigation is ongoing does not act as a blanket response to the past. Were Defendants previously aware of illicit activity? If so, they must state how and when did they became aware, and what were any prior actions taken by defendants. If they were not aware of any illicit activity, in the past, that can be clearly stated.

The Court overrules the objection to every special interrogatory based on “premature” discovery. The Court is unpersuaded that this is a valid objection. CCP § 2030.22(c) seemingly undermines any basis for this objection. That said, while an unreasonably early discovery request is not objectionable per se, the Court notes that the information in the response and its usefulness to the requesting party may be limited by the early state of the parties’ investigations. (See People ex rel. Harris v. Sarpas (2014) 225 Cal.App.4th 1539, 1552-1553 [“The needs of the case did not warrant all of the interrogatories Much of the information sought by the interrogatories had already been provided or could be obtained by other means.”].) Thus, Defendants argument that this information is available via other sources may be valid.

For these reasons, Defendant is ordered to produce verified code-compliant further responses to Special Interrogatories Nos. 1- 7 by August 14, 2026.

The Court declines the parties’ requests for sanctions as Defendants’ responses were made with

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV103309: GARZA, et al. vs KRAVICH, et al. 07/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by LUIS VAZQUEZ (Plaintiff) + CRS# 568837016638 in Department 518 substantial justification, especially given that the parties failed to meet and confer in person or via zoom prior to the court’s order to do so.

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PLEASE NOTE: Pursuant to California Rule of Court 3.1308, subdivision (a)(1), this tentative ruling will become the order of the Court unless it is contested before 4:00 PM on the court day preceding the noticed hearing.

To contest a tentative ruling, a party should do the following:

First, the party must notify Department 518, by email at Dept518@alameda.courts.ca.gov and copy all counsel of record and self-represented parties. The contesting party must state in the subject line of the email the case name, case number and motion.

Second, the party shall log into the eCourt Public Portal, search for this case (e.g., by case number), select the case name, select the "Tentative Rulings" tab, click the "Click to Contest this Ruling" button, enter the party's name and a brief statement of the party's reason for contesting the tentative, and click "Proceed."

Please note the Court does not permit remote appearances for motions for summary judgment that are contested. If you contest a Motion for Summary Judgment, you must appear in person.

For all other motions (unless otherwise noted in the tentative ruling), Parties may appear via videoconference, using the Zoom.com website or application. TO CONNECT TO ZOOM: Department 518 is inviting you to a scheduled ZoomGov meeting.

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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV103309: GARZA, et al. vs KRAVICH, et al. 07/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by LUIS VAZQUEZ (Plaintiff) + CRS# 568837016638 in Department 518

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