MENOR, et al. vs CHANEL, INC., et al.

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/13/2026 Hearing on Motion to Compel Motion to Compel Code-Compliant responses to Plaintiffs’ Form Interrogatories and Requests for Production (Set One) from Defendant Calvin Klein Cosmetics Corporation; filed by JOVY MENOR (Plaintiff) + CRS# 738222903668 in Department 18

Tentative Ruling - 08/12/2026 Patrick McKinney

The Motion to Compel NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ FORM INTERROGATORIES, SET ONE, AND REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT CALVIN KLEIN COSMETICS CORPORATION AND ITS COUNSEL OF filed by JOVY MENOR, BERNARD MENOR on 06/30/2026 is Granted in Part.

On June 30, 2026, Plaintiffs filed a motion to compel Defendant Calvin Klein Cosmetics Corporation (“Defendant”) further responses to Plaintiffs’ Form Interrogatories Set One (“FROGs”) and Requests for Production of Documents Set One (“RFPDs”) and requests monetary sanctions.

Plaintiffs’ reply states that it is “narrowly tailored” to address six remaining defects following Defendant’s opposition and representations that further responses are forthcoming, so the court’s order will address those items and considers the other issues to be settled and moot for purposes of this motion.

1. Defendant’s “not applicable” responses to FROGS 12.2, 12.4-12.6, 13.1, and 13.2

Plaintiffs’ motion is granted as to this issue. Defendant’s response of “not applicable” is nonresponsive to the questions asked by these FROGs. Defendant must answer “yes” or “no” to each of these interrogatories, and if the answer to any of them is “yes”, answer the follow-up questions fully. Defendant must also provide a response to FROG 12.3.

2. Defendant’s objections and response to FROG 16.1

Plaintiffs’ motion is granted as to this issue. Defendant’s objections to this interrogatory are overruled. The request is plainly relevant to the subject matter of this litigation, particularly apportionment of liability and damages, and is not overly broad or vague and ambiguous to the point of being unintelligible. Defendant must also provide a code-compliant yes/no response to this contention interrogatory and provide the information requested in subparts a-d to the best of its present knowledge.

3. Defendant’s response to RFPD No. 2

Plaintiffs’ motion is granted as to this issue. The potential availability of documents from 26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/13/2026 Hearing on Motion to Compel Motion to Compel Code-Compliant responses to Plaintiffs’ Form Interrogatories and Requests for Production (Set One) from Defendant Calvin Klein Cosmetics Corporation; filed by JOVY MENOR (Plaintiff) + CRS# 738222903668 in Department 18 another source does not relieve Defendant of its obligations in discovery. Defendant’s contention in its responsive separate statement that it has nothing to produce are also dubious. Defendant is ordered to provide a code-compliant response to this request and produce all responsive documents within its possession, custody or control even if those documents might be available elsewhere.

4. Defendant’s response to RFPD No. 13

Plaintiffs’ motion is granted as to this issue. Plaintiffs asserts in reply that it does not possess the witness statements referred to in Defendant’s response to this request. Defendant is ordered to produce the witness statements referred to in its response as well as a code-compliant written response.

5. Defendant’s objections in response to RFPD No. 23

Plaintiffs’ motion is granted as to this issue. Defendant’s written response to this request do not comply with Code of Civil Procedure sections 2031.220 or 2031.230. The response must indicate whether a diligent search has been made or the likely whereabouts of the documents. To the extent that Defendant identifies documents responsive to this request, it is ordered to produce them.

6. Verifications

Plaintiffs’ motion is granted. Unverified responses to discovery are considered tantamount to no response at all. Defendant is ordered to provide verifications for all responses to discovery that are currently unverified.

ORDER For the foregoing reasons, Plaintiffs’ motion is GRANTED in accordance with the above. Defendant is ordered to serve complete, code-compliant responses in compliance with the court’s order within 10 days of entry of this order and produce any and all responsive documents within 15 days of entry of this order. The court is inclined to grant Plaintiffs’ request for sanctions, but will waive the award Defendant serves verified amended responses in compliance with this order.

CONTESTING TENTATIVE ORDERS

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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

26CV162809: MENOR, et al. vs CHANEL, INC., et al. 08/13/2026 Hearing on Motion to Compel Motion to Compel Code-Compliant responses to Plaintiffs’ Form Interrogatories and Requests for Production (Set One) from Defendant Calvin Klein Cosmetics Corporation; filed by JOVY MENOR (Plaintiff) + CRS# 738222903668 in Department 18 1. Log into eCourt Public Portal - https://eportal.alameda.courts.ca.gov 2. Case Search 3. Enter the Case Number and select Search 4. Select the Case Name 5. Select the Tentative Rulings Tab 6. Select Click to Contest this Ruling 7. Enter your Name and Reason for Contesting 8. Select Proceed.