Latonia Vaughan vs. Karma Apartments

34-2023-00334089-CU-BC-GDS: Latonia Vaughan vs. Karma Apartments 07/28/2026 Hearing on Motion to Compel Further Responses to Insurance Discovery in Department 16D

Tentative Ruling

NOTICE: Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure: To request limited oral argument, on any matter on this calendar, you must call the Department 16D Oral Argument Request Line at (916) 874-3056 by 4:00 p.m. the court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail message (a) identifying themselves as the party requesting oral argument; (b) indicating the specific matter/motion for which they are requesting oral argument; and (c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below.

If no request for oral argument is made, the tentative ruling becomes the final order of the Court. Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings.

The Department 16D Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16146506749 and the Zoom Meeting ID is 161 4650 6749. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED. Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed on the Court Reporter Services webpage available on the Sacramento Superior Court website at https://saccourt.ca.gov/general-information/court-reporter-services-transcripts.

Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000. 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 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. *** EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G.

CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET IN SACRAMENTO, CA

34-2023-00334089-CU-BC-GDS: Latonia Vaughan vs. Karma Apartments 07/28/2026 Hearing on Motion to Compel Further Responses to Insurance Discovery in Department 16D

95814. ALL HEARINGS NOTICED FOR DEPARTMENT 53 WILL BE HEARD IN DEPARTMENT 16D OF THE NEW COURTHOUSE. PARTIES MAY CONTINUE TO APPEAR REMOTELY IN DEPARTMENT 16D UNLESS SPECIFICALLY ORDERED OTHERWISE. ***

TENTATIVE RULING

Plaintiff Vaughan’s “Motion to Compel Further Responses to Insurance Discovery,” consisting of both Special Interrogatories and Requests for Production directed to defendant Karma Apartments, LLC, is DENIED as follows.

*** If oral argument is requested, the parties must at the time oral argument is requested notify the clerk and the opposing party of the specific discovery requests that will be addressed at the hearing. The parties are also reminded that pursuant to local rules, only limited oral argument is permitted on law and motion matters. ***

Although the notice of motion provides notice of the Court’s tentative ruling system as required by Local Rule 1.06, the notice of motion again does not comply with the specific provisions of Local Rule 1.06(D). Moving counsel directed to review the Local Court Rules, effective 7/1/2026.

Moving counsel again failed to comply with CRC Rule 2.111(3) and Rule 3.1110(b)(3)- (4).

Opposing counsel also failed to comply with CRC Rule 2.111(3).

The present motion to compel shall be denied for several separate and distinct reasons. First, Local Rule 2.31(E) states in its entirety:

When simultaneously filing multiple discovery-related motions in the same case with the same hearing date, each motion shall be filed as a separate document and a separate filing fee paid for each. Parties may not combine motions pertaining to different types of discovery within the same document. Failure to comply with any part of this rule regarding discovery motions may, in the discretion of the court, be grounds for the motions being dropped without consideration. (Underline added for emphasis.)

Here, the moving papers make clear that plaintiff Vaughan is currently seeking an order compelling defendant Karma Apartments, LLC to provide further responses to not only plaintiff’s Special Interrogatories but also her Requests for Production. However, in

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00334089-CU-BC-GDS: Latonia Vaughan vs. Karma Apartments 07/28/2026 Hearing on Motion to Compel Further Responses to Insurance Discovery in Department 16D

violation of Local Rule 2.31(E), plaintiff filed a single motion which purports to address both the Special Interrogatories and the Requests for Production and pursuant to Local Rule 2.31(E), this Court may decline to consider the merits of the present motion.

Second, a motion seeking to compel further responses to either interrogatories or requests for production must be supported by a meet-and-confer declaration pursuant to Code of Civil Procedure §2016.040. (See, Code Civ. Proc. §2030.300(b)(1), §2031.310(b)(2).) The recently amended version of §2016.040(a) now provides in its entirety:

A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion. (Underline added for emphasis.)

Here, the moving declaration by attorney Wood fails to specify whether plaintiff’s meetand-confer efforts in early 2026 were conducted “either in person, by telephone, or by video conference” as required by §2016.040(a). Moreover, the opposing declaration by attorney Singer includes a copy of a letter from attorney Wood, dated 1/20/2026, which specifically states that it is the plaintiff’s attempt to meet and confer regarding defendant Karma Apartments’ responses to “Plaintiff’s insurance-specific Special Interrogatories and Requests for Production.” (Singer Decl., Ex. E, p.1.) However, the sending of mere letters and/or emails fails to satisfy the express requirements for meet-and-confer efforts under the current version of §2016.040(a). On this ground, the present motion to compel is denied.

Even if the aforementioned 1/20/2026 meet-and-confer letter did otherwise comply with the requirements of Code of Civil Procedure §2016.040(a) (which it does not), the Court does not find that this 1/20/2026 meet-and-confer letter constitutes an adequate or good faith attempt to resolve the discovery dispute at issue here. In particular, this 1/20/2026 meet-and-confer letter concludes with the following:

Please serve amended [sic] responses no later than five (5) court days from the date of this letter. [¶] If Karma does not fully comply by that deadline, Plaintiff will proceed with a motion to compel further responses and for sanctions, without further notice, and will seek all relief available under the Code of Civil Procedure, including monetary and evidentiary sanctions. (Singer Decl., Ex. E, p.2) (bold in original; underline added for emphasis).)

The Court finds that the unilateral demand for defendant Karma Apartments to provide “amended [sic] responses” within just “five (5) court days” to be not only unreasonably

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00334089-CU-BC-GDS: Latonia Vaughan vs. Karma Apartments 07/28/2026 Hearing on Motion to Compel Further Responses to Insurance Discovery in Department 16D

short but also unjustified under the circumstances, thereby demonstrating that plaintiff was motivated more by a desire to have defendant capitulate to her demands than to engage in a good faith, meaningful discussion intended to resolve the discovery dispute, or at least narrow its scope. This conclusion is bolstered by the fact plaintiff’s letter further specifies she intends to proceed with a motion to compel “without further notice,” thereby indicating plaintiff’s complete disregard for §2016.040(a)’s requirement that a motion to compel further responses not be filed unless the moving party can demonstrate “a reasonable and good faith attempt to informally resolve each issue presented by the motion.” (Underline added for emphasis.)

Because the plaintiff has failed to comply with the letter and the spirit of this statute, the Court will deny the present motion to compel in its entirety on this additional ground.

In light of the foregoing, the Court need not proceed further, but it does so in order to identify another independent ground for denial of this motion. Based on the opposing declaration by attorney Singer and the exhibits attached thereto, plaintiff propounded to defendant Karma Apartments in October 2025 a set of interrogatories which asked the latter to provide the name of each insurer “that may be liable [sic] to satisfy all or part of a judgment in this action or to indemnify you for payments made to satisfy the judgment” (Singer Decl., Ex.

A, p.2:10-12) and in a verified response thereto, defendant Karma Apartments in November 2025 stated, “no insurance company may be liable to satisfy all or part of a judgment in this action or to indemnify Defendant Karma Apartments LLC for payments made to satisfy the judgment” (Id., Ex. B, p.5:9-11). Thus, aside from the fact that plaintiff subsequently propounded additional Special Interrogatories and Requests for Production relating to defendant Karma Apartments’ insurance coverage, the opposition maintains that there is no additional insurance information which defendant Karma Apartments can provide in response to the Special Interrogatories and Requests for Production at issue in this motion.

Under these circumstances, this Court concludes that no further responses to plaintiff’s Special Interrogatories and/or Requests for Production are warranted.

For the reasons explained above, plaintiff’s motion to compel defendant Karma Apartments’ further responses to “Insurance Discovery” is DENIED in its entirety.

Moving plaintiff to provide notice of this ruling and file proof of service of same within five (5) court days.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC Rule 3.1312.)