Motion to Compel Further Discovery Responses
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RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 05/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16
Tentative Ruling - 05/27/2026 Victoria Kolakowski
The hearing on Team Volkswagen of Hayward Corp.'s Motion to Compel Further Responses to document requests is further continued to June 9, 2026, at 2:30 p.m.
I.
Background
Soliman Mujadadi1 filed a First Amended Complaint against his former employers, including Team Volkswagen of Hayward Corporation (Team VW), alleging causes of action for religiousbased discrimination and wrongful termination in violation of public policy, among others. (Compl. ¶¶ 3, 4, 15179, Feb. 10, 2022.) In response, Team VW (and one other) filed a Second Amended Cross-Complaint against Soliman. (2d Am. Cross-Compl., Dec. 22, 2022.) As relevant here, Team VW alleged that it terminated Soliman partly because Soliman failed to perform his duties as a general manager, embezzled funds from Team VW to fund ice cream businesses, and traded stocks while on duty at Team VW. (Id. ¶¶ 982.)
In March 2025, Team VW served Soliman with a third set of document requests. (Prada Decl. Supp. Mot. ¶ 3, Oct. 24, 2025; see also id. Ex. 1 (providing requests).) In May 2025, Soliman served his objections. (Id. ¶ 4; see also id. Ex. 2 (providing initial responses).) The following month, Team VW sent Soliman a letter detailing what it perceived were meritless objections. (Id. ¶ 5; see also id. Ex. 3 (providing letter).) In August 2025, after a remote conference between the parties, Soliman provided further responses. (Id. Exs. 5, 5a.)
In late September 2025, Team VW served another letter detailing what it perceived remained meritless objections and deficient responses. (Id. ¶ 8; see also id. Ex. 6 (providing second letter).) The parties then attended an informal discovery conference in October 2025. (Id. ¶ 9.)
In October 2025, Team VW moved to compel further responses to document requests 1 through 4, and for a $2,560.00 sanction upon Soliman and his counsel. (Mot., Oct. 24, 2025.) Soliman opposed. (Oppn, May 6, 2026.)
II.
Discussion
On its own motion, the Court finds it appropriate and necessary for a referee to hear and determine any and all discovery motions and disputes relevant to discovery in the action and to report findings and make a recommendation thereon. (
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Here, two factors are present. First, this Motion is one of five currently before the Court. And while several of the motions have RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 05/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16 significant overlap, the Court must still review each filing independently. And second, the issues raised by the parties in their briefing show that this discovery dispute is only one in a continuum of discovery disputes, beginning in January 2025.
The Court has issued rulings that should have allowed the parties to better inform their discussions, adjust their positions, and resolve their discovery disputes. Still, the disputes continue. The Court infers that the parties are entrenched in their respective positions and that their discovery disputes are unlikely to be resolved without supervision.
Altogether, the parties discovery disputes have consumed significant amount of the Courts time and its limited (and underfunded) resources. (See id. at 106 (Where one or more of the above factors unduly impact the court's time and/or limited resources, the court is clearly within its discretion to make an appropriate reference.).) Accordingly, appointment of a referee is necessary because a referee will more effectivelyand, importantly, proactivelysupervise and manage the discovery proceedings, promptly hear discovery disputes, and issue recommendations to the Court.
The Court is inclined to order that the parties share the costs of the referee equally unless the referee finds that one party has unreasonably caused the specific discovery dispute before the referee.
The Court continues the hearing to permit the parties time to confer on whether they consent to appointment of a referee to hear and determine all discovery motions and disputes relevant to discovery in this action and the related actions.
The parties must further confer on the nomination of a qualified discovery referee. If the parties do not agree on a referee, the parties must follow the procedure provided by section 640 of the Code of Civil Procedure.
III. Orders The hearing on the Motion is continued to June 9, 2026, at 2:30 p.m.
The parties must submit a joint statement no later than June 1, 2026, addressing whether they consent to appointment of a discovery referee, and naming their referee if agreed upon by the parties or their proposed nominees if they do not agree. 1 The Court refers to Abdul, Jahid, and Soliman Mujadadi by their first name for claritys
sake as the Court is hearing several motions to compel responses that concern the brothers. The Court intends no disrespect.
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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
RG21103477: Mujadadi VS Team Volkswagen of Hayward Corporation 05/28/2026 Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 in Department 16 The Hearing on Motion to Compel Further Discovery Responses filed by Team Volkswagen of Hayward Corporation (Cross-Complainant) CRS# 869063298253 scheduled for 05/28/2026 is continued to 06/09/2026 at 02:30 PM in Department 16 at Rene C. Davidson Courthouse.
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If a party does not timely contest the foregoing Tentative Ruling and appear at the hearing, the Tentative Ruling will become the order of the court.
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