Motion to Compel Further Discovery Responses
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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 22CV010715: BROUSSARD vs THERMO FISHER SCIENTIFIC, INC., A DELAWARE CORPORATION, et al. 06/03/2026 Hearing on Motion to Compel Further Discovery Responses filed by GERALD BROUSSARD (Plaintiff) CRS# 612712087644 in Department 17 Tentative Ruling - 06/01/2026 Chad A. Stegeman The Motion to Compel Further Discovery Responses filed by GERALD BROUSSARD on 04/03/2026 is Granted in Part. The Motion of Plaintiff Gerald Broussard (Plaintiff) to Compel Further and Monetary Sanctions as to Defendants Thermo Fisher Scientific Inc. (TFS) and Ryan Minobe (collectively Defendants) is GRANTED IN PART.
It is GRANTED as to SPROGS 4, 5, and 12 as to TFS; it is DENIED as to SPROG 14. Sanctions are denied. PROCEDURAL DEFECTS In lieu of an Opposition, Defendants Thermo Fisher Scientific Inc. and Ryan Minobe filed a joint Response to Plaintiffs Motions to Compel Further Responses asserting that they would file supplemental responses to the discovery at issue by May 26, 2026 prior to the hearing. (Response, p. 1:22-24; Hsueh Decl., ¶ 5.) On May 26, 2026, Plaintiff filed a Reply stating that neither Defendant supplemented their responses by said deadline. (Reply, p. 2:2-5.)
Although the response is not an Opposition, Plaintiff does not offer a declaration in support of his position in his Reply.
LEGAL STANDARD Where the party propounding written discovery deems the responses unsatisfactory, the party may move to compel further responses. (Code Civ. Proc., § 2030.300.) Unless 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 of Civil Procedure § 2017.010.)
The responding party bears the burden of justifying any objection or failure to fully respond to an interrogatory. (Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.) DISCUSSION As an initial matter, it is unclear what the subject of this motion is due to the discrepancy in the Memorandum of Points and Authorities and Separate Statement in identifying the discovery requests at issue. From the Notice of Motion and MPA, the Motion appears to concern both Defendants; for TFS, SPROGS 4, 5, 12 and 14, and FROGS-Employment 204.2, 204.5, 209.2 and 214.2, as well as the RFPs in the concurrent Motion to Compel Further RFPs; and for Mr.
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Minobe, RFPS 9, 10, 12, and 15. However, the Separate Statement only addresses the SPROGS for TFS. Plaintiff also does not include any responses to any of the discovery requests in counsel’s supporting declaration, so the Court considers only the four SPROGS as at issue as identified in the Separate Statement.
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 22CV010715: BROUSSARD vs THERMO FISHER SCIENTIFIC, INC., A DELAWARE CORPORATION, et al. 06/03/2026 Hearing on Motion to Compel Further Discovery Responses filed by GERALD BROUSSARD (Plaintiff) CRS# 612712087644 in Department 17 Defendant fails to respond to SPROGS 4 and 5 altogether, and objects that the information is irrelevant, privileged, violates privacy rights, and that their scope is vague and overbroad. It is the responding partys obligation to provide answers as complete and straightforward as the information reasonably available to the responding party permits. (CCP § 2030.220(a).) These are standard interrogatories that broadly seek to identify sources of information and the nature of their knowledge about Plaintiff’s claims. The Motion is GRANTED as to SPROGS 4 and 5.
For SPROG 12, Defendant fails to include the date and subject of the meetings Plaintiff seeks information about. The motion is GRANTED as to SPROG 12.
The response for SPROG 14 is appropriate. The Motion is DENIED as to SPROG 14.
For the foregoing reasons, the Motion to Compel Further is GRANTED IN PART and DENIED IN PART. Accordingly, sanctions are also denied as Defendant had substantial justification in opposing the motion as to its objections. 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. HOW DO I CONTEST A TENTATIVE RULING? THROUGH ECOURT Notify the Court and all the other parties no later than 4:00 PM one court day before the scheduled hearing, and briefly identify the issues you wish to argue through the following steps: 1.
Log into eCourt Public Portal 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 BY EMAIL Send an email to the DEPARTMENT CLERK and all the other parties no later than 4:00 PM one court day before the scheduled hearing. This will permit the department clerk to send invitations to counsel to appear remotely. BOTH ECOURT AND EMAIL notices are required.