Judge: Elaine Lu, Case: 22STCV02933, Date: 2023-04-07 Tentative Ruling

Case Number: 22STCV02933    Hearing Date: April 7, 2023    Dept: 26

22STCV02933

On April 7, 2023, Counsel for the parties
participated in an informal discovery conference with the Court, at the
conclusion of which the parties agreed as follows:

            Within 45 days of today, Defendant will
voluntarily supplement its response to {Requests for Production, Set One,
numbers 16-32 and 45-46 and to produce responsive documents to RPDs 16-32 and
45-46.

            Both parties agree that the only
disputes that remain at issue are RPDs 37-41.

            Within 10 days of Defendant’s
voluntary supplementation of its responses, the parties are ordered to file a
joint statement reflecting that Defendant has done so.  For any motion to compel further in this
action that has been filed or will be filed in the future, the responding
party’s voluntary service of supplemental responses prior to the hearing will
moot all issues for those requests to which reponses have been supplemented except
for sanctions.  The parties are ordered
to meet and confer regarding sanctions and to file a joint statement within 10
days of the service of supplemental responses; the joint statement must advise
that supplemental responses have been served and advise whether the parties
have been able to resolve the sole remaining issue of sanctions.  In order to demonstrate that supplemental
responses have been served thereby mooting a pending motion to compel further,
the responding party must also file and serve a copy of the verified
supplemental responses no later than when the opposition is due.  If the moving party deems that the
supplemental responses remain deficient and/or non-code compliant, the moving
party must timely (within 45 days of service of the supplemental responses)
file and serve a new motion to compel further complying with all statutory
requirements, including a meet and confer regarding the supplemental responses
and a separate statement that includes all responses (original and
supplemental).  The moving party may
contact Department 26 to request a further informal discovery conference to
discuss the remaining disputes following the service of supplemental
responses.  The parties are ordered to
file a joint statement of items remaining in dispute no later than 5 days
before the further IDC.

            This stipulation was shared with all
Counsel on the Court’s tentative ruling website, and all Counsel stipulated in
open court that it accurately reflects the parties’ discussions.

            Plaintiff to give notice.