Judge: Erick L. Larsh, Case: 2023-01306891, Date: 2023-07-20 Tentative Ruling

Plaintiff Aida Parvin’s Motion to Compel Further Responses to Requests for Production is CONTINUED to August 24 at 1:30 p.m.

The parties have not engaged in sufficient meet and confer regarding these motions. [See Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1293 [Discovery Act requires moving party to declare he or she has made a serious attempt to obtain an informal resolution of each issue; rule designed to encourage parties to work out their differences informally to avoid necessity for formal order, which lessens burden on court and reduces unnecessary expenditure of resources by litigants]

The parties  are ordered to meet/confer in person, by videoconference, or by telephone.  There are to be no texts, emails, or letters, except to confirm areas of agreement. 

          For the guidance of the parties, and without deciding on an issue raised by the parties’ papers, the Court gives following guidance:

•        Meet and confer efforts are to focus not only  on what documents will be produced, but also on the withdrawal of objections. Under guiding legal principles for discovery, the Court will view objections that “documents are equally available”, “compound, overbroad, vague and ambiguous and calls for documents that are not relevant to the subject matter” with skepticism. 

•        Attorney-client, attorney work product, and trade secrets objections should be limited to documents that really fall within the protection of the privilege or doctrine.  For any document claimed be privileged or work product, Land Rover is ordered to produce a privilege log.

•        With respect to Parvin, simply repeating her boilerplate argument for each request is not helpful to the Court.  Specific factual and legal reasons showing good cause for each request must be stated. 

•        The Court looks favorably on stipulated protective/confidentiality orders to facilitate discovery in this type of case.

No later than [9 court days before hearing, moving party’s counsel shall file and serve a supplemental declaration, not to exceed five pages, which shall (1) describe the parties’ attempts to meet and confer pursuant to this order, (2) identify each discovery request that remains in dispute, and (3) list all documents, by category, that have been produced. Any further responses served  shall be attached to counsel’s supplemental declaration.  The supplemental declaration shall be filed by both attorneys.

Failure to comply with this order may result in sanctions against the non-compliant party or their counsel pursuant to Code of Civil Procedure §177.5.