Judge: William A. Crowfoot, Case: 24NNCV02597, Date: 2025-06-05 Tentative Ruling

Case Number: 24NNCV02597    Hearing Date: June 5, 2025    Dept: 3

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT

On January 24, 2025, plaintiff Juan Garcia (“Plaintiff”) filed this motion to compel defendant FCA US LLC’s (“Defendant”) compliance with its discovery responses pursuant to Code of Civil Procedure section 2031.320(a). Plaintiffs argue that Defendant failed to produce documents consistent with its responses to inspection demands, and requests sanctions in the amount of $2,400, to be imposed against Defendant and its attorneys of record.

On May 23, 2025, Defendant filed an opposition brief arguing that this motion was moot because the documents at issue were provided the day after this motion was filed. (Opp., p. 1.) Defendant argues against sanctions and submits a declaration from its attorney stating that the failure to produce documents was due to inadvertence. Defense counsel states that Plaintiff failed to adequately meet and confer before filing this motion because Plaintiff’s legal secretary sent a single email with an attachment of a 19-page meet and confer letter on December 4, 2025, which counsel missed, and faults Plaintiff for failing to follow-up on the matter. (Rafter Decl., ¶¶ 5-6.) Defense counsel points out that although the parties were communicating to schedule a deposition, Plaintiff’s counsel never raised the issue of the document production during those interactions or the meet and confer letter. (Rafter Decl., ¶¶ 8-10.)

Given that the documents were produced the next business day after this motion was filed, and the parties successfully scheduled a deposition, there does not seem to be a pattern of obstructive conduct. Instead, if Plaintiff had made a more earnest attempt to follow up on Defendant’s document production, it appears this motion could have been easily avoided. Therefore, imposing sanctions under these circumstances would be unjust and the request for sanctions is DENIED.

In conclusion, Plaintiff’s motion is DENIED in its entirety.

Dated this 5th day of June 2025

Parties who intend to submit on this tentative must send an email to the Court at ALHDEPT3@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org. Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter. Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue. If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar.