> ⚠️ **DRAFT — FOR FOX ROTHSCHILD REVIEW ONLY. DO NOT SERVE AS-IS.** > Starting template prepared for the client. Counsel must (1) confirm/replace every bracketed item, (2) tailor objections to Panda's *actual* Set One document production, (3) choose the correct compliance/inability/objection response under CCP § 2031.210, (4) prepare a privilege log for anything withheld, and (5) serve. Response due **~30 days from 7/30/2026 service (≈ early Sept. 2026; email adds ~2 court days)**. --- JACK I. SIEGAL (SBN [___]) jsiegal@foxrothschild.com T.M. BROWN (SBN [___]) FOX ROTHSCHILD LLP 345 California Street, Suite 2200 San Francisco, CA 94014 T: 415.364.5540 F: 415.391.4436 Attorneys for Plaintiff PANDA SOLUTIONS, LLC ## SUPERIOR COURT OF THE STATE OF CALIFORNIA ## COUNTY OF MONTEREY --- **PANDA SOLUTIONS, LLC,** a Washington limited liability company, Plaintiff, v. **PRO MECHANICAL SERVICES INC.,** a Washington corporation; RSP HOLDINGS, INC., a California corporation; ALCAZAR HEATING AND AIR CONDITIONING, LLC, a California limited liability company; and DOES 1 through 20, inclusive, Defendants. Case No.: **25CV001352** **PLAINTIFF PANDA SOLUTIONS, LLC'S RESPONSES TO DEFENDANT PRO MECHANICAL SERVICES, INC.'S SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS** Assigned for all purposes to Hon. Carrie M. Panetta, Dept. 14 Action Filed: March 12, 2025 Trial Date: September 28, 2026 --- **PROPOUNDING PARTY:** Defendant PRO MECHANICAL SERVICES, INC. **RESPONDING PARTY:** Plaintiff PANDA SOLUTIONS, LLC **SET NUMBER:** Supplemental Plaintiff PANDA SOLUTIONS, LLC ("Plaintiff") responds to the Supplemental Request for Production of Documents of Defendant PRO MECHANICAL SERVICES, INC. ("Defendant") pursuant to Code of Civil Procedure §§ 2031.050 and 2031.210 as follows: ### PRELIMINARY STATEMENT These responses are made solely for purposes of this action and are based on documents reasonably available to Plaintiff as of this date after a diligent search and reasonable inquiry. Discovery and investigation are ongoing. Plaintiff reserves the right to supplement or amend these responses and its production as additional responsive documents are located. A response that Plaintiff will comply is not an admission that responsive documents exist or that any document is relevant or admissible. ### GENERAL OBJECTIONS Incorporated by reference into each response below: 1. Plaintiff objects to each request to the extent it seeks documents protected by the attorney-client privilege, the attorney work-product doctrine (CCP §§ 2018.010–2018.030), or any other privilege or protection. Privileged documents will be withheld and, where required, identified on a privilege log. Any inadvertent production is not a waiver (CCP § 2031.285 / Evid. Code § 912). 2. Plaintiff objects to the extent any request seeks documents constituting or reflecting expert opinion, expert communications, or the substance of expert testimony, as premature under CCP § 2034.010 et seq. Such materials will be disclosed only as required by the expert-disclosure statutes and any court order. 3. Plaintiff objects to each request to the extent it is overbroad, unduly burdensome, oppressive, vague, or ambiguous, or seeks documents not relevant to the subject matter and not reasonably calculated to lead to the discovery of admissible evidence. 4. Plaintiff objects to the extent any request seeks documents equally available to Defendant, already in Defendant's possession, custody, or control, or obtainable from public sources or other parties. 5. Plaintiff objects to the extent any request seeks documents not in Plaintiff's possession, custody, or control. 6. Plaintiff objects to the extent the supplemental demand exceeds the scope permitted by CCP § 2031.050. Subject to and without waiving the foregoing, Plaintiff responds: ### RESPONSE TO SUPPLEMENTAL REQUEST NO. 1 Plaintiff incorporates the Preliminary Statement and General Objections. Subject to and without waiving those objections, and pursuant to CCP § 2031.220: > **[COUNSEL — SELECT / EDIT ONE:]** > > **(a) Statement of compliance (with new documents):** Plaintiff will comply with this demand in whole. Plaintiff will produce all non-privileged documents in its possession, custody, or control that are responsive to Defendant's Request for Production of Documents, Set One, and that have come into existence, been created, or been located since Plaintiff's prior production. Production will be made at [location / electronically] at a mutually convenient time on or before [date]. Privileged responsive documents, if any, will be withheld and identified on a privilege log. > > **(b) No further responsive documents:** Plaintiff has conducted a diligent search and reasonable inquiry and represents that, other than documents already produced in response to Set One and any documents withheld on the basis of privilege (identified on Plaintiff's privilege log), Plaintiff is not in possession, custody, or control of additional responsive documents. Plaintiff will supplement if further responsive documents are located. --- ### EVIDENCE-PRESERVATION NOTE (internal — not part of served response) Given RSP Holdings' **spoliation** affirmative defense, confirm before responding that Panda has preserved and can account for: the affected crops (or their documented condition/disposal), the mechanical/HVAC equipment at issue, environmental/sensor and control-system data, maintenance and service records, and all related communications. Document chain of custody. Coordinate any inspection with counsel. --- *As to objections:* Dated: __________, 2026 FOX ROTHSCHILD LLP By: _______________________________ Jack I. Siegal Attorneys for Plaintiff PANDA SOLUTIONS, LLC *(Verification required if the response contains a statement of compliance or representation of inability to comply — CCP § 2031.250. Proof of service to be attached per the parties' e-service agreement, CCP § 1010.6.)*