Judge: Cherol J. Nellon, Case: 25STCV02060, Date: 2025-05-21 Tentative Ruling

Case Number: 25STCV02060    Hearing Date: May 21, 2025    Dept: 14

#10

Case Background

This is a lemon law action.

On April 11, 2025, Plaintiffs Tizoc Restaurant, Inc. and Alejandro Cuevas filed their Complaint against Defendant General Motors, LLC (GM).

On April 3, 2025, Plaintiffs filed a First Amended Complaint (FAC).

On April 11, 2025, Defendant filed a motion for a protective order.

On May 8, 2025, Plaintiffs filed an opposition.

On May 14, 2025, Defendant filed a reply.

Instant Pleading

Defendant moves for a protective order which would allow Defendant to designate (1) warranty policies and procedure manuals and (2) Defendant’s policies and procedures used to evaluate customer requests for restitution or replacement as confidential.

Defendant’s motion for a protective order is DENIED.

Discussion

Code of Civil Procedure, section 2031.060 provides that “[w]hen an inspection, copying, testing, or sampling of documents, tangible things, places, or electronically stored information has been demanded, the party to whom the demand has been directed, and any other party or affected person, may promptly move for a protective order.” “The court, for good cause shown, may make any order that justice requires to protect any party or other person from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense,” including “[t]hat a trade secret or other confidential research, development, or commercial information not be disclosed, or be disclosed only to specified persons or only in a specified way.”  (Code Civ. Proc., section 2031.060, subd. (b)(5).)  

Here, Defendant moves for a protective order on the grounds that Code Civ. Proc., section 871.62(h) requires Defendant to make an initial disclosure of confidential policies, procedures, and training materials. Defendant contends its (1) warranty policies and procedure manuals and (2) Defendant’s policies and procedures used to evaluate customer requests for restitution or replacement are confidential.

In opposition, Plaintiffs argue that Code Civ. Proc., section 871.26 requires Defendant to produce preliminary materials without a protective order.

Code Civ. Proc., section 871.26 (b) provides that “Within 60 days after the filing of the answer or other responsive pleading, all parties shall, without awaiting a discovery request, provide to all other parties an initial disclosure and documents pursuant to subdivisions (f), (g), and (h).”

Here, the Court agrees with Plaintiffs that Code Civ. Proc., section 871.26 requires Defendant to produce preliminary materials without providing a procedure for a protective order. Defendant moves for this protective order under Code Civ. Proc., section 2031.060, which only applies to demands for inspection, copying, testing, or sampling of documents. This motion concerns the initial disclosure under Code Civ. Proc., section 871.26, which is not a demand for inspection of documents. Section 871.26 does not provide any procedure through which any party may seek a protective order or otherwise limit the disclosure. The Court finds that it is not authorized to grant a protective order as to the initial disclosure described in Code Civ. Proc., section 871.26. The motion for a protective order is DENIED.

Conclusion

Defendant’s motion for a protective order is DENIED.





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