Judge: David A. Hoffer, Case: 30-2021-1197351, Date: 2022-08-15 Tentative Ruling

The Motion to Compel Further Responses to Plaintiff’s Special Interrogatories, Set One, filed on 5/17/22 by Plaintiff Sandy Yvonne Rodriguez (“Plaintiff”) is DENIED.

Plaintiff moves “to strike” HMA’s “meritless objections” and to compel Defendant Hyundai Motor America (“HMA”) to provide further responses to her Special Interrogatories (the “SROGs”), Set One to HMA, for SROG Nos. 4-7, and 20-29.

But the Opposition has shown that at least some of the objections are well-taken, while Plaintiff has not shown that further responses should be compelled here.

For SROG Nos. 4-7, Plaintiff asserts that no “facts” were stated in the supplemental responses at issue.  But those responses point to HMA’s response to Form Interrogatory 15.1, which Plaintiff failed to address in the Separate Statement. The Court thus cannot conclude, based on what Plaintiff  has presented, that HMA’s supplemental responses were deficient.

For SROGs 20-29, the interrogatories seek information beyond the scope of this Court’s CMO.  HMA has also shown that responding to these SROGS, at least for those concerning the “POWERTRAIN DEFECT,” would be unduly burdensome here.  (See Vedder Decl.,  ¶¶ 1-7, 14 – 15, 17, and 19-22.).

Despite this ruling, the court will expand the CMO limitations on PMK depositions from 3 categories to 10 (matching the current CMO issued by this court in Song- Beverly cases).  This expansion will permit the plaintiff to seek PMK depositions on some of the subjects listed in the final set of challenged interrogatories.

The Motion is therefore denied.

HMA’s Evidentiary Objections, filed as ROA 101, are SUSTAINED for Obj. Nos. 1 and 2, and 4-10 [foundation; hearsay], but otherwise OVERRULED.

Plaintiff’s Evidentiary Objections, filed as ROA 111, are SUSTAINED for Obj. No. 3 [legal opinion], but otherwise OVERRULED. 

Counsel for defendant is ordered to give notice of this ruling.