Judge: John J. Kralik, Case: 22BBCV00513, Date: 2023-11-03 Tentative Ruling

Case Number: 22BBCV00513    Hearing Date: November 3, 2023    Dept: NCB

 

Superior Court of California

County of Los Angeles

North Central District

Department B

 

 

brianna l. rangel,

                        Plaintiff,

            v.

 

general motors llc,

                        Defendant.

 

  Case No.:  22BBCV00513

 

  Hearing Date:  November 3, 2023

 

[TENTATIVE] order RE:

motion for summary judgment or in the alternative summary adjudication

 

BACKGROUND

A.    Allegations

Plaintiff Brianna L. Rangel (“Plaintiff”) alleges that on November 30, 2021, she purchased a 2017 Chevrolet Tahoe.  The action arises out of the warranty and repair obligations of Defendant General Motors LLC (“Defendant” or “GM”) in connection with the vehicle Plaintiff purchased and for which Defendant issued a written warranty.  The warranty was not issued by the selling dealership.  Plaintiff alleges that the vehicle was delivered to Plaintiff with serious defects and nonconformities to warranty, including structural, engine, electrical, and suspension system defects. 

The complaint, filed on July 14, 2022, alleges causes of action for: (1) violation of Song-Beverly Act – breach of express warranty; (2) violation of Song-Beverly Act – breach of implied warranty; and (3) violation of Song-Beverly Act § 1793.2.

B.     Motion on Calendar

On August 21, 2023, Defendant filed a motion for summary judgment in its favor and against Plaintiff.  In the alternative, Defendant moves for summary adjudication on the following issues:

·         Issue 1: Plaintiff’s 1st and 3rd causes of action fail as a matter of law because Plaintiff did not buy the vehicle as a “new motor vehicle” and since she bought the vehicle, she has only presented it once for a repair, which is insufficient for a breach of express warranty claim under the Act.

·         Issue 2: Plaintiff’s 2nd cause of action fails as a matter of law because Plaintiff bought the vehicle used and Defendant was not a “distributor or retail seller of used consumer goods in [the] sale” of the used vehicle to Plaintiff.

On October 20, 2023, Plaintiff filed opposition paper. 

On October 27, 2023, Defendant filed reply papers.   

EVIDENTIARY OBJECTIONS

            With the reply papers, Defendant submitted evidentiary objections to Plaintiff’s evidence submitted with the opposition brief.  The Court rules as follows:

·         Declaration of Plaintiff’s counsel Siyun Yang: Objection nos. 1 (a part of paragraph 4), 4 (a part of paragraph 6), and 12 (a part of paragraph 26) are sustained as counsel’s statements are argument, as opposed to evidence.  Objection nos. 2-3 (paragraph 5), 6 (a part of paragraph 11), and 14 (a part of paragraph 42) are sustained as hearsay. Objection nos. 4 (to paragraph 10), 7 (a part of paragraph 12), 8 (a part of paragraph 13), 9 (a part of paragraph 14), 10 (paragraph 15), 11 (paragraph 20), and 13 (a part of paragraph 28) are overruled. 

·         Declaration of Plaintiff Brianna Rangel: Objection nos. 15-17 regarding portions of paragraphs 4, 5, and 6 are sustained as hearsay statements. 

DISCUSSION

Defendant GM moves for summary judgment or, alternatively, summary adjudication, on the grounds that: (1) the breach of express warranty claims (1st and 3rd causes of action) fail because Plaintiff bought the vehicle used and she only presented it once for repairs, which is insufficient for the Song-Beverly Act; and (2) the breach of implied warranty claim (2nd cause of action) fails because Plaintiff did not buy the vehicle from Defendant. 

A.    Plaintiff’s Request for Continuance pursuant to CCP § 437c(h), Request for Leave to Amend, and Request for a Stay

Preliminarily, the Court addresses Plaintiff’s requests for a continuance of the motion, for leave to amend the complaint, and to stay the action. 

First, Plaintiff requests relief pursuant to CCP § 437c(h), arguing that it is necessary for Plaintiff to conduct further essential discovery of Defendant’s special warranty coverages; Defendant and AutoNation’s inability to eliminate the defects/nonconformity up to warranty within the reasonable number of attempts, thereby constituting a breach and warranting restitution; depositions regarding representations made by Defendant’s authorized repair facilities’ repair technicians and personnel; and declaratory statements made by James Oak, its Customer Resource Technical manager, regarding new special warranty coverages that was issued for the subject vehicle.  (Yang Decl., ¶¶8-25.) 

CCP § 437c(h), “mandates a continuance of a summary judgment hearing upon a good faith showing by affidavit that additional time is needed to obtain facts essential to justify opposition to the motion.” (Cooksey v. Alexakis (2004) 123 Cal.App.4th 246, 253–254; CCP § 437c(h) [“[i]f it appears from the affidavits submitted in opposition to a motion for summary judgment or summary adjudication, or both, that facts essential to justify opposition may exist but cannot, for reasons stated, be presented, the court shall deny the motion, [or] order a continuance to permit affidavits to be obtained or discovery to be had, or make any other order as may be just”].)  “Continuance of a summary judgment hearing is not mandatory, however, ... when the submitted affidavit fails to make the necessary showing under [Code of Civil Procedure] section 437c, subdivision (h).” (Cooksey, supra, 123 Cal.App.4th at p. 254.) The necessary showing is: “(1) the facts to be obtained are essential to opposing the motion; (2) there is reason to believe such facts may exist; and (3) the reasons why additional time is needed to obtain these facts.” (Wachs v. Curry (1993) 13 Cal.App.4th 616, 623 abrogated on other grounds by Marathon Entertainment, Inc. v. Blasi (2008) 42 Cal.4th 974, 987, fn. 6.) In connection with the third requirement, “[t]here must be a justifiable reason why the essential facts cannot be presented. An inappropriate delay in seeking to obtain the facts may not be a valid reason why the facts cannot then be presented.” (Cooksey, supra, 123 Cal.App.4th at p. 257.) Thus, a majority of courts have held “that lack of diligence may be a ground for denying a request for a continuance of a summary judgment motion hearing.” (Id.)

Plaintiff provides the declaration of counsel Siyun Yang in support of the request for a continuance.  However, Plaintiff’s counsel’s declaration does not address what facts to be obtained are essential to opposing the motion.  Instead, Plaintiff’s declaration appears to cite to and rely on the documents that Plaintiff already has to support Plaintiff’s position in opposition to the motion.   Plaintiff’s counsel states that “the Court should continue the MSJ hearing and Trial if [it] finds that further information and discovery is necessary for a determination of the instant motion” (Yang Decl., ¶23), but this request improperly puts the burden on this Court to determine if a continuance is proper based on speculative evidence the Court does not know about.  The Court declines to continue the hearing on the motion for summary judgment.  Plaintiff has not shown what discovery efforts are still underway, such as scheduled depositions that could not be heard prior to filing the opposition to this motion or whether Defendant has stonewalled discovery.  Further, this action was commenced on July 14, 2022 and the Jury Trial is set for December 4, 2023; as far as the Court can tell, there are no discovery motions on calendar and there has not been no trial continuance to accommodate discovery matters.   Nothing suggests that the additional discovery Plaintiff seeks could not have been obtained sooner with reasonable diligence. 

In addition, as explained below, the known facts present an issue of law to the Court that cannot be cured by additional discovery regarding the repair history. The vehicle was sold to Plaintiff as a used vehicle, and no amount of discovery will change that fact.

CCP § 437c(h) is intended “ ‘[t]o mitigate summary judgment's harshness’ ” (Frazee v. Seely (2002) 95 Cal.App.4th 627, 634) “for an opposing party who has not had an opportunity to marshal the evidence.” (Mary Morgan, Inc. v. Melzark (1996) 49 Cal.App.4th 765, 770.) Plaintiff appears to have had ample opportunity to conduct discovery and there does not appear to be any issues with discovery delays. 

Second, Plaintiff seeks a stay in the matter pending the California Supreme Court’s review of the case Rodriguez v. FCA US, LLC (2022) 77 Cal.App.5th 209.  The Court denies the request for a stay.  While the California Supreme Court has granted review of Rodriguez, the Supreme Court declined to de-publish the Rodriguez opinion and stated that the Court of Appeal’s Rodriguez case “may be cited …  for its persuasive value….”  (Rodriguez v. FCA US (Cal. 2022) 295 Cal.Rptr.3d 351.)  As such, this case can only be cited for its persuasive value. (Cal. Rules of Court, rule 8.1115(e)(3).) The Court will consider Rodriguez, but does not believe that further decisions in that case will be decisive in this case.

Third, Plaintiff seeks leave to file a first amended complaint (“FAC”) to add allegations to reflect a prior lease, showing that Plaintiff was the sole and first owner of the subject vehicle prior to her option to purchase the vehicle.  The request for leave to file an FAC is denied.  Plaintiff has not stated the basis for why she did not include allegations about the lease or her prior repair attempts (before purchasing the vehicle) earlier in the action.  Plaintiff was the party with the best knowledge of these facts as Plaintiff was the party who signed any lease prior to the sales contract.  Even if Plaintiff were to bring a motion under CCP § 576 or CRC Rule 3.1324, Plaintiff has not shown when the facts giving rise to the amended allegations were discovered and the reasons why the request for amendment was not made earlier.  In the complaint before the Court, Plaintiff alleged the transaction starting from the sales contract. This was a deliberate choice by Plaintiff and her counsel to litigate under this particular theory, as opposed to alleging a theory based on the lease.  The lease and the sales contract are separate transactions and Plaintiff chose to pursue this action on the latter transaction.  Although Plaintiff’s counsel states that this additional information was procured through discovery (Yang Decl., ¶34), these are not new facts that were at one time unknown to Plaintiff and later discovered during discovery as Plaintiff was the one that leased the vehicle initially and brought the car for repairs prior to purchasing the vehicle.  The Court will not now allow Plaintiff to amend the complaint to allege an alternate theory solely as a mechanism to avoid summary judgment in this action. 

Plaintiff’s request for a continuance is denied.  Plaintiff’s request to stay the action until the Supreme Court reviews the Rodriguez case is denied.  The Court finds that it may rely on Rodriguez as the Supreme Court declined to de-publish the case and stated that it may be cited for persuasive authority.  Finally, the request for leave to amend the complaint is denied.   

The Court will address the substantive merits of the motion for summary judgment.

B.     1st and 3rd causes of action for breach of express warranty

            Defendant moves for summary adjudication on Plaintiff’s 1st and 3rd causes of action, alleging breach of express warranty and violation of Civil Code § 1793.2.  Defendant argues that Plaintiff’s claims fail as a matter of law because Plaintiff did not buy the vehicle as a “new motor vehicle.”

“ ‘A plaintiff pursuing an action under the [Song-Beverly] Act has the burden to prove that (1) the vehicle had a nonconformity covered by the express warranty that substantially impaired the use, value or safety of the vehicle (the nonconformity element); (2) the vehicle was presented to an authorized representative of the manufacturer of the vehicle for repair (the presentation element); and (3) the manufacturer or his representative did not repair the nonconformity after a reasonable number of repair attempts (the failure to repair element).’ ”  (Donlen v. Ford Motor Co. (2013) 217 Cal.App.4th 138, 152.)  The statutory language states:

“New motor vehicle” includes the chassis, chassis cab, and that portion of a motor home devoted to its propulsion, but does not include any portion designed, used, or maintained primarily for human habitation, a dealer-owned vehicle and a “demonstrator” or other motor vehicle sold with a manufacturer’s new car warranty....

(Civ. Code, § 1793.22(e)(2) [emphasis added].)

In making its arguments, Defendant relies on the Court of Appeal case in Rodriguez v. FCA US, LLC (2022) 77 Cal.App.5th 209 and distinguishes Jensen v, BMW of North America, Inc. (1995) 35 Cal.App.4th 112.  In opposition, Plaintiff argues that Rodriguez is distinguishable and should not be considered in light of the California Supreme Court’s review.  Plaintiff argues that Jensen governs, which held that cars sold with a balance remaining on the manufacturer’s warranty constitute a “new motor vehicle” under the Song-Beverly Act.

In Rodriguez, the “sole issue in the case [was] whether the phrase ‘other motor vehicle sold with a manufacturer’s new car warranty’ covers sales of previously owned vehicles with some balance remaining on the manufacturer’s express warranty.” (Rodriguez, supra, 77 Cal.App.5th at 215.)  The plaintiff in Rodriguez purchased a used truck from a third-party used car dealership that had 55,000 miles on it. The plaintiff did not purchase any additional warranties, though the original powertrain warranty was still in effect at the time of purchase. (Id.) The trial court granted the vehicle manufacturer’s motion for summary judgment because the vehicle was “used.”

The Court of Appeal affirmed the order, finding that the statutory text and legislative history supported its reasoning that a used vehicle with some balance of the original warranty was not a “new motor vehicle” under the Act.  (Id. at 219-223.)  Specifically, the Rodriguez Court reasoned that section 1793.22(e)(2) referred to a list of “two vehicles (dealer-owned vehicles ‘and’ demonstrators) followed by an adjectival clause qualifying or describing those vehicles.”  (Id. at 220.)  It explained that the lack of a comma in the phrase “dealer-owned vehicle and a ‘demonstrator’ or other motor vehicle sold with a manufacturer’s new car warranty” suggested that the latter phrase “or other motor vehicle” was “intended to function as a catchall provision to cover a narrow class vehicle – the previously driven, but basically new (i.e., not previously sold) car.” (Id.) 

The Court of Appeal further noted that it was unclear whether the third-party dealership issued any warranties to plaintiffs, “but that would be the only way they could seek a refund or replacement under the Act.” (Id. at 223.) The Court concluded “that the phrase ‘other motor vehicles sold with a manufacturer’s new car warranty’ refers to cars sold with a full warranty, not to previously sold cars accompanied by some balance of the original warranty.” (Id. at 225.)

The Rodriguez court discussed Jensen, supra, 35 Cal.App.4th 112, and emphasized that “Jensen involved a lease by a manufacturer-affiliated dealer who issued a full new car warranty along with the lease.”  (Rodriguez, supra, 77 Cal.App.5th at 223 [original italics].)  In distinguishing the earlier case, it concluded that Jensen was “correctly decided,” but its interpretation of section 1793.22 should be limited to the specific facts unique to that case: that the manufacturer had issued a full warranty at the time of sale. (Id. at 224.)

In Jensen, the plaintiff leased a vehicle from a manufacturer-affiliated dealer. The vehicle had been driven 7,565 miles. The salesman incorrectly represented that it “had been used as a demonstrator for the dealership,” when in fact it had obtained the car at an auction.   (Jensen, supra, 35 Cal.App.4th at 119.) The lease was issued with a “36,000-mile warranty on top of the miles already on the car.”  (Id.)  The Jensen court concluded that “the words of section 1793.22 are reasonably free from ambiguity” because “[t]he use of the word ‘or’ in the statute indicates ‘demonstrator’ and ‘other motor vehicle’ are intended as alternative or separate categories of ‘new motor vehicle’ if they are ‘sold with a manufacturer’s new car warranty.’” (Id. at p. 123.) The Court noted the “peculiar grammatical structure” of the section and further reviewed the amendments, documents relating to legislative proceedings, and the overall statutory scheme, concluding that “section 1793.22 includes cars sold with a balance remaining on the new motor vehicle warranty.”  (Id. at 123, 126.)  The Court cited to the “Act’s purpose as a remedial measure” and to protect “‘any individual to whom the vehicle is transferred during the duration of a written warranty.’”  (Id. at 126.)  Jensen concluded that under section 1793.22, “cars sold with a balance remaining on the manufacturer’s new motor vehicle warranty are included within its definition of ‘new motor vehicle.’” (Id. at 123.) 

In contrast to Rodriguez, the Jensen Court did not emphasize the lack of a comma in the phrase “dealer-owned vehicle and a ‘demonstrator’ or other motor vehicle sold with a manufacturer’s new car warranty,” but instead focused on the word “or” to hold that this phrase created an additional category of “new motor vehicle.”  (Rodriguez, supra, 77 Cal.App.5th at 220.)  Thus, while Rodriguez concluded that the clause defined two additional types of vehicles as “new,” the Jensen Court concluded that the clause defined three: dealer-owned vehicles, demonstrators, and other vehicles sold with a manufacturer’s new car warranty.

Several other cases in the Fourth District have distinguished Jensen on similar grounds, which shows that the “other motor vehicle” provision in Civil Code, § 1793.22(e)(2) is not “reasonably free from ambiguity” (Jensen, supra, 35 Cal.App.4th at 123) as the Jensen Court suggests.  (See e.g., Kiluk v. Mercedes-Benz USA, LLC (2019) 43 Cal.App.5th 334, 340, n.4 [questioning Jensen’s broad holding that “every car sold with any portion of a new-vehicle warranty remaining is a new motor vehicle”]; Dagher v. Ford Motor Co. (2015) 238 Cal.App.4th 905, 923 [limiting Jensen to the facts in the case which involved a lease from the dealer, not a private party].)  However, this issue will be clarified soon with the California Supreme Court’s review of the Rodriguez case.  At least for the purposes of this motion, the Court will consider the persuasive value of Rodriguez, which discussed and distinguished Jensen based on the specific facts of the cases.  Further, as explained in Kiluk, the Court of Appeal found that, under section 1795.5, “[t]he same protections generally apply to sale of used goods accompanied by an express warranty, except that the distributor or retail seller is bound, as opposed to the manufacturer, and the duration of the implied warranty of merchantability is much shorter.” (Kiluk, supra, 43 Cal.App.5th at 336.)

In seeking to meet its initial burden, Defendant argues that Plaintiff bought the subject vehicle used, the warranty had already expired by mileage, and Plaintiff did not buy any new or additional warranty from Defendant for the used vehicle but instead purchased an optional service contract from a third-party Portfolio. 

Defendant presents the following facts.  Plaintiff purchased a 2017 Chevrolet Tahoe, which was designated as “USED” with 64,617 on November 30, 2021 from Community Chevrolet Company.  (Def.’s Fact 1-2; Mot. Evid. at Ex. A [Retail Installment Sale Contract].)  Defendant was not a party to the November 2021 sale of the subject vehicle to Plaintiff by Community Chevrolet Company.  (Def.’s Fact 3.)  When the vehicle was first delivered as a new vehicle, Defendant issued a New Vehicle Limited Warranty applicable to the vehicle with a bumper-to-bumper coverage for the earlier of 3 years or 36,000 miles and powertrain coverage for the earlier of 5 years or 60,000 miles.  (Id. at 4.)  The warranty’s bumper-to-bumper coverage and powertrain coverage expired by mileage before Plaintiff purchased the vehicle.  (Id. at 5.)  Defendant did not issue or provide any new or additional warranty coverage to Plaintiff or the vehicle when Plaintiff bought it used in November 2021.  (Id. at 6.) 

Defendant also argues that Plaintiff only presented the vehicle once for repair, such that the Act does not apply as there must be more than one repair attempt.  (Def.’s Fact 7; Mot. Evid. at Ex. D.) 

Based on the facts presented by Defendant, Defendant has upheld its initial burden in showing that Plaintiff purchased a vehicle that was used, or not a “new” vehicle under the Act.  In addition, Defendant has shown that Plaintiff did not purchase the vehicle with a full manufacturer’s car warranty and that Plaintiff’s vehicle at the time of purchase had mileage over and above the original warranty terms.  In addition, Plaintiff purchased additional coverage from a third party (Portfolio) as opposed to obtaining a full new car warranty from a manufacturer-affiliated dealer. 

As such, the burden shifts to Plaintiff to raise a triable issue of material fact.

Plaintiff argues that the subject vehicle was leased to Plaintiff with the manufacturer’s original warranty intact and that following up on the maturity of the lease, Plaintiff exercised her purchase option and executed a sales contract with Defendant’s authorized dealership, Community Chevrolet Company.  However, as discussed above with respect to Plaintiff’s request for leave to amend the complaint, Plaintiff is now essentially alleging and presenting an alternate set of facts that were not originally alleged by Plaintiff.  While Plaintiff argues that Defendant was aware of these facts, Plaintiff deliberately chose to limit the pleading of this action to facts starting from the date of purchase, as opposed to the earlier date of the lease of the vehicle.  It was not Defendant’s responsibility to frame the pleadings for Plaintiff’s benefit nor expand its summary judgment motion to cover issues not alleged in Plaintiff’s complaint.  As pointed out by Defendant in the reply brief: “plaintiff’s complaint does not address or concern anything that occurred during her lease; it concerns only what occurred after she bought the Tahoe used. (See complaint, ¶ 8 [alleging plaintiff bought the vehicle used].) Plaintiff filed this lawsuit alleging post-purchase claims under the Song–Beverly Consumer Warranty Act (Song–Beverly).”  (Reply at p.2.)  A summary judgment motion is framed by the pleadings based on the allegations of the complaint.  (AARTS Productions, Inc. v. Crocker Nat’l Bank (1986) 179 Cal.App.3d 1061, 1064–65.) 

Defendant’s motion properly addresses the pleadings as framed by Plaintiff, and the Court too will construe Plaintiff’s allegations as framed (and limited) by the allegations of the complaint.  Thus, Plaintiff’s attempts to raise triable issues of material fact by relying on a prior lease agreement—which was a separate transaction and written contract and the repair attempts during the lease period—will not be considered for the purposes of this motion or Plaintiff’s opposition arguments.  As such, Plaintiff has not raised triable issues of material fact on the 1st and 3rd causes of action.

Even if the Court were to consider the lease period, it may be that Plaintiff was the owner of a “new” vehicle at the time of the lease.  However, at the time of purchase, she opted to purchase a used vehicle, and that is the vehicle she owns today.  By the time of the sales contract, the vehicle was no longer new and the vehicle had reached a mileage of 64,617 miles, such that the bumper-to-bumper coverage (earlier of 3 years or 36,000 miles) and the powertrain coverage had already expired (5 years or 60,000 miles).  Plaintiff argues that she was provided special warranty coverages for the Air Conditioning Condenser (Combi-Cooler) Refrigerant Leak in July 2020 and Brake Assist Decreased Due to Vacuum Loss in October 2019, but these were prior to her purchase of the vehicle in 2021.  Further, Plaintiff argues that she was provided special coverage adjustments, but she has not shown how these amount to a full new car warranty. Unlike Jensen, Plaintiff’s vehicle at the time of purchase was over the mileage limit for the original warranties, plus Plaintiff was not provided a full new car warranty at the time of signing the sales contract.  

For these reasons, the Court finds that Plaintiff has not raised a triable issue of material fact in opposition to Defendant’s motion.  Accordingly, Defendant’s motion is granted as to the 1st and 3rd causes of action for breach of express warranty.

C.     2nd cause of action for breach of implied warranty

Next, Defendant moves for summary adjudication as to Plaintiff’s 2nd cause of action for breach of implied warranty under the Song–Beverly Act, arguing that it fails as matter of law because Plaintiff bought the vehicle used and Defendant was not a “distributor or retail seller of used consumer goods in [the] sale” of the used vehicle to Plaintiff.

In vehicle sales, the implied warranty of merchantability “means that the goods ‘[p]ass without objection in the trade under the contract description,’ and are ‘fit for the ordinary purposes for which such goods are used.’ ” (Brand v. Hyundai Motor Am. (2014) 226 Cal.App.4th 1538, 1545.) “[A] new car need not ‘be perfect in every detail’; rather, its implied merchantability ‘requires only that a vehicle be reasonably suited for ordinary use.’ ” (Id. at p. 1546.) A plaintiff must show that at the time of purchase “the product did not possess even the most basic degree of fitness for ordinary use.” (Mocek v. Alfa Leisure, Inc. (2003) 114 Cal.App.4th 402, 406.) For a vehicle, this means whether it was fit for driving and the “ordinary purpose of providing transportation.” (American Suzuki Motor Corp. v. Superior Court (1995) 37 Cal.App.4th 1291, 1296.) 

Defendant argues that Plaintiff cannot maintain this cause of action against a manufacturer where Plaintiff brought the vehicle used because only distributors and retail sellers can be liable for the breach of implied warranties in the sale of a used car.  (Nunez v. FCA US LLC (2021) 61 Cal.App.5th 385, 398 [“[I]n the sale of used consumer goods, liability for breach of implied warranty lies with distributors and retailers, not the manufacturer, where there is no evidence the manufacturer played any role in the sale of the used car to plaintiff.”]; id. at 399 [“[O]nly distributors or sellers of used goods—not manufacturers of new goods—have implied warranty obligations in the sale of used goods.”].)

As discussed above, Defendant has established in its initial burden that the subject vehicle was a used vehicle at the time Plaintiff purchased the vehicle from Community Chevrolet Company.  Thus, the burden shifts to Plaintiff to raise a triable issue of material fact.

For the reasons stated above, the Court finds that Plaintiff has not raised a triable issue.  In addition, to the extent that Plaintiff argues that Community Chevrolet Company is an authorized retail dealership, Plaintiff has not established this fact with evidence, other than conclusory declaration statements by Plaintiff and counsel.  (The Court notes that the opposition does not specifically address the 2nd cause of action.)

For these reasons, the Court finds that Plaintiff has not raised a triable issue of material fact in opposition to Defendant’s motion with respect to the 2nd cause of action.  Accordingly, Defendant’s motion is granted as to the 2nd cause of action for breach of implied warranty.

            Accordingly, summary adjudication is granted on the 2nd cause of action.

D.    Plaintiff’s Request for Sanctions against Defendant under CCP § 128.5(a)(D)(2)

In the opposition brief, Plaintiff requests sanctions against Defendant under section 128.5(a)(D)(2), arguing that Defendant should be sanctions for filing a frivolous motion for summary judgment.  Plaintiff argues that Defendant should have known about the multiple prior repair attempts and the underlying lease agreement, and that Defendant improperly argued that the vehicle was not “new” by omitting the prior lease from its arguments. 

In light of the ruling on this motion, Plaintiff’s request for sanctions is denied. 

CONCLUSION AND ORDER

Defendant General Motors, LLC’s motion for summary judgment is granted.  

Defendant is ordered to lodge with the Court and serve on Plaintiff a proposed judgment within ten (10) days and to provide notice of this order.

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