Judge: Joseph Lipner, Case: 22STCV35844, Date: 2023-09-07 Tentative Ruling

Case Number: 22STCV35844    Hearing Date: April 9, 2024    Dept: 72

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

DEPARTMENT 72

TENTATIVE RULING

            Plaintiff Carlos Drepic (“Plaintiff”) seeks to compel the deposition of a Person Most Qualified (“PMQ”) on all categories pursuant to a notice propounded to Defendant General Motors LLC (“Defendant”). 

The Court GRANTS Plaintiff’s motion in part as follows.  Defendant shall within 30 days produce a PMQ for deposition on categories 1-4, 7 and 10 of the deposition notice.  Except as so granted, the Court denies the motion.  Plaintiff shall give notice

Defendant agrees that the topics enumerated above are proper.  As to all other categories, Plaintiff has failed to file a separate statement in support of the motion.  Nor has Plaintiff filed any document explaining category-by-category why the other categories are supposedly proper notwithstanding Defendant’s objections.  The Court therefore does not compel the production of a PMQ as to any of the other topics.

Plaintiff argues in his reply that no separate statement is required.  The Court disagrees.  CRC 3.1345 subdivision (a) requires a separate statement for “[a]ny motion involving the content of a discovery request.”  This is such a motion.  Parties routinely file separate statements where a defendant objects to entire categories of PMQ deposition notices.  Moreover, Plaintiff’s failure to at least address the objections raised by Defendant on a category-by-category deprives the Court of an ability to rule on the substance of the other categories.