Judge: Lee W. Tsao, Case: 22NWCV01666, Date: 2024-07-16 Tentative Ruling

Case Number: 22NWCV01666    Hearing Date: July 16, 2024    Dept: C

Matthew Luon, et al. vs American Honda Motor Co., Inc.

Case No.: 22NWCV01666

Hearing Date: July 16, 2024 @ 9:30

 

#3

Tentative Ruling

Plaintiffs Matthew Luon and Lisa Kim Luon’s Motion to Compel Deposition and Production of Documents is GRANTED.  Defendant’s Person Most Knowledgeable is ordered to sit for Deposition within 45 days, absent an agreement by the parties to a later date. 

The request for sanctions is DENIED. 

Plaintiff to give notice.

 

Plaintiffs Matthew Luon and Lisa Kim Luon (collectively “Plaintiffs”) sue Defendant American Honda Motor Co., Inc. (“Defendant”) after leasing a 2021 Honda Pilot, identified by VIN No.: 5FNYF5H22MB027020 (the “Subject Vehicle”).  Plaintiffs allege that nonconformities in the Subject Vehicle substantially impaired its use, value, and safety, and Defendant’s authorized service centers could not conform the Subject Vehicle to warranty within a reasonable number of presentations in violation of the Song-Beverly Warranty Act.

Plaintiffs move to compel the deposition of Defendant’s Person Most Knowledgeable (“PMK”) and the production of documents.

Pursuant to California Code of Civil Procedure section 2025.410, subdivision (a), “[i]f, after service of a deposition notice, a party to the action… without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed with it, or to produce for inspection any document… described in the deposition notice, the party giving the notice may move for an order compelling the deponent's attendance and testimony, and the production for inspection of any document… described in the deposition notice.” Code of Civil Procedure section 2025.410 provides that objections may be made to a deposition subpoena on the grounds that there are irregularities or errors in the process or form of the notice or subpoena. 

A motion made pursuant to Code of Civil Procedure section 2024.450 must (1) set forth specific facts showing good cause justifying the production for inspection of any document and (2) be accompanied by a meet and confer letter, “or, when the deponent fails to attend the deposition and produce the documents described in the deposition notice,… by a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance.” 

On April 13, 2023, Plaintiff noticed the deposition of Defendant’s PMK for May 3, 2023. (Castruita Decl., ¶ 4.) On April 27, 2023, Defendant served an objection to Plaintiff’s notice of deposition on the grounds that Plaintiff failed to meet and confer. (Id., ¶ 5.)

On May 5, 2023, Plaintiff served an amended notice of deposition for May 30, 2023. (Id., ¶ 21; Ex. 7.) On May 27, 2023, Defendant served an identical objection to Plaintiff’s amended notice of deposition. (Id., ¶ 8.)

On June 5, 2023, Plaintiff served a second amended notice of deposition for June 19, 2023. (Id., ¶ 9.) On June 14, 2023, Defendant served an identical objection to Plaintiff’s second amended notice of deposition. (Id., ¶ 10.)

On November 21, 2023, Plaintiff emailed Defendant for available dates before February 1, 2024. (Id., ¶ 12, Ex. 8.) Not having received a response, Plaintiff emailed Defendant on December 1, 2023 with three proposed dates and requested a response. (Id., ¶ 14, Ex. 9.) According to Plaintiff’s Counsel, no response was received as of December 14, 2023, the date this motion was filed. 

In Opposition to the motion, Defendant’s counsel states that on December 8, 2023, she offered January 26, 2024, to Plaintiff’s counsel to depose Defendant’s PMK in whatever case they chose. (Rein Decl., ¶ 12, Ex. K.) On December 10, 2023, Defendant’s counsel offered the additional date of January 11, 2024, to Plaintiff’s counsel for the deposition of Defendant’s PMK in whatever case they chose. (Ibid.) Plaintiff’s counsel made no subsequent attempts to meet and confer regarding the deposition of Defendant’s PMK. (Id., ¶ 14.)

In Reply, Plaintiff’s counsel states that the parties have agreed to depositions on July 22, 2024 and July 29, 2024. 

Accordingly Plaintiff’s Motion to Compel Deposition is GRANTED.  Defendant is ordered to produce its PMK for deposition within 45 days, absent an agreement by the parties to a later date. 

Sanctions

 

CCP¿section¿2025.450(c) provides, “(1) If a motion under subdivision (a) is granted, the court shall impose a monetary sanction . . . in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.”¿ (Id.,, § 2025.450(c).)¿ 

 

Plaintiffs have noticed three depositions of Defendant’s PMK, and Defendant has objected to each one.  With each objection, Defendant invited Plaintiffs to meet and confer regarding dates.  While Plaintiffs correctly point out that there is no meet and confer requirement before noticing a deposition, it is common knowledge that the availability of PMKs for deposition is limited.  Therefore, it should be of no surprise to Plaintiffs when the practice of unilaterally setting deposition dates, on just a few weeks’ notice, is met with negative results.  Defendant states that it offered Plaintiffs’ law firm two deposition dates in January 2024 for cases of their choosing, but it appears this case was not identified as one of them.  Under the circumstances here, no sanctions are warranted. 

 

Accordingly, the request for sanctions is DENIED. 

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