Judge: Lee W. Tsao, Case: 22NWV00697, Date: 2023-09-27 Tentative Ruling

Case Number: 22NWV00697    Hearing Date: September 27, 2023    Dept: C

Velasco v. Dyno Autosales

CASE NO.:  22NWCV00697

HEARING 9/27/23 @ 9:30 AM

#3

 

Plaintiff’s Motions are GRANTED in part and DENIED in part.  No sanctions.

Moving Party to give NOTICE.

 

Plaintiff Elizabeth Velasco (Plaintiff) moves for an order compelling further responses to her discovery requests.

Background

On August 11, 2022, Plaintiff filed a Complaint against Defendant Dyno Autosales, Inc. (Defendant) for alleged violations of the Song-Beverly Act for failure to repair or repurchase Plaintiff’s vehicle.

Legal Standard

CCP § 2031.310 allows a party to file a motion compelling further answers to document requests if it finds that the response is inadequate, incomplete, or evasive, or an objection in the response is without merit or too general.  The motion shall be accompanied with a meet and confer declaration.  (CCP § 2031.310(b).) 

Meet and Confer

The parties have adequately met and conferred.

Discussion

Form Interrogatories

Plaintiff seeks to compel further responses to Form Interrogatories Nos. 12.1 and 12.6. No. 12.1 seeks information regarding witnesses to the “INCIDENT” and 12.6 seeks information regarding reports made of the “INDICENT.” Defendant objected to the interrogatories on the grounds they were vague and ambiguous as to the term “INCIDENT.”

Defendant’s vague and ambiguous objection is proper because the interrogatories are vague and ambiguous as to the events Plaintiff intended to include in its definition of “INCIDENT.” This is a lemon law case and Plaintiff chose to define “INCIDENT” as the default: “INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” There are numerous events or circumstances that Plaintiff could intend to include in her definition spanning from the unknown manufacture date of the vehicle or purchase in November 2021 to Defendant’s rejection of Plaintiff’s repurchase request on July 30, 2022.  Thus, Defendant’s vague and ambiguous objections are sustained. Plaintiff’s request to compel for further responses to her Form Interrogatories is denied.

Special Interrogatories

Plaintiff seeks further responses to Special Interrogatories Nos. 7, 14-16, 20-22, and 34. Interrogatory No. 7 seeks information related to emissions testing. Nos. 14-16 seek information related to Defendant’s unreasonable or unauthorized use affirmative defense. Nos. 20-22 seek information related to Defendant’s maintenance affirmative defense. No. 34 seeks Defendant’s lemon law policies and procedures for the previous four years.

Interrogatory No. 7 is not relevant to Plaintiff’s claims because Plaintiff is not claiming that the vehicle failed to pass an emission check in her Complaint.

Defendant’s responses to Interrogatories Nos. 14-16 are insufficient. Defendant objected to these Interrogatories on the grounds that the terms “engine concerns”, “repair orders”, “unauthorized”, and “unreasonable use” were not defined and are therefore vague and ambiguous and the Interrogatories reference to “repair orders” made them unintelligible. Defendant’s vague and ambiguous and unintelligible objections are overruled because “where the question is somewhat ambiguous, but the nature of the information sought is apparent, the proper solution is to provide an appropriate response.” (Deyo v. Kilbourne (1978) 84 Ca.3d 771, 783.) Thus, Plaintiff’s requests to compel further responses to Interrogatories Nos. 14-16 are granted.

Similarly, Defendant’s responses to Interrogatories Nos. 20-22 are insufficient. Defendant objected to these Interrogatories on the grounds that “engine concerns” and “repair orders” are vague and ambiguous. However, Defendant’s vague and ambiguous and unintelligible objections are overruled because the terms are not so vague and ambiguous because “where the question is somewhat ambiguous, but the nature of the information sought is apparent, the proper solution is to provide an appropriate response.” (Deyo, supra, 84 Ca.3d 771, 783.) Thus, Plaintiff’s requests to compel further responses to Interrogatories Nos. 20-22 are granted.

Defendant is ordered to provide a further response to Interrogatory No. 36 because it seeks information within the scope of discovery. However, the Interrogatory is overbroad as to time. Defendant’s lemon law policies and procedures from the date of purchase to the date of the filing of Plaintiff’s lawsuit are within the scope of discovery because they are relevant to proving whether Defendant followed its policies and procedures as to Plaintiff’s vehicle. Therefore, Defendant is ordered to provide a further response to Interrogatory No. 34 with the limitation that it shall produce responsive documents published from the date of purchase to the date of filing.

Requests for Admission

Plaintiff seeks further responses to Requests for Admission Nos. 1-4, 6, 7, 9, 17, and 44.

Defendant is ordered to provide further responses to Requests Nos. 1-4 because the terms are not vague or ambiguous as they are defined under CCP § 1791.

Defendant is ordered to provide further responses to Requests Nos. 6 and 7 because Defendant must state whether it intends to contest whether an Implied Warranty of Merchantability arose from the sale and whether it disclaimed it.

Defendant is ordered to provide a further response to Request No. 9, 17, and 44 because the terms objected to are not so ambiguous “where the question is somewhat ambiguous, but the nature of the information sought is apparent, the proper solution is to provide an appropriate response.” (Deyo, supra, 84 Ca.3d 771, 783.)

Requests for Production

Defendant is ordered to provide further responses to Request Nos. 5, 6, 7, 18, and 35 because Defendant’s PMK identified several documents that were not produced which are responsive to these categories. Plaintiff identifies invoices for repairs and parts, Plaintiff’s file within Defendant’s DMS system, and records of repairs of Plaintiff’s vehicle. Further, Plaintiff brought his vehicle to Defendant for repair on two occasions and Defendant brought the vehicle to Mike’s Auto for repair. Thus, Defendant is ordered to provide a further response to Requests Nos. 5, 6, and 7.

Defendant is ordered to provide further responses to Requests Nos. 13, 30, 31, 32, 46, and 47. The Requests are overbroad as to time. However, Defendant’s lemon law policies and procedures from the date of purchase are within the scope of discovery because they are relevant to proving whether Defendant followed its policies and procedures as to Plaintiffs’ vehicle. Therefore, Defendant is ordered to provide further responses to Requests Nos. 16-27, 30, and 31 with the limitation that it shall produce responsive documents published from the date of purchase to present.

Defendant is ordered to provide further responses to Requests Nos. 15. The Requests are overbroad as to scope because they seek documents related to vehicles outside of California.  Therefore, Defendant is ordered to provide further responses to Requests Nos. 33 and 37 with the limitation that it shall produce responsive documents for California vehicles.

Defendant’s responses to Requests Nos. 26-28 and 36, 39 are insufficient because they fail to state that Defendant conducted a reasonably diligent search for responsive documents.

Sanctions

The court shall impose a monetary sanction against the party who unsuccessfully makes or opposes a motion to compel further responses to interrogatories or demand for production of documents unless the party subject to the sanction acted with substantial justification or the sanction would otherwise be unjust. (Code of Civ. Proc., §§ 2030.300, subd. (d), 2031.310, subd. (h), 2033.290, subd. (d).)  Given the mixed ruling, the court declines to impose sanctions. 

Accordingly, Plaintiff’s Motions are GRANTED in part and DENIED in part as set forth above. Defendant is to provide further responses within 30 days of this Order.