Judge: Melvin D. Sandvig, Case: 22CHCV00999, Date: 2023-05-15 Tentative Ruling

Case Number: 22CHCV00999    Hearing Date: May 15, 2023    Dept: F47

Dept. F47

Date: 5/15/23

Case #22CHCV00999

 

MOTION TO COMPEL DEPOSITION & PRODUCTION OF DOCUMENTS

 

Motion filed on 3/2/23.

 

MOVING PARTY: Plaintiffs Julio Basulto and Leslie Reyes

RESPONDING PARTY: Defendant General Motors, LLC

NOTICE: ok

 

RELIEF REQUESTED: An order compelling the deposition of Defendant General Motors, LLC’s Person or Persons Most Qualified, with production of documents, within 30 days.  Additionally, Plaintiffs request an order imposing sanctions against Defendant in the amount of $2,952.22.

 

RULING: The motion is granted, in part, and denied, in part, as set forth below.

 

SUMMARY OF FACTS & PROCEDURAL HISTORY

 

The is action arises out of Plaintiffs Julio Basulto and Leslie Reyes’ (Plaintiffs) purchase of a 2021 Chevrolet Tahoe (the Vehicle) which was covered by Defendant General Motors, LLC’s (Defendant) express and implied warranties.  Plaintiffs contend that the Vehicle developed substantial defects related to the engine, electrical and other vehicle components which have not been adequately repaired, despite multiple attempts.  Defendant has refused Plaintiffs’ request to repurchase or replace the Vehicle.

 

As a result, on 10/27/22, Plaintiffs filed this action against Defendant for violation of the Song-Beverly Consumer Warranty Act.  On 11/21/22, Plaintiffs served Defendant with Notice of Deposition for Defendant’s Person Most Qualified.  (Kaufman Decl. ¶8, Ex.1).  On 12/14/22, Defendant served objections to the notice.  (Id. ¶9, Ex.2).  On 12/16/22, Plaintiffs’ counsel called Defendant’s counsel to meet and confer and also sent an email.  (Id. ¶10, Ex.3).  Defendant failed to respond; therefore, on 12/19/23, Plaintiffs served their 1st Amended Notice of Deposition of Defendant’s Person Most Qualified (1st Amended Notice) setting the deposition for 1/13/23.  (Id. ¶11, Ex.4).  Defendant did not serve any objections nor did Defendant appear for deposition on 1/13/23.  (Id. ¶12). 

 

On 3/2/23, Defendant filed and served the instant motion seeking an order compelling the deposition of Defendant’s Person or Persons Most Qualified, with production of documents, within 30 days.  Additionally, Plaintiffs request an order imposing sanctions against Defendant in the amount of $2,952.22.  Defendant has opposed the motion and Plaintiff has filed a reply to the opposition. 

 

 

 

ANALYSIS

 

CCP 2025.450 provides, in relevant part:

 

“(a) If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, 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, electronically stored information, or tangible thing 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, electronically stored information, or tangible thing described in the deposition notice.

 

(b) A motion under subdivision (a) shall comply with both of the following:

(1) The motion shall set forth specific facts showing good cause justifying the production for inspection of any document, electronically stored information, or tangible thing described in the deposition notice.

(2) The motion shall be accompanied by a meet and confer declaration under Section 2016.040, or, when the deponent fails to attend the deposition and produce the documents, electronically stored information, or things described in the deposition notice, by a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance.

 

. . .

 

(g)(1) If a motion under subdivision (a) is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) 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.”

 

Objections to a deposition notice must be served at least three calendar days before the date for which the deposition is scheduled.  See CCP 2025.410(a).  Defendant admits that it failed to serve any objections before the 1/13/23 deposition date set forth in the 1st Amended Notice claiming that the failure was the result of inadvertence and mistake.  (See Brar Decl. ¶6).  However, Defendant’s counsel does not state the dates on which it purportedly miscalendared the deposition date and its objections deadline.  Id.  Additionally, Defendant’s counsel fails to explain why Defendant did not try to resolve the issue upon discovering the miscalendaring error, why it did not serve objections based on the miscalendared deadline, or, minimally, upon receipt of the instant motion which was served on 3/2/23 rather than waiting until 2 months later to include objections to the 1st Amended Notice with the opposition to the motion which was filed and served on 5/2/23.  Id.  Further, Defendant cites no authority which allows it to interpose objections to a deposition notice approximately 4 months after its failure to appear at the deposition or produce responsive documents.  

 

Even if Defendant had timely served its objections to the 1st Amended Notice, the Court finds them to be without merit, especially considering Plaintiffs’ willingness  to execute a Protective Order.  Therefore, Defendant is ordered to produce its Person(s) Most Qualified with regard to the categories set forth in the 1st Amended Notice and to produce documents in response to the requests therein.  Counsel for the parties are ordered to meet and confer regarding the scheduling of the deposition so that it will take place within the next 30 days. 

 

Because Plaintiffs failed to meet and confer after Defendant failed to appear for deposition in response to the 1st Amended Notice, the Court finds that imposing sanctions under the circumstances would be unjust.  See CCP 2025.450(b)(2), (g)(1).

 

The Court notes that in violation of General Orders and court rules, Plaintiffs have failed to bookmark the declaration attached to the motion and Defendant has failed to bookmark the exhibits attached to the opposition and declaration submitted in support of the opposition.  See CRC 3.1110(f)(4); (5/3/19 First Amended General Order Re Mandatory Electronic Filing for Civil).  The parties are warned that failure to comply with court rules and orders in the future may result in matters being continued so that papers can be properly submitted, papers not being considered and/or the imposition of sanctions.