Judge: Melvin D. Sandvig, Case: 23CHCV01357, Date: 2023-10-30 Tentative Ruling

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Case Number: 23CHCV01357    Hearing Date: October 30, 2023    Dept: F47

Dept. F47

Date: 10/30/23

Case #22CHCV01357

 

MOTION TO COMPEL FURTHER RESPONSES

(Requests for Production of Documents, Set 1)

 

Motion filed on 7/7/23.

 

MOVING PARTY: Plaintiff Marcos Frias Solis

RESPONDING PARTY: Defendant General Motors LLC

NOTICE: ok

 

RELIEF REQUESTED: An order compelling Defendant General Motors LLC to provide further responses to Plaintiff’s Requests for Production, Set 1, numbers 27, 28, 29, 30, 31, 32, 37, 38 and 39 within 10 days.  Additionally, Plaintiff requests sanctions against Defendant in the amount of $2,845.00.

 

RULING: The motion is granted.  Further responses are due and sanctions are payable within 30 days. 

 

SUMMARY OF FACTS & PROCEDURAL HISTORY

 

This action arises out of Plaintiff Marcos Frias Solis’ (Plaintiff) purchase of a 2019 Chevrolet Silverado (the Vehicle) on 6/2/19.  Plaintiff contends he has presented the Vehicle to Defendant General Motors LLC’s (Defendant) authorized facilities on multiple occasions for repair of defects related to the brake system malfunction, transmission, transmission control module, torque converter, check engine light and other issues without success.  Plaintiff also contends that Defendant has refused to repurchase or repair the Vehicle.

 

On 12/12/22, Plaintiff filed this action against Defendant for violation of the Song-Beverly Act.  On 1/11/23, Plaintiff served Defendant with Requests for Production, Set 1.  (Brande Decl.).  On 2/14/23, Defendant served unverified responses.  Id. The responses included objections to Requests 27, 28, 29, 30, 31, 32, 37, 38 and 39.  Id. 

 

On 4/10/23, Plaintiff sent his first meet and confer correspondence to Defendant.  (Id., Ex.5).  Defendant did not respond, therefore, Plaintiff made further efforts.  (Id., Ex.6).  On 5/2/23, Defendant indicated that it would send Plaintiff verifications and responsive documents as soon as they were available.  Id.  After further follow-up, on 5/24/23, Plaintiff received the verifications.  Id.  On 5/30/23, Plaintiff made a further effort to meet and confer and requested a two-week extension of the deadline to file a motion to compel.  Id.  The request for an extension was granted; however, Defendant failed to meet and confer.  Id.

 

Therefore, on 7/7/23, Plaintiff filed and served the instant motion seeking an order compelling Defendant to provide further responses to Plaintiff’s Requests for Production, Set 1, numbers 27, 28, 29, 30, 31, 32, 37, 38 and 39 within 10 days.  Additionally, Plaintiff requests sanctions in the amount of $2,845.00 against Defendant.  Defendant has opposed the motion and Plaintiff has filed a reply to the opposition.

 

ANALYSIS

 

Plaintiff’s objections (numbers 1-10) to the declaration of Darshnik Meet Singh Brar are overruled. 

 

A party may obtain discovery regarding any matter, not privileged, that is relevant to the subject

matter involved in the action or to the determination of any motion made in the action, if the

matter itself is admissible or appears reasonably calculated to lead to the discovery of admissible

evidence. See CCP 2017.010.  Doubts as to relevance are generally resolved in favor of allowing discovery.  Colonial Life & Acc. Ins. Co. (1982) 31 C3d 785, 790.

 

CCP 2031.310(a) provides:

 

“On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply:

(1) A statement of compliance with the demand is incomplete.

(2) A representation of inability to comply is inadequate, incomplete, or evasive.

(3) An objection in the response is without merit or too general.”

 

The Court finds that Plaintiff adequately met and conferred before filing the instant motion. 

 

The documents sought are relevant to Plaintiff’s claims against Defendant under the Song-Beverly Act.  As such, Plaintiff has provided sufficient facts to establish the requisite good cause for production of the subject documents.  See CCP 2031.310(b)(1). 

 

The subject document requests (numbers 27-32 and 37-39) seek documents related to Defendant’s policies and procedures for how Defendant handles consumer warranty claims and repurchase requests.  Defendant has responded to the requests with various objections based on overbreadth, vagueness, ambiguity, relevance, burden, proprietary/trade secret information, attorney-client privilege and attorney work product. 

 

Whether or not documents responsive to the requests exist may provide information as to whether Defendant has a policy which violates the Song-Beverly Act and/or whether or not Defendant willfully violated the Song-Beverly Act when it refused to replace or repurchase Plaintiff’s vehicle.  See Oregel (1995) 90 CA4th 1094, 1104; Johnson (2005) 35 C4th 1191, 1198-1200; Kwan (1994) 23 CA4th 174, 186. 

 

Information regarding vehicles other than Plaintiff’s vehicle is relevant to the subject matter of this action as it could assist Plaintiffs in proving Defendant’s willful violation of the Song-Beverly Consumer Warranty Act.  Documents responsive to such requests may reasonably lead to the discovery of information as to the nature and duration of the defects, Defendant’s knowledge of the defects, and Defendant’s inability to repair the defects. 

 

Defendant’s objections lack merit and/or have not been properly supported.  As set forth above, the documents sought are relevant and/or could lead to the discovery of admissible evidence.  Therefore, the requests are not irrelevant or overbroad.  The requests are also not vague and/or ambiguous.  Defendant has also failed to establish that responding to any of the subject requests would be overly burdensome or oppressive.  To the extent that documents are being withheld on the basis of attorney-client privilege and/or work product doctrine, Defendant is required to provide a privilege log.  See CCP 2031.240(c).

 

Defendant has failed to establish that the documents sought contain confidential and/or propriety information and that dissemination of the information would result in injury.  To the extent that any of the requests actually seek confidential, proprietary and/or trade secret information, the Court finds that a the LASC Model Protective Order which Plaintiff indicates that he is amenable to entering will adequately protect Defendant’s interests.  (See Defendant’s Separate Statement, p.5:1-4; Reply p.5:8-10).    

 

The Court notes that Plaintiff indicates in the reply that despite Defendant’s representations to the contrary in the opposition, Defendant has not produced: (1) CA CEC Training Materials; (2) CAC and TAC spreadsheet; (3) Call Center Policies & Procedures; (4) Service Manual; (5) Service Policy & Procedure Manual; and (6) Standard Provisions of Dealer Agreement.  (See Brar Decl. ¶3; Opp. p.1:6-25; Brande Decl. ¶4).

 

The Court finds that Plaintiff is entitled to sanctions against Defendant for its failure to comply with its discovery obligations in the amount of $2,845.00.  CCP 2031.310(h); (Brande Decl. ¶9). 

 

CONCLUSION

 

Based on the foregoing, the motion is granted.  Further responses are due and sanctions are payable within 30 days.