Judge: Michael Shultz, Case: 21CMCV00285, Date: 2023-12-19 Tentative Ruling

INSTRUCTIONS: If the parties wish to submit on the tentative ruling and avoid a court appearance on the matter, the moving party must:

1. Contact the opposing party and all other parties who have appeared in the action and confirm that each will submit on the tentative ruling.

2. No later than 4:00 p.m. on the court day before the hearing, call the Courtroom (310-761-4302) advising that all parties will submit on the tentative ruling and waive hearing; and

3. Serve notice of the Court's ruling on all parties entitled to receive service.

If this procedure is followed, when the case is called the Court will enter its ruling on the motion in accordance with its tentative ruling. If any party declines to submit on the tentative ruling, then no telephone call is necessary, and all parties should appear at the hearing. If there is neither a telephone call nor an appearance, then the matter may either be taken off calendar or ruled on. 

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Case Number: 21CMCV00285    Hearing Date: February 27, 2024    Dept: A

21CMCV00285 Augusto Barco-Robledo v. General Motors

Tuesday, February 27, 2024, at 8:30 a.m.

 

[TENTATIVE] ORDER GRANTING PLAINTIFF’S MOTION IN THE ALTERNATIVE FOR TERMINATING, ISSUE, AND/OR EVIDENTIARY SANCTIONS IN ADDITION TO MONETARY SANCTIONS.

 

I.        BACKGROUND

       The complaint alleges that Defendant issued a written warranty to Plaintiff in connection with Plaintiff’s purchase of a vehicle made and distributed by Defendant, General Motors, LLC (“GM”). The vehicle developed widespread defects that GM failed to repair within a reasonable number of attempts and refused to repurchase the vehicle. Plaintiff alleges violations of the Song-Beverly Consumer Warranty Act.

II.      ARGUMENTS

       Plaintiff argues that Defendant failed to comply with the Court’s initial order to produce a person most knowledgeable and documents at deposition. Defendant partially complied by responding to certain categories. Defendant also failed to comply with a second court order requiring Defendant’s compliance with the first order. Plaintiff files this third motion to impose the $500 per day sanction, compel Defendant’s compliance and alternatively, impose evidentiary, issue and/or terminating sanctions.

       In opposition, GM argues it produced a PMQ on January 23, 2024. Plaintiff sent one email stating the testimony was insufficient without making further attempts to meet and confer. GM contends it produced documents in compliance with the court’s order.

       In reply, Plaintiff argues that Defendant has blatantly disobeyed this court’s order by producing documents limited to certain categories, produced a witness with limited or no knowledge of the subjects at issue, and instructed the witness not to answer questions, all of which warrant an additional order to comply and imposition of sanctions.

III.    DISCUSSION

A.      Procedural background

       On September 15, 2022, the Court granted Plaintiff’s motion to compel Defendant’s further discovery responses (M.O. 9/15/22.)  Defendant was ordered to serve verified, code-compliant responses and production of documents within 10 calendar days of the court’s order and provide a privilege log where applicable. (Id.) Defendant’s request to limit the scope temporally and geographically was denied. (Id.)

       On July 27, 2023, the Court granted Plaintiff’s motion to compel the deposition of Defendant’s PMQ by June 13, 2023, “to testify on the topics identified in Plaintiff’s Amended Notice of Deposition within 30 days without limitation or condition.” (M.O. 7/27/23). Plaintiff had been attempting to take the deposition since January 25, 2022. (Id.)  

       On December 19, 2023, the court granted Plaintiff’s motion to compel Defendant’s compliance with the July 27, 2023, order requiring Defendant to produce a PMQ on categories identified in Plaintiff’s notice. (M.O. 12/19/23.) The court found that Defendant ignored the 30-day deadline to produce a witness, and instead offered “global” deposition dates to Plaintiff in this and other cases which resulted in undue burden, expense, and annoyance. The court declined to grant the alternative request for terminating, issue and /or evidentiary sanctions opting to impose less severe sanctions of $500 for each day that Defendant did not produce a witness after the 10th day. (Id.)

       The Court can impose sanctions, including issue, evidentiary or terminating sanction if a party or party-affiliated deponent fails to obey an order compelling attendance, testimony, and production. (Code Civ. Proc., § 2025.450.) In lieu of or in addition to, the Court can impose monetary sanctions.

B.      The January 23, 2024, PMQ Deposition

              The Court determined that Plaintiff’s document requests for internal investigations and analysis of the defects, and warranty and vehicle repurchase policies, procedures, and practices were relevant and discoverable. (Crandall declaration, Exhibit 2.) The parties also participated in an Informal Discovery Conference with the Court on May 20, 2022.  (Id. ¶ 11.) The Court ordered Defendant to respond to this document request on September 15, 2022. ((Id.) ¶ 13.)

       Plaintiff sought the deposition of Defendant’s PMQ, regarding repair history and records of the vehicle, warranty and vehicle repurchase polices, all documents previously produced, and internal investigation and analysis. (Mot. filed 6/13/23, 1:11-16.)  The court ordered Defendant to produce a witness, and thereafter, ordered Defendant’s compliance with the original order, and imposition of daily sanctions.

       Despite the court’s clear order requiring Defendant to produce a witness with knowledge of the specific categories raised by the motion “without limitation or condition,” and explaining ad nauseum the documents’ and testimony’s relevance, and a second order requiring Defendant’s compliance with imposition of daily monetary sanctions, Defendant limited the categories of inquiry (1 through 4, 7, and 10) and produced a witness, Bryan Jenkins, who lacked knowledge of those categories. The witness was unfamiliar with internal investigations and analyses of the defect at issue, customer assistance complaints, or of the documents produced at the deposition, or how those documents were created, or how a vehicle was evaluated.  (Supp. Declaration, Confidential Transcript, 80:11-85.)

       Defense counsel instructed the witness not to answer, asserting attorney-client privilege. Defense counsel then allowed the witness to answer unless the matter concerned privileged information, which the witness was required to unilaterally determine although defense counsel also instructed the witness not to answer lay questions on grounds the answer involved a legal conclusion. (Crandall Supp. Decl., Ex. 1, 91:3-23.)

       While instructions not to answer are permitted if the question pertains to privileged matters or the deponent is being harassed, GM offers no explanation for how the privilege was implicated, contending that it has complied with the court’s order by limiting the categories of inquiry and producing an unqualified witness. (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal. App. 4th 1006, 1015.)

       Moreover, defense counsel, Ms. Pappas’s, contention that the court did not order a witness on “specific categories” is contrary to the two orders requiring GM to produce a witness knowledgeable on all the categories raised by Plaintiff’s motion. (Crandall Supp. Decl. 2/20/24, Ex. 3, .pdf page 22, e-mail of 2/6/24.) This evidence conflicts with Ms. Pappas’ declaration that “GM is willing to work with Plaintiff” to schedule depositions on the remaining categories, which is not supported by the emails submitted by Plaintiff. (Pappas Decl., ¶ 11.)

       GM faults Plaintiff for only sending one email to claim that the PMQ was insufficient, and that Plaintiff should have made further attempts. (Pappas decl., ¶ 11.) Plaintiff has been attempting to schedule this deposition since January 25, 2022. (Min. Ord. 7/27/23, page 2.) Plaintiff has still not obtained testimony from a witness knowledgeable about any category raised, or who can provide foundation and authentication for the documents Defendant produced.

       Two years of efforts to meet and confer, including conferences with the court, three motions concerning this issue, two orders compelling the production of a PMK witness, and imposition of daily monetary sanction of $500 have not resulted in the desired effect of “encouraging fair disclosure of discovery to prevent unfairness resulting from the lack of information.” (Midwife v. Bernal (1988) 203 Cal.App.3d 57, 64.) .) Instead, GM raises new hurdles for Plaintiff’s counsel to overcome.

       Defendant has engaged in misuse of the discovery process: using a discovery method in a manner that does not comply with its specified procedures; employing a discovery method in a manner or to an extent that causes unwarranted annoyance, embarrassment, or oppression, or undue burden and expense; failing to respond or to submit to an authorized method of discovery; making, without substantial justification, an unmeritorious objection to discovery; making an evasive response to discovery, twice disobeying a court order to provide discovery; opposing unsuccessfully and without substantial justification, a motion to compel or to limit discovery; and failing to confer in good faith. (Cal Code Civ Proc § 2023.010.)

       The court previously declined to impose issue, evidentiary, or terminating sanctions, in furtherance of the principle that sanctions should be “appropriate to the dereliction,” and tailored to accomplish the discovery sought. (Do It Urself Moving & Storage, Inc. v. Brown, Leifer, Slatkin & Berns (1992) 7 Cal.App.4th 27, 35.) The imposition of terminating sanctions may be imposed “as a first measure in extreme cases, or where the record shows lesser sanctions would be ineffective.” (Id. at 191–192.)

       GM’s repeated misconduct over the course of two years has established that GM’s noncompliance with its discovery obligations or with the court’s orders are willful and that less severe measures have not deterred the misconduct.  

       Accordingly, the court GRANTS plaintiff’s request for monetary sanctions for every day Defendant failed to comply by producing a person most knowledgeable on all categories on January 23, 2024.  The court imposes monetary sanctions of $17,500 ($500 per day x 35 days) from January 23, 2024, to February 27, 2024.

       Additionally, the court sets an Order to Show Cause why the court should not impose an additional $1,000 sanction payable to the Plaintiff and reportable to the State Bar, on grounds defense counsel, Ms. Pappas, did not meet and confer in good faith with respect to the document request served with the Notice of Deposition. Defendant produced a witness pursuant to only limited categories, and there is no showing that Defendant complied with the document request in part or at all. Co-defense counsel, Xylon Quezada, interposed improper and unsubstantiated objections and instructions not to answer. (Code Civ. Proc., § 2023.050.)

       Given the extreme misconduct, the court GRANTS the alternative request for imposition of issue sanctions and orders that Plaintiff’s prima facie case is determined against GM, and GM is precluded from introducing any evidence at trial controverting the following issues: (1) the vehicle had a nonconformity covered by the express warranty that substantially impaired the use, value or safety of the vehicle (the nonconformity element); (2) the vehicle was presented to an authorized representative of the manufacturer of the vehicle for repair (the presentation element); and (3) the manufacturer or his representative did not repair the nonconformity after a reasonable number of repair attempts (the failure to repair element). " (Oregel v. American Isuzu Motors, Inc. (2001) 90 Cal.App.4th 1094, 1101.)

IV.    CONCLUSION

       Based on the foregoing, Plaintiff’s alternative motion for sanctions is GRANTED. Defendant is ordered to pay Plaintiff and counsel $17,500 in monetary sanctions within 10 days.  The court orders issue and evidentiary sanctions as described above, and the Court sets an OSC re: Additional Sanctions of $1,000 against defense counsel, Alexandria Pappas, for March 6,  2024, in Department A of the Compton Courthouse.  Counsel is ordered to respond in writing to the OSC, two days prior to the hearing.