Judge: Stephen I. Goorvitch, Case: 22STCV25570, Date: 2023-03-30 Tentative Ruling

Case Number: 22STCV25570    Hearing Date: March 30, 2023    Dept: 39

Amore Jackson, et al v. Ford Motor Company

Case No. 22STCV25570

Plaintiffs’ Motion to Compel Deposition

            Plaintiffs move to compel Defendant to produce its person most knowledgeable for a deposition and to produce certain documents.  The Court grants the motion in part and denies the motion in part. 

            The Court orders Defendant to produce the following documents at or before the deposition, to the extent they have not been produced already:

1.         Purchase and/or lease contract concerning the subject vehicle.

2.         Repair orders and invoices concerning the subject vehicle.

3.         Communications with dealer, factory representative and/or call center concerning the subject vehicle.

4.         Warranty claims submitted to and/or approved by Defendant concerning the subject vehicle.

5.         Any Warranty Policy and Procedure Manual published by defendant and provided to its authorized repair facilities, within the State of California, for the date the subject vehicle was purchased to the present.

6.         Any internal analysis, investigation, and/or communications regarding the same defects claimed by plaintiff in vehicles of the same year, make and model as the subject vehicle which were sold within the State of California.

7.         Any customer complaints regarding the same defects claimed by plaintiff in vehicles of the same year, make and model as the subject vehicle which were sold within the State of California.

8.         All policies and/or procedures used to evaluate customer requests for repurchase pursuant to the Song-Beverly Consumer Warranty Act, from the date of purchase to the present.

9.         Technical Service Bulletins and/or Recall Notices regarding the same defects claimed by plaintiff in vehicles of the same year, make and model of the subject vehicle which were sold within the State of California.

10.       Any documents supporting plaintiff’s claim for incidental and/or consequential damages.

            The Court orders Defendant to produce a PMK to testify about the following categories:

1.         All repairs to the vehicle

2.         Technical Service Bulletins and/or Recall Notices regarding the same defects claimed by plaintiff in vehicles of the same year, make and model of the subject vehicle which were sold within the State of California.

            3.         See Category #2

            4.         The process by which a Technical Service Bulletin is issued including but not limited to all criteria, data, or information relied upon.

5.         Technical Service Bulletins and/or Recall Notices regarding the same defects claimed by plaintiff in vehicles of the same year, make and model of the subject vehicle which were sold within the State of California.

6.         See Category #5

7.         Defendant’s failure to repurchase the vehicle

8.         All policies and/or procedures used to evaluate customer requests for repurchase pursuant to the Song-Beverly Consumer Warranty Act, from the date of purchase to the present.

9.         Any Warranty Policy published by defendant and provided to its authorized repair facilities, within the State of California, for the date the subject vehicle was purchased to the present.

10.       See Category #9

11.       Any Procedure Manual published by defendant and provided to its authorized repair facilities, within the State of California, for the date the subject vehicle was purchased to the present.

12.       See above.

13.       Technical Service Bulletins and/or Recall Notices regarding the same defects claimed by plaintiff in vehicles of the same year, make and model of the subject vehicle which were sold within the State of California.

14.       See above.

15.       All documents listed above. 

Plaintiffs’ counsel shall provide notice.