NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al.

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

reporter from the Court’s Approved Official Reporter Pro Tempore list. Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporter’s Office and an official reporter will be provided

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TENTATIVE RULING

Plaintiff Kenneth Jay Namba’s (“Plaintiff”) Motion to Compel Further Responses to Special Interrogatories from Defendant American Honda Motor Co., Inc.’s (“Defendant”) is ruled upon as follows.

Factual Background

Plaintiff served the at issue discovery requests on September 15, 2025. (Conn Decl., ¶ 2.) Defendant served its responses on October 31, 2025. (Conn Decl., ¶ 3.) Following meet-and-confer efforts, Plaintiff filed the instant motion on March 20, 2026. (Conn Decl., ¶¶ 5-20.) Defendant served amended responses on April 17, 2026. (Herzog Decl., ¶ 7.)

Plaintiff now moves to compel further responses to special interrogatories nos. 1, 3, 5, 7, 9, 10 & 14-19.

This matter was previously continued from May 6, 2026 to permit the Parties to engage in further meet-and-confer efforts. The Parties filed their joint statement on June 1, 2026, setting forth the Parties’ efforts to further meet and confer and the resulting

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

compromises.

The Parties do not appear to have come to any agreement regarding any of the at issue special interrogatories.

Interrogatories at Issue

Special Interrogatory No. 1: IDENTIFY each of YOUR EMPLOYEES who COMMUNICATED with PLAINTIFF or PLAINTIFF’S representatives CONCERNING the SUBJECT VEHICLE.

Defendant responded:

AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, as directed to pre-litigation communications, a response to this interrogatory would necessitate the making of a compilation, abstract, audit, or summary of documents, the burden or expense of which is substantially the same for Plaintiff as it is for AHM. Pursuant to California Code of Civil Procedure section 2030.230, AHM refers Plaintiff to and will produce its CRRS Reports, which contain information that is confidential, commercially sensitive, and/or proprietary, pursuant to the entry of an appropriate protective order.

Special Interrogatory No. 3: IDENTIFY each of YOUR EMPLOYEES who have driven the SUBJECT VEHICLE.

Defendant responded:

AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, no AHM employees drove the SUBJECT VEHICLE during Plaintiff’s ownership. As directed to any test drive of the SUBJECT VEHICLE by employees of an authorized Honda repair facility, a further response to this interrogatory would necessitate the making of a compilation, abstract, audit, or summary of documents, the burden or expense of which is substantially the same for Plaintiff as it is for AHM. Pursuant to Code of

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

Civil Procedure section 2030.230, AHM refers Plaintiff to and will produce the service records received from Capital City Honda, Future Honda, and Folsom Lake Honda, business entities separate from and independent of AHM, copies of which AHM believes are in the possession of Plaintiff and his counsel, portions of which contain information that is confidential, commercially sensitive, and/or proprietary, pursuant to the entry of an appropriate protective order.

Special Interrogatory No. 5: IDENTIFY each of YOUR EMPLOYEES who have worked on, REPAIRED, serviced, or inspected the SUBJECT VEHICLE.

Defendant responded:

AHM objects to this interrogatory as vague, ambiguous, and as asking for information that is not relevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence. In addition, the phrase “worked on, REPAIRED, serviced, or inspected” is not defined, described, or otherwise explained in this discovery and, without such, the information referred to or sought cannot be determined, without speculation. AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy.

AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, AHM identifies AHM Field Technical Specialist Nelson Coats. As directed to employees of an authorized Honda repair facility, a further response to this interrogatory would necessitate the making of a compilation, abstract, audit, or summary of documents, the burden or expense of which is substantially the same for Plaintiff as it is for AHM.

Pursuant to Code of Civil Procedure section 2030.230, AHM refers Plaintiff to and will produce the service records received from Capital City Honda, Future Honda, and Folsom Lake Honda, business entities separate from and independent of AHM, copies of which AHM believes are in the possession of Plaintiff and his counsel, portions of which contain information that is confidential, commercially sensitive, and/or proprietary, pursuant to the entry of an appropriate protective order.

Special Interrogatory No. 7: IDENTIFY each of YOUR EMPLOYEES who COMMUNICATED with any of YOUR AUTHORIZED DEALERSHIPS CONCERNING PLAINTIFF or the SUBJECT VEHICLE.

Defendant responded:

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, a response to this interrogatory would necessitate the making of a compilation, abstract, audit, or summary of documents, the burden or expense of which is substantially the same for Plaintiff as it is for AHM. Pursuant to Code of Civil Procedure section 2030.230, AHM refers Plaintiff to and will produce its Tech Line Contact Report and CRRS Reports, which contain information that is confidential, commercially sensitive, and/or proprietary, pursuant to the entry of an appropriate protective order.

With respect to interrogatories nos. 1, 3, 5, and 7, Plaintiff argues in the joint statement that each seeks the contact information for employees, pursuant to the definition of the term found in the interrogatories, but Defendant provided no such contact information, instead stating that witnesses may be contacted through Defendant’s counsel. Defendant argues that it has provided amended responses which respond to these interrogatories. However, these amended responses are not before the Court, nor may the Court properly rule upon the amended responses. Further, the Court notes that the amended responses do not contain amended responses to interrogatories nos. 1, 3, and 7.

Accordingly, Plaintiff’s motion to compel is GRANTED as to interrogatories 1, 3, 5, and 7.

Special Interrogatory No. 9: IDENTIFY each of YOUR EMPLOYEES who was a manager or otherwise responsible for the customer relations department in the district or region having jurisdiction over PLAINTIFF’S complaints from the time PLAINTIFF purchased the SUBJECT VEHICLE to the present.

Defendant responded:

AHM objects to this interrogatory as vague, ambiguous, and as asking for information that is not relevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence. AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

Plaintiff argues that an amended response is warranted, because Plaintiff seeks the identification of witnesses with “direct knowledge of Honda’s relevant customer relations policies, practices, and procedures.” (Joint State., p. 3:18-19.) Thus, Plaintiff argues, the interrogatory seeks relevant information. In opposition, Defendant argues that it has identified “those individuals from its customer service department who addressed Plaintiff's concerns through its production of its CRRS reports,” and that the request seeks information which is not relevant.

Information is relevant “if it might reasonably assist a party in evaluating its case, preparing for trial, or facilitating a settlement. [citations omitted.] Admissibility is not the test and information, unless privileged, is discoverable if it might reasonably lead to admissible evidence.” (Lipton v. Superior Court (1996) 48 Cal.App.4th 1599, 1611-1612 [emphasis in original].) “Any doubts regarding relevance are generally resolved in favor of allowing the discovery.” (Mercury Interactive Corp. v. Klein (2007) 158 Cal.App.4th 60, 98.)

Defendant’s objection of relevance is overruled. The Court finds that the request seeks information which is reasonably calculated to lead to the discovery of admissible evidence. Plaintiff seeks identification of witnesses who may have personal knowledge of the handling of lemon law complaints. Such information would certainly be relevant to Plaintiff's claim for civil penalties under Civil Code § 1794(c) given that Plaintiff must show a willful failure by Defendant in complying with its obligations under the Song- Beverly Act.

Plaintiff’s motion to compel is GRANTED as to interrogatory No.

9.

Special Interrogatory No. 10: IDENTIFY each of YOUR EMPLOYEES in the region serving California who had authority to offer a refund of a customer’s money or a replacement vehicle in accordance with the SONG-BEVERLY ACT from the date PLAINTIFF purchased the SUBJECT VEHICLE to the present.

Defendant responded:

AHM objects to this interrogatory as asking for information that is not relevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence AHM objects to the extent this interrogatory asks for information that is protected by the right to privacy. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

The motion to compel further response to interrogatory no. 10 is GRANTED for the same reasons as with respect to interrogatory no.

9.

Special Interrogatory No. 14: IDENTIFY the transit company that delivered the SUBJECT VEHICLE to the selling dealership.

Defendant responded:

AHM objects to this interrogatory as asking for information that is not relevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence.

Plaintiff argues that “The issues experienced by Plaintiff are consistent with the Vehicle having sustained impact damage prior to purchase (which was not disclosed to him). If this damage was repaired prior to delivery to the dealership, that information would not be on the “PDI” document and is information Plaintiff would need to subpoena.” (Joint State., p. 4:23-26.) Defendant argues that “there is no evidence and there is no claim by plaintiff that the vehicle was damaged in transit.” (Id., p. 5:4-5.)

However, while Defendant asserts that the vehicle was not damaged or repaired prior to Plaintiff’s purchase of the vehicle, Defendant has provided no response to discovery asserting this fact.

Defendant’s objection of relevance is overruled. Plaintiff’s motion to compel is GRANTED as to this request.

Special Interrogatory No. 15: What are YOUR policies for repurchasing vehicles in accordance with the SONG-BEVERLY ACT, in effect from the date that Plaintiff purchased the SUBJECT VEHICLE?

Defendant responded:

AHM objects to this interrogatory as vague, ambiguous, overly broad, and as asking for information that is not relevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence. Further, by inclusion of reference to the SONG-BEVERLY ACT, this interrogatory is not full and complete in and of itself and requires reference to other documents in violation of Code of Civil Procedure section 2030.060(d) particularly considering the Song-Beverly Consumer Warranty Act is comprised of multiple

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

distinct sections of the California Civil Code. AHM further objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, AHM has no written policies concerning the issuance of vehicle purchase refunds pursuant to the California Song-Beverly Consumer Warranty Act, other than the statute itself.

Special Interrogatory No. 16: Set forth all facts explaining why YOU did not repurchase the SUBJECT VEHICLE in response to PLAINTIFF’S repurchase request.

Defendant responded:

AHM objects to this interrogatory as vague, ambiguous, and overly broad. AHM objects to the extent this interrogatory asks AHM to respond on behalf of any other entity and responds only on behalf of AHM. Subject to and without waiving these objections, a response to this interrogatory would necessitate the making of a compilation, abstract, audit, or summary of documents, the burden or expense of which is substantially the same for Plaintiff as it is for AHM. Pursuant to California Code of Civil Procedure, section 2020.230, AHM refers Plaintiff to and will produce its CRRS Reports, which contain information that is confidential, commercially sensitive, and/or proprietary, pursuant to the entry of an appropriate protective order.

Defendant argues that it has served amended responses which provide the information sought in interrogatories nos. 15 and 16. As with respect to interrogatories nos. 1, 3, 5, and 7, these amended responses are not properly before the Court in the instant motion.

Plaintiff’s motion to compel further response to special interrogatories nos. 15 and 16 is GRANTED.

Special Interrogatory No. 17: If any of YOUR EMPLOYEES identified in the answers to these interrogatories has been reprimanded for any action or omission CONCERNING the SUBJECT VEHICLE or PLAINTIFF, state the date and substance of the reprimand.

Defendant responded:

AHM objects to this interrogatory as asking for information that is not relevant to

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence. AHM further objects to the extent this interrogatory asks AHM to respond on behalf of any other entity.

Plaintiff argues that this interrogatory is relevant, because it seeks information which would allow Plaintiff to determine whether Defendant engaged in a willful violation of the Song-Beverly Warranty Act. Defendant argues that “Whether an employee was reprimanded or not has nothing to do with whether the vehicle should or should not have been repurchased due to a nonconformity that is a substantial impairment to use, value, or safety.” (Joint State., 7:24-26.)

Defendant’s objection of relevance is overruled. Plaintiff’s motion to compel is GRANTED as to this request.

Special Interrogatory No. 18: What were YOUR policies and procedures that were in effect during the period PLAINTIFF possessed the SUBJECT VEHICLE CONCERNING the recording of telephone calls between YOU and consumers?

Special Interrogatory No. 19: What were YOUR policies and procedures that were in effect during the period PLAINTIFF possessed the SUBJECT VEHICLE CONCERNING the retention, storage, and deletion of recordings of telephone calls between YOU and consumers?

Defendant responded to interrogatories nos. 18 and 19:

AHM objects to this interrogatory as vague, ambiguous, overly broad, and as asking for information that is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. In addition, AHM objects to this interrogatory as calling for information that is confidential, commercially sensitive, and/or proprietary.

Plaintiff argues that given Defendant’s representations that any such evidence has been deleted or destroyed, the interrogatories seek information which is reasonably calculated to lead to the discovery of admissible evidence, to determine whether there was any spoilation of evidence. Defendant argues that “AHM has no responsive documents and, as to telephone call recordings, they would have been discarded in ordinary course of business, which is compliant with 2030.230. However, any call logs were produced through the CRRS report, reflecting the communications between

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV017829: NAMBA vs AMERICAN HONDA MOTOR CO., INC., et al. 06/15/2026 Hearing on Motion to Compel Further Discovery Responses to Plaintiffs First Set of Specially Prepared Interrogatories in Department 8D

Plaintiff and AHM.” (Joint State., p. 8:15-18.)

Despite Defendant’s assertion that it has no responsive documents, it did not attest to this in its response to interrogatories nos. 18 and 19.

To the extent that Defendant asserts any responsive information is confidential or proprietary, Defendant must serve a privilege log. Defendant’s other objections are overruled.

Plaintiff’s motion to compel is GRANTED as to request nos. 18 and 19.

Disposition

As set forth above, Plaintiff’s motion to compel is granted in its entirety.

Defendant shall serve verified amended responses by no later than June 29, 2026.

The minute order is effective immediately. No formal order pursuant to California Rules of Court, rule 3.1312 or further notice is required.