MOTION TO COMPEL PRODUCTION
# Case Name Tentative
1. KOPICK, INC. VS. EPLEX, INC. 2025-01491949 MOTION TO BE RELIEVED AS COUNSEL OF RECORD
The motion of attorneys Samuel Yu and Daniel Yu and law firm Kahana & Feld LLP to be relieved as counsel for defendant Eplex, Inc. is GRANTED. (Code Civ. Proc., § 284; Cal. Rules of Court, rule 3.1362.) Attorneys will be relieved as counsel of record for client effective upon filing of proof of service of the signed order on client.
Moving attorney is to give notice of ruling which includes notice to Defendant that corporations must be represented by counsel.
2. FLORES VS. FCA US, LLC 2023-01366471 MOTION TO COMPEL PRODUCTION
Plaintiff Francisco Javier Flores’ motion to compel Defendant, FCA US, LLC (“FCA”) to provide responses, without objections, to Plaintiff’s Request for Production of Documents, Set One, is MOOT.
On May 22, 2024, Plaintiff served Requests for Production of Documents, Set One (“RFPs”) on FCA. (Rucker Decl., ¶ 4, Ex. 1.) Plaintiff sent a meet and confer letter to FCA on December 31, 2025. (Rucker Decl., ¶ 7, Ex. 2.)
On January 13, 2026, FCA served verified responses to Requests for Production of Documents, Set One. (Gruzman Decl., ¶ 4, Ex. 2.) Defendant has shown the responses are not untimely based on an agreement between FCA and Plaintiff’s counsel’s firm Strategic Legal Practices (“SLP”). Specifically, FCA and SLP entered into an informal arrangement for all cases between FCA and Strategic Legal Practices. (Hugret Decl., ¶ 4.) The informal arrangement was negotiated directly with SLP’s Founding Partner Payam Shahian in December 2024. (Hugret Decl., ¶ 4.)
The arrangement allowed Plaintiff’s counsel to serve discovery requests, while FCA received an open-ended extension to respond to Plaintiff’s discovery. (Hugret Decl., ¶ 5.) The basis of this agreement was that FCA would not be required to respond to discovery served by SLP during the pendency of this arrangement unless such responses were specifically requested by SLP, at which time, FCA would promptly provide responses. (Hugret Decl., ¶ 5.) As part of this agreement. FCA also agreed to informally produce certain case documents, such as the warranty claims and call logs. (Hugret Decl., ¶ 5.)
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FCA complied with its portion of the agreement and provided informal document productions for 185 cases by January 27, 2025. (Hugret Decl., ¶ 5.) FCA further complied with the agreement by serving verified responses to the RFPs on January 13, 2026, and producing documents, Bates Number 00001-001527. Therefore, the Motion is MOOT.
Plaintiff’s request for sanctions is DENIED.
Moving party to give notice.
3. HOME OF THE MINISTERING ANGEL VS. SENECA FAMILY OF AGENCIES 2025-01498434 1. MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES Defendant Seneca Family of Agencies’s Motion to Compel Further Responses to its Form Interrogatories, set one, is GRANTED. Plaintiff is ORDERED to provide a further response to interrogatory no. 17.1 and provide a verification by the person with personal knowledge of Plaintiff’s compliance with its discovery obligations. Defendant has reserved its request for sanctions for a separate motion. (See London v.
Dri-Honing Corp. (2004) 117 Cal.App.4th 999, 1008.) Defendant’s requests for judicial notice are granted. (Evid. Code, § 452(d).) The Court finds Plaintiff has failed to comply with its discovery obligations. Code of Civil Procedure section 2030.220(c) requires a party to “make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations ....” Plaintiff responded to numerous subparts of interrogatory no. 17.1 stating “(b) Responding Party and its representatives lack personal knowledge of facts sufficient at this time to either admit or deny the request.
Responding Party’s representatives directly involved in the 1987 transaction inclusive of Billy Eugene Small have since passed away. [¶] (c) Responding Party is informed and believes that Dan McQuaid (address and telephone number unknown to Responding Party) or Lloyd Copenbarger, Esq. (address and telephone number unknown to Responding Party) may have information relating to the request.” Plaintiff’s person most knowledgeable, Doris Small, signed the verification as an officer of Plaintiff stating: “[t]he matters stated in the foregoing document are true of my own knowledge ....” (Averett Decl., Ex.
J.) Later, Small testified at her deposition, she did not conduct a reasonable search. (Averett Decl., Ex. P, 48:4-62:25.) Thus, Plaintiff is compelled to provide a further response to interrogatory no. 17.1 after conducting “reasonable and good faith effort to obtain the information” and is ordered to provide a verification by the person with personal knowledge of the efforts.
2. MOTION TO COMPEL PRODUCTION Defendant Seneca Family of Agencies’s Motion to Compel Further Responses to its Requests for Production, set one, is GRANTED.