JOSE AVIGAIL GRAMAJO ORDONEZ vs. GENERAL MOTORS LLC

Plaintiff Jose Gramajo Ordonez filed his motion to compel responses to documents, set one, and Feb 18, 2026. Plaintiff alleges that he served three separate meet and confer letters outlining why defendant’s responses were not code compliant. The defendant refused to supplement responses. Plaintiff alleges that defendant has not produced documents in connection with RFPs: 1-58. Plaintiff also alleges that Defendant has refused to meet and confer with Plaintiff’s counsel via Zoom or phone calls to complete a good faith attempt to meet and confer.

Defendant filed its opposition on May 5, 2026, explaining that under modifications to the. Song- Beverly Consumer Warranty Act, new cases filed after January 1, 2025, new cases under the Act are subject to AB 1755. Defendant argues that discovery is limited, under the act in that defendant must now produce early disclosures of a specific set of documents related to the subject vehicle. The documents produced by the defendant thus far have been identified by the Legislature as “those most associated with lemon law claims”. These include a vehicle summary reports, service documents, product brochures, etc.

California discovery rules are to be liberally construed in favor of disclosure. Discovery statutes must be interpreted broadly to facilitate the exchange of information between parties. "[A]bsent a showing that substantial interests will be impaired by allowing discovery, liberal policies of discovery rules will generally counsel against overturning a trial court's decision granting discovery and militate in favor of overturning a decision to deny discovery" (Flagship Theatres of Palm Desert, LLC v. Century Theatres, Inc., 198 Cal.App.4th 1366 (2011), Forthmann v. Boyer, 97 Cal.App.4th 977 (2002)). As the Supreme Court explains, "a strict, rigid interpretation of the relevancy requirement" would likely "lead recalcitrant parties to attempt to construct an 'irrelevancy' barrier to discovery more frequently," while "a more fluent, liberal interpretation may discourage resorting to this kind of delaying tactic" (Pacific Tel. & Tel. Co. v. Superior Court, 2 Cal.3d 161 (1970)). The statutory provisions governing discovery methods "must be liberally construed in favor of discovery and reviewing courts must not extend statutory limitations upon discovery beyond limits expressed by legislature". (Irvington-Moore, Inc. v. Superior Court, 14 Cal.App.4th 733 (1993)).

The court is concerned with Defendant’s apparent lack of meet and confer efforts. In addition, the voluntary production requirement most likely does not replace responses to discovery requests asked by either party.

Marin Local Rule, Civil, 2.13 provides in pertinent part:

For any discovery dispute in a civil case that the parties cannot resolve informally in the meet and confer process, it shall be the policy of the Marin County Superior Court to Civil Rules – to require use of the Discovery Facilitator Program (“the Program”). Reasonable and good faith participation in the Program before the filing of a discovery motion satisfies a party’s meet and confer obligation for purposes of this rule