SHAWN MASSOUDI vs GENERAL MOTORS LLC

2023CUPL012179: SHAWN MASSOUDI vs GENERAL MOTORS LLC 08/27/2026 in Department 44 Motion to Compel the Deposition of Defendant General Motors LLC's Persons Most Knowledgeable with Production of Documents

Department Rules. Parties and counsel shall follow the Department 44 rules and Zoom protocols, available at https://www2.ventura.courts.ca.gov/Courtroom/C44.

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ZOOM Registration Link:

https://ventura-courts-ca.zoom.us/meeting/register/iqN7uhQSQMuOqs-9TQXgEQ

No advance notice is required to appear in person.

Tentative Rulings. Oral argument should address the tentative decision. To submit on the tentative decision, email courtroom44@ventura.courts.ca.gov before 8:00 a.m. on the hearing date, copying all other parties. Use the subject line “SUBMISSION ON TENTATIVE”, [Case Number], [Case Title] and [Party]. If not all parties submit, the hearing will proceed, and the tentative ruling may change.

The Court may adopt, modify or reject the tentative ruling after hearing. The tentative ruling has no legal effect unless and until adopted by the Court.

Motion: Plaintiff Shawn Massoudi’s Motion to Compel the Deposition of Defendant General Motors LLC’s Person(s) Most Knowledgeable, with Production of Documents (Opposed)

Tentative Ruling:

Plaintiff Shawn Massoudi’s Motion to Compel the Deposition of Defendant General Motors LLC’s Person(s) Most Knowledgeable, with Production of Documents is GRANTED in part and DENIED in part.

The motion is GRANTED to the extent Plaintiff seeks to compel GM actually to produce one or more PMK witnesses on the testimony GM expressly agreed in its July 10, 2026 objections to provide. GM shall produce an appropriately prepared PMK or PMKs on Categories 1, 2, 3, 5, 7, 9, and 12, subject to the limitations stated in GM’s July 10 responses and objections, on a mutually agreeable date before the discovery cutoff and no later than September 10, 2026.

The motion is DENIED without prejudice as to Categories 4, 6, 8, 10, 11, 13, and 14; as to any additional testimony on Categories 1, 2, 3, 5, 7, 9, and 12 beyond that which GM agreed to

2023CUPL012179: SHAWN MASSOUDI vs GENERAL MOTORS LLC

provide; and as to Plaintiff’s request to compel further production of documents. Plaintiff failed to submit the separate statement required by California Rules of Court, rule 3.1345, and the Court declines to adjudicate the numerous disputed categories and document requests without the request-by-request presentation required by that rule.

No monetary sanctions are awarded.

Plaintiff to give notice.

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