PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al.

25CV018548: PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al. 08/27/2026 Hearing on Motion to Compel Further Responses to Requests for Production of Documents, Set One in Department 16D

Tentative Ruling

NOTICE:

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25CV018548: PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al. 08/27/2026 Hearing on Motion to Compel Further Responses to Requests for Production of Documents, Set One in Department 16D

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 forward the form to the Court Reporter’s Office and an official reporter will be provided.

*** EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G STREET IN SACRAMENTO, CA 95814. ALL HEARINGS NOTICED FOR DEPARTMENT 53 WILL BE HEARD IN DEPARTMENT 16D OF THE NEW COURTHOUSE. ***

TENTATIVE RULING: Plaintiff Danny Ray Pierce, Jr.’s (“Plaintiff”) motion to compel defendant Mazda Motor of America, Inc. (“Mazda”) to serve verified further responses to Requests for Production of Documents, Set One (“RFPDs”), numbers 1 through 31 is ruled upon as follows.

This is a Lemon Law action arising from Plaintiff’s purchase of a 2023 Mazda CX50, (“the Subject Vehicle”). Plaintiff alleges causes of action under the Song-Beverly Act for breach of express warranty, breach of implied warranty, and violation of Civil Code section 1793.2.

On or about December 2, 2025, Plaintiff propounded the RPFDs on Mazda. Mazda responded on January 5, 2026 with only boilerplate objections, which Plaintiff contends are not codecompliant or consistent with case law. Mazda raised various objections, including that the requests are vague and ambiguous, unduly burdensome, violate privacy rights, and seek irrelevant, confidential, and/or privileged information.

In opposition, Mazda contends that the subject motion is moot because on April 23, 2026, Mazda served verified further responses and served 922 documents regarding the Subject Vehicle and any service visits. However, service of responses after the motion was filed and prior to the hearing does not moot the motion. A motion is “made” when it is filed and served. (CCP § 1005.5.) While Defendant suggests that the service of responses moots the motion, the cited authority involves a scenario where untimely responses are served after a motion to compel initial responses was filed, not after a motion to compel further responses was filed. (Sinaiko Healthcare Consulting, Inc. v.

Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 409- 410.) Thus, Plaintiff is still entitled to an order even if further responses were served after the motion. The content of any further responses served after the motion was filed is not before the Court on this motion.

Other than arguing that the motion is moot, which as discussed, it is not, Mazda only addresses its original objection only responses to RFPD nos. 23-30. To that end Mazda argues that Plaintiff

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018548: PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al. 08/27/2026 Hearing on Motion to Compel Further Responses to Requests for Production of Documents, Set One in Department 16D

only needs documents regarding the Subject Vehicle. Mazda contends that RFPDs asking for information about other vehicles is grossly overbroad, vague and outside the scope of discovery.

Plaintiff categories the discovery requests as follows:

Requests 1-14 seek documents relating to Plaintiff’s own vehicle. Requests 15-29 seek documents reflecting Mazda’s written warranties and repurchase policies and procedures under the Song-Beverly Act. Requests 30-31 seek documents related to Mazda’s knowledge of the same or similar defects in other vehicles of the same year/make/model as the Subject Vehicle.

The Court finds the discovery requests are sufficiently specific to identify the documents being sought. Indeed, in its opposition Mazda fails to substantiate any objection based on the ground the request is vague or ambiguous. A vague and ambiguous objection is only proper where the request is so ambiguous that the responding party cannot provide an intelligent response. (Cembrook v. Superior Court (1961) 56 Cal.2d 423, 430.) This objection is overruled.

The remaining objections are overruled as follows.

The Court finds that Plaintiff is entitled to information about the same defects regarding other identical (same year, make, model, sold in California) Mazda CX50 vehicles. In this regard, the Court sustains Defendants’ overbreadth objection in part so as to effectively narrow the requests to such information. Indeed, in the discovery context, 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 [court’s emphasis].) In fact, evidence regarding other vehicles with similar defects as Plaintiff’s could potentially be admissible at trial in a lemon law action. (Donlen v. Ford Motor Co. (2013) 217 Cal.App.4th 138, 154; see also Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 971.) Here, for example, the subject documents could lead to the discovery of admissible evidence regarding Mazda’s knowledge of the defects, and that Mazda lacks the means to fix the defects and nevertheless refuses to repurchase Plaintiff’s vehicle.

Such information would certainly be relevant to Plaintiff’s claim for civil penalties under Civil Code section 1794(c) given that Plaintiff must show a willful failure by Mazda in complying with its obligations under the Song-Beverly Act. Further, documents related to the warranty and repurchase policies, procedures, and practices could lead to the discovery of admissible evidence regarding Hyundai’s compliance with the Song-Beverly Act. (See Johnson v. Ford Motor Co. (2005) 35 Cal.4th 1191, 1199-1200 [evidence of “corporate policies and practice regarding reacquisition of vehicles” could support the jury's finding that defendant “had violated the Lemon Law”].)

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018548: PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al. 08/27/2026 Hearing on Motion to Compel Further Responses to Requests for Production of Documents, Set One in Department 16D

The Court’s imposed limitation of the requests to cover only similar defects in identical (same year, make, model, sold in California) Mazda CX50 vehicles effectively addresses Mazda’s claim that the requests here are otherwise still overbroad and precludes it from determining what Plaintiff is asking for. Mazda must simply make a good faith effort to respond to the discovery based upon a reasonable interpretation of the request. The Court rejects and overrules any further objection that the RFPDs failed to specifically describe documents or reasonably particularize each category of item. The overbreadth objections to the discovery as narrowed are overruled. Mazda’s burdensome and oppression objections are also overruled due to the fact that as set forth above the discovery is limited to identical vehicles sold only in California.

Defendant further objected that the information sought would divulge confidential information and trade secrets. Defendant has not moved for a protective order and no such motion is presently before the Court. Further, Mazda does not discuss these objections in the opposition much less substantiate them, and they are overruled. Mazda had the burden to substantiate its objections and failed to do so. (Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255 [citing Coy v. Superior Court (1962) 58 Cal.2d 220-221].)

In addition, while Mazda interposed objections based on attorney-client privilege and work product privilege, it failed to indicate whether any documents were withheld on this basis. To the extent Mazda withholds any documents on the basis of the privileges, it must provide further responses that provide sufficient factual information for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. (CCP § 2031.240.)

Any other objections asserted in Mazda’s objection only responses to the RFPDs not specifically addressed above are also overruled.

In sum, Plaintiffs' motion to compel is granted to the extent described above. In light of the Court's rulings here, Mazda shall serve further verified responses, as limited to the Subject Vehicle and other identical (same year, make, model, sold in California) Mazda CX50 vehicles, to Plaintiff's request for production of documents, set one by no later than September 27, 2026.

Plaintiff’s request for sanctions is denied as the Court finds that Mazda’s opposition, while not persuasive, was substantially justified.

Mazda’s request for sanctions is denied as Plaintiff’s motion was successful and therefore substantially justified.

This minute order is effective immediately. No formal order pursuant to CRC Rule 3.1312 or further notice is required.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV018548: PIERCE vs MAZDA MOTOR OF AMERICA, INC., A CALIFORNIA CORPORATION, et al. 08/27/2026 Hearing on Motion to Compel Further Responses to Requests for Production of Documents, Set One in Department 16D