ZIJING WANG VS. FORD MOTOR COMPANY ET AL

Matter on the Law & Motion / Discovery calendar for Tuesday, September 2, 2025, Line 4 [Part 1 of 2 of the tentative ruling].

PLAINTIFF ZIJING WANG's Motion To Compel Further Responses To Plaintiff's Request For Production Of Documents, Set One. Plaintiff Zijing Wang seeks an order compelling Ford Motor Company to make further responses to Wang's Requests for Production of Documents, Set One, Request Nos. 1-31. The motion is granted in part and denied in part and the court orders sanctions against Wang.

The court concludes that Ford's offer of production of the documents set out below is sufficient and proportionate to the needs of the case:

o Documents Related to the Subject Vehicle: documents related to the service and repair of the subject vehicle, including records of communications with dealer personnel and call center personnel concerning the subject vehicle.

o Policies and Procedures: Warranty Guide applicable to the subject vehicle; Warranty Policy and Procedure Manual, subject to protective order; and Ford's written statements of policy and/or procedures used to evaluate customer requests for repurchase or replacement pursuant to "Lemon Law" claims, including ones brought under the Song-Beverly Consumer Warranty Act, subject to protective order.

o Other Customer Complaints: A list or compilation of customer complaints in defendant's electronically stored information database that are substantially similar to the alleged defects claimed by plaintiffs, in vehicles purchased in California for the same year, make, and model of the subject vehicle.

o Field Service Actions: A list of Field Service Actions ("FSA") applicable to the subject vehicle, and FSAs for vehicles purchased or leased in California for the same year, make, and model of the subject vehicle.

It appears that Ford has not yet made full production because the protective order the parties agreed to has been submitted to the court but not yet signed and filed. The court requests that the parties email the stipulated protective order to Contestdept301tr@sftc.org by the hearing date and the court will sign and enter it forthwith. In the future, if a stipulation remains outstanding for more than two weeks, the court invites the parties to contact the clerk of this department for assistance. Ford is ordered to complete its production of all documents identified above, to the extent it has not done so, within 15 days of notice of entry of the protective order.

Wang seeks a much broader discovery order. The court concludes that Wang has not carried the burden of setting forth specific facts showing good cause for production beyond the documents identified above. (See Code Civ. Proc., section 2031.310, subd. (b)(1).) Generally the documents identified by Ford above are a good approximation of the universe of relevant and proportionate discovery in a garden-variety Song-Beverly Act case. To obtain additional discovery (such as, for example, drafts of warranty repurchase policy manuals or correspondence about what should go into warranty repurchase policy manuals), a moving party should be prepared to explain why there is good cause specific to the particular case at hand to produce additional materials. Wang's moving papers offer no explanation that is specific to this case and are therefore unpersuasive.