Notice Of Motion And Motion To Compel The Deposition Of Defendants Person Most Knowledgeable And Production Of Documents
Matter on calendar for Wednesday, July 2, 2025, Line 7, PLAINTIFF STEVEN SORIANO's Motion To Compel The Deposition Of Defendants Person Most Knowledgeable And Production Of Documents.
Plaintiff's motion for defendant GM to produce its PMK for examination regarding matters 1-5 and 12-14 and produce documents (requests 1-9) is GRANTED. The deposition was set for May 14, 2025. Defendant served its untimely objections on May 13, 2024. (Cao Decl., Ex. 4.) Per CCP 2025.410(a), defendant has waived its objections (which were boilerplate). Plaintiff attempted to meet and confer in good faith. The cited discovery is reasonably calculated to lead to the discovery of admissible evidence.
Plaintiff's "other vehicle" requests regarding the same alleged defects is proper. (See Donlen v. Ford Motor Co. (2013) 217 Cal.App.4th 138, 154 [explaining probative value of "other vehicle" evidence]; Santana v. FCA US, LLC (2020) 56 Cal.App.5th 334, 346-347 [noting intentionally inadequate "repair" of fuel pump based on defendant's prior knowledge].) Defendant presents no competent evidence showing that the requests are unduly burdensome.
Defendant's PMK shall appear for deposition and defendant shall produce the cited documents by July 16, 2025. The record does not show Defendant acted with substantial justification with respect to this discovery. Defendant shall pay $500 as sanctions, payable to the court by way of the clerk of the court (a copy of this order to accompany payment), payment no later than by August 25, 2025, receipt filed no later than September 3, 2025. (See Code of Civil Procedure section 2025.450(g).)
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