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Notice Of Motion And Motion To Compel Deposition Attendance Of A Person Most Qualified And Custodian Of Records Of Defendant American Honda Motor Co., Inc., And Request For Sanctions
Set for Law and Motion/Discovery Calendar on Wednesday, July 16, 2025, Line 10. PLAINTIFFs MIGUEL VILLANUEVA,and INGRID MUKUL's Motion To Compel Deposition Attendance Of A Person Most Qualified And Custodian Of Records Of Defendant American Honda Motor Co., Inc., And Request For Sanctions.
Plaintiff's motion to compel the deposition of defendant's person most qualified ("PMQ") and production of documents is granted. The discovery at issue is reasonably calculated to lead to the discovery of admissible evidence. (See Code of Civil Procedure section 2017.010.) Defendant failed to demonstrate the merit of any of its objections, which appear to be boiler plate. Defendant presents no competent evidence showing that the requests are unduly vague or burdensome.
As for scheduling, Plaintiff sought alternative deposition dates on several occasions and defendant failed to respond. (Leite Decl., par. 8.) Defendant must produce the PMQ and all-nonprivileged documents by August 29, 2025. If there are privileged documents, a privilege log should be produced prior to the deposition. Parties to meet and confer regarding a mutually convenient date no later than the identified date.
The court does not find Defendant's actions in connection with this discovery to be substantially justified. Defendant shall pay $2,160 to Plaintiff as sanctions, payable by August 29, 2025.
For the 9:00 a.m. calendar, all attorneys and parties may appear in Department 302 remotely or in person. Remote hearings will be conducted by videoconference using Zoom. (Dept. 302 Zoom ID 160 409 7690; Passcode 516287.) To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number.
Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing.
Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested.
The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/JMQ) | |
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