Joseph B. Carvalho v. Volkswagen Group of America, Inc.

Joseph B. Carvalho v. Volkswagen Group of America, Inc.

Plaintiff’s Motion to Compel Deposition of Defendant’s Experts with Document Production

Hearing Date: May 29, 2026

PARTIES TO APPEAR on Plaintiff Joseph B. Carvalho’s (“Plaintiff”) motion to compel Defendant Volkswagen Group of America, Inc. (“Defendant”) to produce documents and its designated expert for deposition. After reviewing the moving and opposing papers, and keeping in mind that Plaintiff will orally reply to the opposition on the day of the hearing, the parties should be prepared to address the following:

1. Should the Court deny the motion without prejudice due solely to Plaintiff’s insufficient notice for defense expert Tom Ressman’s deposition and document production? [See Opp. at 4-5; First Amended Notice, Exh. D to Simpson-James Decl.; Objections to First Amended Notice, Exh. 21 to Souto Decl.; Code Civ. Proc. §§ 2025.270(a) (notice must be served at least 10 days before the date set for deposition), 1010.6(a)(1)(B) (any period of notice shall be extended after service by electronic means by two court days), and 2025.410(a) (objections must be served at least three calendar days before the deposition).]

2. When will Defendant produce Mr. Ressman to comply with Plaintiff’s deposition request?

3. Have the parties settled on a date for Mr. Ressman to inspect Plaintiff’s 2024 Volkswagen Atlas (the “Subject Vehicle”)?

4. Have the parties agreed to a limited extension of the expert discovery deadline, specifically for both the inspection of the Subject Vehicle and Mr. Ressman’s deposition?

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