Motion to Compel Deposition of Person Most Qualified (PMQ) in California

Motion To Compel Deposition of Plaintiff’s Person Most Knowledgeable The Notice of Deposition of Plaintiff’s PMQ included 14 categories of documents to be produced. See Lee Decl., Exh. C. However, Defendant did not make a fact-specific showing of good cause for production of each category of documents, as required by CCP § 2025.450(b)(1). As such, no order compelling such production will issue. Kyung Tae Kang is also the designated PMQ of Plaintiff.

s Motion to Compel Deposition Attendance and Live Testimony of Person Most Knowledgeable 2) Status Conference The Court GRANTS Plaintiff Peter H. Breen, M.D.’s motion to compel the deposition of the person most qualified of Defendant Regents of the University of California (“Regents”), as modified below. The Court GRANTS Plaintiff’s request for judicial notice (ROA 647), except that judicial notice will not extend to the truth of the statements contained therein.

Plaintiff now moves to compel a deposition of Defendant’s Person Most Qualified. (“PMQ”) Defendant opposes the motion.

.: 23NWCV00361 HEARING : 8/23/23 @ 9:30 AM #3 Plaintiff Ma Estela Aguirres Motion to Compel Deposition of Defendants Person Most Knowledgeable and Motion to Compel Further Responses to her Requests for Production of Documents at Deposition are DENIED as MOOT without prejudice. Moving Party to give NOTICE.

.: BC585358 [TENTATIVE] ORDER RE: PLAINTIFF’S MOTION TO COMPEL DEPOSITION OF DEFENDANT’S PERSON MOST KNOWLEDGEABLE Dept. 98 1:30 p.m. April 3, 2017 On June 17, 2015, Plaintiff Brenda Frank (“Plaintiff”) filed this action against Defendant Costco Wholesale Corporation (“Defendant”) for alleged damages arising out of an August 11, 2014 trip and fall. On January 20, 2017, Plaintiff noticed the deposition of Defendant’s Person Most Knowledgeable (“PMK”). The deposition notice included eleven (11) topics.

On September 8, 2020, VW produced its person most qualified, Peter Green, for deposition by Plaintiffs. On September 23, 2020, Plaintiffs withdrew their Motion to Compel Deposition Attendance. On November 16, 2020, Plaintiffs filed a second Motion to Compel Deposition Attendance, arguing the deposition testimony provided by VW’s person most qualified was inadequate. On March 16, 2021, VW filed an Opposition to Plaintiffs’ second Motion to Compel Deposition Attendance.

Costco Wholesale Corporation, et al. 19STCV16192 Willie Etta Evans’ Motion to Compel Deposition of the Employee or Person Most Qualified for Costco Wholesale Corporation TENTATIVE RULING Willie Etta Evans’ Motion to Compel Deposition of the Employee or Person Most Qualified for Costco Wholesale Corporation is granted. Background Plaintiff’s Complaint was filed on May 9, 2019.

Superior Court Case No. 19CECG02708 Hearing Date: April 21, 2022 (Dept. 501) Motion: (1) by Plaintiff to Compel Deposition Appearance of Defendant’s Person Most Knowledgeable and Request for Sanctions (2) by

Superior Court Case No. 19CECG02708 Hearing Date: January 11, 2022 (Dept. 501) Motion: (1) by Plaintiff to Compel Deposition Appearance of Defendant’s Person Most Knowledgeable and Request for Sanctions (2) by

Defendants motion to compel deposition of Holcomb Engineerings Person Most Knowledgeable is granted. Holcomb Engineerings Person Most Knowledgeable is ordered to appear for deposition within 30 days of this hearing. 2. Holcomb Engineering is also ordered to pay $2,460 in sanctions due to the nonappearance of its Person Most Knowledgeable at the prior deposition date.

Motion for an Order Compelling Attendance and Testimony of Plaintiff’s Person Most Qualified and Production of Documents at Deposition: Motions to compel (#1 and #2) The discovery was served on 8-21-18. Despite an effort to meet and confer, no responses have been received. Motion to compel deposition (#3) The PMK deposition was noticed for 9-26-18. The notice of deposition was served on 8-21-18.

DISCUSSION Parties have met and conferred on the issue and agreed to set a PMK deposition date for September 23, 2022. Parties request that the hearing be continued to approximately 30 days after the deposition date; the Court grants this request. CONCLUSION Plaintiff Mackenzie Young Jay Kims Motion to Compel Deposition of Defendants Person Most Knowledgeable is CONTINUED to October 27, 2022, at 1:30 p.m. in Department 28 at the Spring Street Court House.

Plaintiffs Sina, Azadeh, and Sohrab Mardani (Plaintiffs) move to compel the deposition of Defendant County of Los Angeless (Defendant) Person Most Knowledgeable (PMK) with respect to categories No. 16 and 1113, for which Defendant produced as its witness Martin Moreno, who conceded during deposition not being the person most qualified to testify regarding the relevant categories. (Motion at pp. 68, 1013.)

Case Number: 21STCV09057 Hearing Date: March 10, 2023 Dept: 61 Plaintiffs James White and Dawn Jamadars Motion to Compel Deposition of Defendant FCA US, LLCs Person Most Knowledgeable is DENIED with respect to the production of a second person most knowledgeable, but GRANTED with respect to requests for production No. 7, 20, 22, 25, 32, 33, 37, 41, 44, 53, 55, 58, 65, 66, 70, 73, 77, 86, 88, 98, 100, 122124, 127129, 131, 133135, 137, and 145148.

MOTION TO COMPEL PERSON MOST QUALIFIED DEPOSITION AND PRODUCTION OF DOCUMENTS; REQUEST FOR SANCTIONS MOVING PARTY: Plaintiff Eddie Garrett RESPONDING PARTY(S): Defendants Shlomo Rechnitz, et al. PROOF OF SERVICE: ANALYSIS Motion to Compel Deposition Defendants’ argument that the “Apex Doctrine” precludes Plaintiff taking the deposition of Defendant Rechnitz Core, GP’s PMK is not persuasive.

.: 22STCV23683 [TENTATIVE] ORDER GRANTING PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANTS PMK Dept. 48 8:30 a.m. December 21, 2023 On July 22, 2022, Plaintiff Raymundo Hernandez this action against Defendant General Motors LLC for breach of warranties arising from the purchase of an allegedly defective vehicle. On October 11, 2023, Plaintiff noticed the deposition of Defendants person most knowledgeable (PMK), for a deposition on November 1, 2023.

Compelling Deposition On January 4, 2019, Plaintiff served the notice of deposition of the person most knowledgeable (“PMK”) for Defendant. (Motion, p. 3:5-7.) Plaintiff explains that on March 7, 2019, Defendant’s counsel served an objection to the deposition of the person most knowledgeable for Defendant. (Id. at p. 3:7-8.) Plaintiff states that on March 13, 2019, her counsel sent out a meet and confer letter regarding the objection to the deposition. (Id. at p. 3:9-11.)

Defendant indicated its PMQ would appear at the noticed date, subject to the objections asserted. (Abdolhosseini Decl., para. 24, Exh. 7.) On November 6, 2019, Plaintiff again noticed the deposition of Defendant’s person most qualified for January 9, 2020. (Abdolhosseini Decl., para. 25, Exh. 8.) Defendant objected. (Abdolhosseini Decl., para. 26.) On December 27, 2019, Plaintiff again noticed the deposition of Defendant's person most qualified for February 27, 2020.

Case Number: 21STCV34801 Hearing Date: June 20, 2023 Dept: 24 NATURE OF PROCEEDINGS: Hearing on Motion to Compel Deposition Attendance of a Person Most Knowledgeable by Defendant American Honda Motor Co. Inc.; Request for Sanctions TENTATIVE RULING: The above-captioned matters are called for hearing.

MOTION TO COMPEL If a party or an officer, director, managing agent, employee of a party, or person designated as the person most qualified to testify fails to appear for examination or produce documents, the demanding party may move to compel attendance, testimony, and production. (Code Civ. Proc., § 2025.450, subd. (a).) On July 13, 2022, Plaintiff served a notice of deposition of Defendants PMK and requested production of documents, with a deposition and production date of August 15, 2022.

Such an individual is often referred to as a Person Most Knowledgeable (“PMK”) or Person Most Qualified (“PMQ”) depositions. (Code Civ. Proc., § 2025.230.) Code Civ.

.: 20STCV41519 Hearing Date: 9/14/23 Trial Date: 1/16/24 [TENTATIVE] RULING RE: Plaintiffs Ian Zachary Botnick, Candy Michelle Botnick, and Mary Joness Motion to Compel Deposition Attendance and Production of Documents by Defendant BMW of North America, LLCs Person Most Knowledgeable.

Proc., § 2025.450(g)(1).)¿¿ Discussion Motion to Compel Deposition Attendance of PMQ and Custodian of Records ¿ p laintiff moves to compel the deposition of Defendant Kias Person Mos Knowledgeable (PMK) and produce all responsive documents identified in Plaintiffs Notice of Deposition of Kias PMK.

Plaintiffs motion to compel deposition of Staters person most knowledgeable On April 21, 2023, Plaintiff noticed the deposition of Staters person most knowledgeable for May 3, 2023. The notice listed 13 subjects on which Plaintiff would examine the person most knowledgeable. Stater objected, asserting that Plaintiff unilaterally set the deposition. Stater also objected to the subjects of examination listed in the deposition notice.

Case Number: 22STCV12490 Hearing Date: November 8, 2023 Dept: 30 EDDIE WILLIAMS vs RAMOS TOWING LLC Motion to Compel Deposition of Person Most Knowledgeable Motion to Compel Deposition of Person Most Knowledgeable TENTATIVE Plaintiffs motions to compel the deposition of Defendants PMK are GRANTED. Defendant is ordered to produce its PMK for deposition within 30 days of this order. Moving party to give notice.

.: 21STCV08004 [TENTATIVE] ORDER DENYING PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANTS PMK Dept. 48 8:30 a.m. February 9, 2023 On June 16, 2021, Plaintiff Consumer Advocacy Group, Inc. filed a first amended complaint against Defendants Vitacost.com, Inc., Badia Spices, Inc. (Badia), and Amazon.com, Inc., alleging violation of Proposition 65. On January 11, 2023, Plaintiff filed a motion to compel the deposition of Bafias person most knowledgeable (PMK).

On November 26, 2018, Plaintiff noticed a deposition of Winger’s Inc.’s person most knowledgeable (“PMK” or “PMQ”) for December 17, 2018. (Motion, Abramson Decl. ¶ 4, citing to Exh. 1.) On December 12, 2018, Winger’s Inc.’s counsel indicated that someone named Mr. Khodayeki would be attending the PMQ deposition. (Id., Abramson Decl. ¶ 5, citing to Exh. 2.) On December 16, 2018, however, after settlement talks fell apart, Winger’s Inc.’s counsel stated that his client would not attend the deposition.

Case Number: 20STCV25568 Hearing Date: September 7, 2022 Dept: 28 Plaintiff Eric Cottrells Motion to Compel Deposition of Defendant Caliber Bodyworks, Incs Person Most Knowledgeable; Plaintiff Eric Cottrells Motion to Compel Deposition of Defendant Caliber Holdings, LLCs Person Most Knowledgeable Having considered the moving papers, the Court rules as follows.

Vo in Support of Motion to Compel Deposition of Lincoln Transportation Services, Inc.) Plaintiff’s counsel then indicated that he would make the person most knowledgeable to testify for Lincoln Transportation and Cardenas available for deposition in December, but failed to do so. (Ibid.)

.: 21STCV26450 [TENTATIVE] ORDER GRANTING IN PART PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANTS PMK Dept. 48 8:30 a.m. June 6, 2023 On July 19, 2021, Plaintiff Macys Retail Holdings LLC filed this action against Defendant Southern California Edison Company. Plaintiff noticed the deposition of Defendants Person Most Knowledgeable (PMK). Defendant served a response with objections, and the parties met and conferred.

The Court will reserve its ruling on the motion to compel deposition until the further hearing. If the Defendant’s PMQ deposition occurs before the further hearing, the motion to compel will go off-calendar as moot. Plaintiff’s request for sanctions against Defendant is DENIED. DISCUSSION: Motion To Compel Deposition Plaintiff Cheree Martin moves to compel the deposition of Defendant Southern California Permanente Medical Group’s Person Most Qualified (“PMQ”).

MOTION TO COMPEL DEPOSITION Plaintiff’s Motion “to Compel the Defendant’s Person Most Knowledgeable to: 1) Familiarize Himself with the Subject Matter of this Case; 2) Make a Diligent Search for Documents Responsive to Deposition Subpoena; 3) Answer Questions at Deposition” is denied. Defendant designated Darth Eliopulos (the “PMK”), the Vice President Area Manager for the territory in question. Plaintiff took the deposition of Defendant’s PMK on 11/17/2016.

(BC603920) _____________________________________________ Defendant/Cross-Complainant City of Pomona’s MOTION TO COMPEL DEPOSITION OF THE PERSON MOST QUALIFIED OF VALLEY BUSINESS CENTER Responding Party: Defendant/Cross-Defendant/Cross-Complainant, Valley Business Center, LLC Tentative Ruling Defendant/Cross-Complainant City of Pomona’s Motion to Compel Deposition of the Person Most Qualified of Valley Business Center is DENIED.

Fresno Credit Bureau Case No. 22STCV09813 Motions to Compel Plaintiff filed the following motions: (1) Motion to compel further responses to Requests for Production of Documents, set one; (2) Motion to compel further responses to Form Interrogatories, set one; (3) Motion to compel further responses to Special Interrogatories, set one; and (4) Motion to compel deposition of Defendants person most qualified. Defendant did not file oppositions to the motions.

CONCLUSION AND ORDER Therefore, the Court grants in part Plaintiffs Motion to Compel Deposition of Defendant Target Corps Person Most Qualified and Employees & Request for Production of Documents. Justino Schoeder shall appear for deposition within 30 days of the Courts order. Plaintiffs shall give notice of the Courts order and file a proof of service of such.

Case Number: 20STCV00320 Hearing Date: November 30, 2022 Dept: 34 SUBJECT: Motion to Compel Deposition of Defendants PMK and Production of Documents Moving Party : Plaintiffs Stephen Glick and Alfred Garcia Resp. Party : None Plaintiffs Motion is GRANTED in part and DENIED in part. Defendant shall make its person most qualified available for deposition forthwith.

Defendants sought to depose the PMK on July 16, 2019. (Id.) The proof of service of the Deposition Subpoena was made on the Person Most Knowledgeable of R.L.C.S., Inc. dba Red Line Couriers, by personally serving Megan Isner, the person authorized to accept service, on June 24, 2019, at 1267 Willis Street, Ste. 200, Redding, CA 96001. (Tabrisky Decl., Ex. B; POS filed 8/26/19.) Defendants obtained a Certificate of Nonappearance on July 16, 2019. (Id., Ex. C.)

.: 18STCV00257 Hearing Date: December 11, 2019 [TENTATIVE] RULING RE: Plaintiff Ruth Hernandez’s Motion to Compel DEPOSITION OF LEBLEUCHATEAU, iNC.’S PERSON MOST KNOWLEDGEABLE Plaintiff Ruth Hernandez’s Motion to Compel Deposition of Lebleuchateau Inc.’s Person Most Knowledgeable is GRANTED. The Court orders Lebleuchateau Inc. to pay the sum of $500 to Plaintiffs for failure to appear pursuant to the subpoena. FACTUAL BACKGROUND This is an action for elder abuse and wrongful death.

Case Number: 21STCV44429 Hearing Date: January 26, 2023 Dept: 72 MOTION TO COMPEL DEPOSITION Date: 1/26/23 (8:30 AM) Case: Gabriel Garcia v. General Motors LLC (21STCV44429) TENTATIVE RULING : Plaintiff Gabriel Garcias Motion to Compel Deposition of Defendant General Motors LLCs Person Most Qualified is GRANTED.

(1) Motion to Compel Deposition (Oral or Written) (2) OSC re Sanctions/Dismissal Tentative Ruling: Plaintiff TKFBGP Family Ltd. Partnership’s unopposed Motion to Compel Deposition of Defendant Tri-Emerald, Holdings, LLC’s Person Most Knowledgeable (“PMK”) is GRANTED. Defendant Tri-Emerald Holdings, LLC is ORDERED to produce its PMK and to produce the documents requested in the deposition notice for a deposition date to occur within the next four weeks – or at least by December 21, 2018.

Plaintiff’s Motion to Compel Deposition of General Motor LLC’s Person Most Knowledgeable (PMK) and Request for Sanctions. TENTATIVE RULING Plaintiff’s motion to compel the deposition of General Motors, LLC’s Person Most Knowledgeable and Custodian of Records and Request for Sanctions is denied. Plaintiff noticed a deposition of Defendant’s PMK on February 3, 2020 for a February 21, 2020 deposition.

On July 21, 2021, Plaintiff filed a Motion to Compel Deposition of Infinity Realty’s Person Most Qualified as well as a Motion to Compel a Second Deposition of Gavriel Sfaee. The motions had initial hearing dates of February 1 and 2, 2022. On July 27, 2021, Freeman’s Ex Parte Application to continue trial was granted. The Final Status Conference was continued to October 5, 2021 and trial was continued to October 12, 2021.

.: 22STCV13087 (1) MOTION TO COMPEL DEPOSITION OF DEFENDANTS PERSON MOST KNOWLEDGEABLE; REQUEST FOR SANCTIONS (2) MOTION TO COMPEL DEPOSITION OF WITNESS REZA HAGHSHENAS; REQUEST FOR SANCTIONS MOVING PARTY : (1) (2) Plaintiff Albert Santa RESPONDING PARTY(S) : (1) (2) Defendant Sky Asset Management, Inc.

Accordingly, the Court GRANTS the motion to compel deposition and the deposition shall go forward within 10 days. Plaintiff shall serve notice of this ruling.

Discussion Plaintiff moves the Court to order the deposition of Defendants person most qualified (PMQ) within ten calendar days. (Motion to Compel Deposition, p. 7:610.) Plaintiff initially served the Notice of Deposition for the PMQ on January 16, 2024. (Decl. Bedwan, ¶ 16.) Defendant objected to the deposition on January 25, 2024. (Opposition, Exh. A.) The deposition has apparently not yet occurred.

TENTATIVE RULING Plaintiff Magen Osman Taha's unopposed motion to compel deposition attendance and production of documents by defendant FCA US LLC's ("FCA") person most knowledgeable ("PMK") is granted. FCA shall ensure the PMK is available for deposition within 15 days of service of the final ruling and produce the documents. Defendant is ordered to pay sanctions in the amount requested within 15 days.

Plaintiffs brings this Motion to Defendant to produce its person most knowledgeable (PMK) at deposition and to produce documents. Plaintiffs contend that despite properly noticing the deposition and meeting and conferring with Defendant, Defendant has not produced its PMK. Defendant opposes the Motion claiming Defendant is prepared to proceed with the PMK deposition on certain categories but Plaintiffs have failed to properly meet and confer on Defendant’s objections to the remaining categories.

Plaintiffs brings this Motion to Defendant to produce its person most knowledgeable (PMK) at deposition and to produce documents. Plaintiffs contend that despite properly noticing the deposition and meeting and conferring with Defendant, Defendant has not produced its PMK. Defendant opposes the Motion claiming Defendant is prepared to proceed with the PMK deposition on certain categories but Plaintiffs have failed to properly meet and confer on Defendant’s objections to the remaining categories.

Plaintiffs brings this Motion to Defendant to produce its person most knowledgeable (PMK) at deposition and to produce documents. Plaintiffs contend that despite properly noticing the deposition and meeting and conferring with Defendant, Defendant has not produced its PMK. Defendant opposes the Motion claiming Defendant is prepared to proceed with the PMK deposition on certain categories but Plaintiffs have failed to properly meet and confer on Defendant’s objections to the remaining categories.

Plaintiffs brings this Motion to Defendant to produce its person most knowledgeable (PMK) at deposition and to produce documents. Plaintiffs contend that despite properly noticing the deposition and meeting and conferring with Defendant, Defendant has not produced its PMK. Defendant opposes the Motion claiming Defendant is prepared to proceed with the PMK deposition on certain categories but Plaintiffs have failed to properly meet and confer on Defendant’s objections to the remaining categories.

FCA US, LLC'S PERSON MOST QUALIFIED *TENTATIVE RULING:* Plaintiff’s motion to compel deposition of Defendant FCA Us LLC’s Person Most Qualified is granted.

J.W. v Glendale USD MOTION TO COMPEL DEPOSITION Calendar: 4 Case No: BC617522 Date: 7/7/17 MP: Plaintiff, J.W., a minor through her guardian ad litem, Laurie Wilson RP: Defendant, Glendale Unified School District RELIEF REQUESTED: 1. Order compelling Defendant to produce its person most knowledgeable for a deposition. 2. Order imposing monetary sanctions of $1,260.

Motion to Compel Deposition (Oral or Written) filed by Martin B Theis, Renn Transportation, Inc. Defendants/Cross-Complainants Martin Buckley Theis and Renn Transportation, Inc.’s unopposed motion to compel the deposition of Cross-Defendant Bunzl Distribution USA, Inc.’s person most knowledgeable (PMK) with production of documents is GRANTED. The deposition of the PMK is to address category numbers 3 and 12, and production of documents numbers 1, 8, 9, 11, 12, 13, and 15 (with redactions if applicable.)

Coldren's Motion to Compel Deposition of Defendant's PMK The court GRANTS Plaintiff Coldren's motion to compel the deposition of Defendant FCA US LLC's Person Most Knowledgeable. Defendant's PMK shall appear for deposition and produce the documents requested in the notice of deposition within 30 days, at a mutually agreeable time, at the location specified in the notice of deposition. Plaintiff's request for sanctions is DENIED.

.: BC686522 Hearing Date: February 20, 2019 [TENTATIVE] order RE: MOTION to compel deposition of defendant KEYES WOODLAND HILLS BUICK GMC CADILLAC’S person most knowledgeable ANALYSIS “If, after service of a deposition notice, a party to the action. . . without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed with it. . . the party giving the notice may move for an order compelling the deponent's attendance and testimony. . . .”

Defendant concedes that it must produce a person most qualified to testify in response to Plaintiff’s deposition notice. (Defendant’s Opposition, at p.7.) Therefore, the motion is granted. The Court is not sympathetic to Defendant’s argument that it requires additional time to identify persons most qualified to testify to each of the topics in Plaintiff’s deposition notice.

Defendant is to produce the person most knowledgeable 20 days from this order.

.: 21STCP03351 Hearing Date: June 6, 2023 Claimants Jesse Rioss and Lydia Rodriguezs motion to compel appearance and deposition of Defendant Liberty Mutual Fire Insurance Companys, person most qualified is granted. Respondent Liberty Mutual Fire Insurance Company is ordered to produce its person most qualified for deposition within 15 days.

American Honda 03/01/2024 in Department 41 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 Motion: Plaintiff’s motion to compel deposition of PMQ and custodian of records and for sanctions (Opposed) Tentative Ruling: The motion requested that the Court order Defendant to produce for deposition a PMQ on various categories and a custodian of records.

.: BC631000 Hearing Date: October 30, 2017 [TENTATIVE] order RE: Motion to compel deposition defendant’s person most knowledgeable “If a deponent fails to answer any question or to produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in the deposition notice or a deposition subpoena, the party seeking discovery may move the court for an order compelling that answer or production.

Motion to Compel Designation of New PMK The motion of the plaintiff to compel defendant Los Alamitos Surgical Center, LP, to designate a new Person Most Knowledgeable as to Examination Categories 8-11 is DENIED. Defendant Los Alamitos Surgical Center, LP, produced its Person Most Knowledgeable for deposition. The PMK refused to answer certain questions on relevance grounds on the advice of counsel.

Motion to Compel Deposition and Production of Documents Pursuant to Subpoena Defendant moves an order compelling Jos. A. Banks Person Most Knowledgeable (PMK) to attend deposition and produce documents pursuant to the Deposition Subpoena. (CCP § 2025.450(a).)

Accordingly, Plaintiff’s Motion to Compel the Deposition of Defendant’s Person Most Knowledgeable with respect to Plaintiff’s “Request for Production of Documents and Things for Inspection and Copying, Set No. Two,” is GRANTED. Conclusion Therefore, Plaintiff’s Motion to Compel Deposition of Defendant L.A. Checker Cab Company, Inc.’s, Person Most Knowledgeable is GRANTED. Moving party is ordered to give notice.

SUBJECT: Motion to Compel Deposition of Defendant’s Person Most Knowledgeable and Production of Documents Moving Party: Plaintiff Rafael Vicente Resp. Party: General Motors, LLC The motion to compel deposition of Defendant’s PMK and production of documents is DENIED. Plaintiff’s request for sanctions is DENIED. PRELIMINARY COMMENT: Plaintiff’s motion and separate statement fail to include page numbers.

MOTION TO COMPEL DEPOSITION OF PERSON MOST KNOWLEDGEABLE OF; REQUEST FOR SANCTIONS MOVING PARTY: Plaintiff John Hastie, by and through his Successor in Interest, Sandra Hastie RESPONDING PARTY(S): Defendants Shlomo Rechnitz, Rockport Administrative Services, LLC and CNRC, LLC STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: This is an Elder Abuse case.

.: 21STCV33923 [TENTATIVE] ORDER GRANTING PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANTS PMK; GRANTING PLAINTIFFS MOTION TO DEEM RFAs ADMITTED Dept. 48 8:30 a.m. January 18, 2024 On September 14, 2021, Plaintiff Leo Cordova this action against Defendant Long Spring Freight LLC and others. On October 6, 2023, Plaintiff served a Notice of Deposition of Defendants Person Most Knowledgeable (PMK) and an Amended Second Set of Requests for Admission (RFAs) on Defendant.

.: 21STCV33923 [TENTATIVE] ORDER GRANTING PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANTS PMK; GRANTING PLAINTIFFS MOTION TO DEEM RFAs ADMITTED Dept. 48 8:30 a.m. January 2, 2024 On September 14, 2021, Plaintiff Leo Cordova this action against Defendant Long Spring Freight LLC and others. On October 6, 2023, Plaintiff served a Notice of Deposition of Defendants Person Most Knowledgeable (PMK) and an Amended Second Set of Requests for Admission (RFAs) on Defendant.

RUAN TRANSPORT CORPORATION *HEARING ON MOTION TO COMPEL DEPOSITION OF PERSON MOST KNOWLEDGEABLE OF DEFENDANT WHOLE FOODS MARKET CALIFORNIA, INC. AND FOR SANCTIONS FILED BY: CHAVEZ, RICHARD HENRY *TENTATIVE RULING:* The motion is deemed moot; Defendant has agreed to produce its PMK. Sanctions are denied.

Motion to Compel Deposition of Person Most Qualified On June 9, 2023, Plaintiff filed this instant motion to compel deposition of Defendants person most knowledgeable and production of documents. No opposition was filed. On July 10, 2023, Plaintiff filed a reply. This indicates that Defendant served Plaintiff a copy of the opposition, but did not file it with the Court.

BC698814 PAMELA OSKEY ET AL VS GENERAL MOTORS LLC ET AL Plaintiffs’ Motion to Compel Deposition of GM’s Person Most Knowledgeable and Requests for Production of Documents TENTATIVE RULING: The motion to compel is granted. Defendant is ordered to produce a PMK on all requested categories and is further ordered to produce the requested documents.

Conclusion Plaintiffs Fidel Hernandez Medina and Patricia Hernandezs Motion to Compel Deposition Attendance and Production of Documents by Defendant Toyota Motor Sales, U.S.A., Inc.s Person Most Knowledgeable is DENIED.

Defendant Mohammad Mahani’s Motion to Compel Deposition and Production of Records of the Person Most Knowledgeable and/or Custodian of Records of Avanguard Surgery Center Re: Medical and Billing Records of Plaintiff Tadeo Marquez is GRANTED. Avanguard to produce a Person Most Knowledgeable and/or Custodian of Record within twenty days of this order.

Tentative ruling for May 20, 2019 on Plaintiff Jeffrey Rudin's Motion to Compel Deposition of Defendant Jaguar Land Rover North America LLC's "Person Most Knowledgeable" and Production of Documents at Deposition The court grants, in part, Plaintiff Jeffrey Rudin's request for an order compelling the deposition of Defendant Jaguar Land Rover North America LLC's ("Jaguar") "person most knowledgeable" ("PMK") and production of documents at deposition.

Case Number: 21STCV12959 Hearing Date: June 6, 2023 Dept: 61 Plaintiff Llasveli Hernandezs Motion to Compel Deposition of Defendant Nissan North Americas Person Most Qualified is GRANTED. Sanctions are awarded against Defendant in the amount of $1,575. Plaintiff to give notice. I.

Plaintiff Chris Rossi (“Plaintiff”) moves to compel the deposition of Defendant General Motors, LLC’s person most knowledgeable (“PMK”) and order Defendant to produce documents pursuant to the deposition subpoena. This is a lemon law case stemming from Plaintiff’s purchase of a new 2015 Cadillac Escalade. On March 7, 2018, Plaintiff noticed the deposition of General Motors LLC’s Person Most Knowledgeable with production of documents. (Barry Decl. Exh. 1.)

On November 29, 2021, Plaintiff filed a Motion to Compel Deposition of Uber Techs Person Most Qualified to be heard on June 15, 2022. The Court continued the hearing on the motion to July 1, 2022. Defendants filed an opposition on June 2, 2022. On June 8, 2022, Plaintiff filed a reply. Trial is currently scheduled for November 16, 2022.

On November 29, 2021, Plaintiff filed a Motion to Compel Deposition of Uber Techs Person Most Qualified to be heard on June 15, 2022. The Court continued the hearing on the motion to July 1, 2022, and then again to July 14, 2022. Defendants filed an opposition on June 2, 2022. On June 8, 2022, Plaintiff filed a reply. Trial is currently scheduled for November 16, 2022.

Tenative Ruling 2 of 2 MOTION TO COMPEL DEPOSITION AND PRODUCTION OF DOCUMENTS AND REQUEST FOR SANCTIONS (CCP § 2025.450) TENTATIVE RULING: Plaintiff Linda Carrs Motion to Compel Deposition of Person Most Knowledgeable and Production of Documents; Request for Sanctions is GRANTED AS TO APPEARANCE AT DEPOSITION AND DENIED AS TO PRODUCTION OF DOCUMENTS.

Notice Of Motion And Second Motion To Compel Deposition And Deposition Answers Of Cpmcs Person Most Qualified And For Sanctions The matter is on calendar for Tuesday, February 6, 2018, Line 2, PLAINTIFF WAYNE RUDEN'S Notice Of Motion And Second Motion To Compel Deposition And Deposition Answers Of CPMC's Person Most Qualified And For Sanctions.

Defendant is ordered to produce its PMQ within 10 days. The Court notes Defendant previously identified Mr. Tom Lynch at the person most qualified to testify. Mr. Lynchs desire to resign as CEO by some unspecified date does not disqualify him from testifying as the person most qualified to testify on behalf of Defendant.

to compel deposition of defendant Angel Hernandez, dba Costless Plumbing Heating & Air Conditioning’s person most qualified Tentative Ruling: To grant.

The motion to compel deposition is GRANTED. Conclusion Plaintiff Ahmad Chihas Motion to Compel the Deposition of Aston Martin Lagonda of North America, Incs Person Most Knowledgeable, with Production of Documents is GRANTED. The Court will discuss a date for the deposition with counsel at the hearing.

[TENTATIVE] ORDER GRANTING PLAINTIFFS MOTION TO COMPEL DEPOSITION TESTIMONY FROM DEFENDANTS EMPLOYEES AND PERSON MOST QUALIFIED; REQUEST FOR SANCTIONS The complaint alleges that Defendant employed Plaintiff as a meat clerk. Plaintiff alleges that Defendant retaliated against him after he reported unlawful label tampering on meat products by changing the expiration date.

Motion to Compel Deposition of Person Most Knowledgeable of Jimbo J. Inc. filed by Pltf Silvio Thomas; Motion to Compel Deposition of PMK of Jimbo J Inc. is DENIED. Plaintiffs may not serve deposition notices until 20 days after service of summons or appearance of any defendant. [CCP § 2025.210(b)] Defendants have not appeared in the action and there is no proof of service filed with the court confirming service on defendants.

Velasquez's unopposed motion to compel deposition of a person most knowledgeable and custodian of records of defendant General Motors LLC is granted. Defendant shall produce the PMK, and produce all responsive documents identified in plaintiff's notice of deposition. Plaintiff is granted sanctions in the amount of $800.00. The deposition may be done via a video conference platform within three weeks, with plaintiff to make the arrangements and inform all parties in advance.

KEATING STEVEN PABROS PLAINTIFF SUZANNE HEDMA’S MOTION TO COMPEL DEPOSITIONS OF DEFENDANT THE SHORESIDE RESIDENTS ASSOCIATIONS PERSON MOST KNOWLEDGEABLE AND REQUEST MONETARY SANCTIONS TENTATIVE RULING: The Motion of Plaintiff Suzanne Hedman to Compel Deposition of Defendant The Shoreside Residents Association’s Person Most Knowledgeable (PMK) (Motion) is GRANTED.

Plaintiff’s motion to compel deposition attendance and production of documents by defendant Elk Grove Volkswagen’s person most knowledgeable (PMK) is denied without prejudice.

Case Number: 20STCV25399 Hearing Date: April 19, 2022 Dept: 28 Motion to Compel Deposition of Person Most Knowledgeable Having considered the moving papers, the Court rules as follows. BACKGROUND On July 7, 2020, Plaintiff Shaun Gartin (Shaun) filed this action against Defendant Nvard Muradyan (Defendant) for negligence and negligence per se.

The court has reviewed Plaintiff’s Motion to Compel Further Responses to Requests for Production of Documents and Motion to Compel Deposition of Defendant’s Person Most Qualified (“PMQ”) and responds by imposing this court’s “Case Management Conference Order (Song-Beverly Litigation),” which will be provided to counsel under separate cover.

Plaintiffs’ (Miguel Hernandez and Miguel Angel Hernandez) Motion to Compel Deposition Attendance of Defendant Nissan North America, Inc.’s Person Most Knowledgeable and Custodian of Records (Motion), filed on 5-26-20 under ROA No. 48, is GRANTED.

[Tentative] Ruling Plaintiffs Motion to Compel Deposition Attendance of a Person Most Qualified and Custodian of Records of Defendant American Honda Motor Co., Inc. is GRANTED.

CONCLUSION Plaintiff Lena Swifts Motion to Compel Deposition of Defendants Person Most Knowledgeable is GRANTED. Defendant is ordered to produce the PMK(s) for a deposition to occur within 30 days of the hearing on the motion or another mutually agreed upon date. Defendant is ordered to produce the relevant, requested documents 1 week prior to the deposition.

[TENTATIVE] RULING: Plaintiff Hovik Pashayans Motion to Compel Deposition of Mercedes-Benz USA, LLCs Person Most Qualified is GRANTED.

On November 13, 2023, Plaintiff filed the instant Motion to Compel Deposition Attendance and Production of Documents by Defendant SM BMWs person most knowledgeable (PMK). On April 9, 2024, SM BMW filed its Objection. Subsequently, Plaintiff filed their Reply on April 18, 2024.

Plaintiffs move to compel deposition attendance and production of documents by Defendant AMERICAN HONDA MOTOR CO., INC.s (Defendant) person most knowledgeable (PMK).

BC710580 CONSTANCE HARDEN ET AL VS GENERAL MOTORS LLC Plaintiff’s Motion to Compel Deposition of Person Most Knowledgeable TENTATIVE RULING: The motion is granted in part. Defendant is ordered to designate a PMK for categories 3, 5, 10, 12, 16, 17, 19, 20, 21, 23, 24, and 25. Defendant is ordered to provide a further response, without objections and with a privilege log, to request numbers 4, 5, 6, 7, 8, 9, 11, 24, and 47. The deposition is to take place within 15 days.

The motion of the plaintiffs to compel Deposition of the Person Most Qualified and a motion to compel responses to a Request for Production of Documents are GRANTED as follows: Motion to Compel Deposition Counsel for defendants filed opposition and a declaration that essentially argues the delay in providing the PMQ was excusable because the prior PMQ has left and defendants have not yet hired a new one.

ANALYSIS Motion To Compel Deposition Plaintiffs move to compel the deposition of Defendant FCA US LLC’s Person Most Knowledgeable with production of documents and requests monetary sanctions. Plaintiff argues that Defendant refused to produce a PMK for the deposition noticed for January 22, 2020, only provided one alternative date, and refuse to produce documents at the deposition as set forth in the notice of deposition.