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Filing # 91653269 E-Filed 06/25/2019 03:38:29 PM
IN THE CIRCUIT COURT OF THE TWENTIETH:
JUDICIAL CIRCUIT IN AND: FOR,.COLLIER
COUNTY; FLORIDA
So CASE NO! 11-2019-CA-001892-0001-XX.
‘NAPLES SERVICE & SUPPLY-INC,
Plaintiff,
v
‘FCA US LLC,
Defendant:.
/
FCA-US-LLC’S RESPONSE TO PLAINTIFF'S
REQUEST FOR PRODUCTION
FCA US LLC.(“FCA US”) responds to Plaintiff's Request for Production’as follows:
These résponses are made solély for'the ptitpose of this action.. Eacly response is made
subject. to all ‘objections as'to competence, materiality, selevance or ‘other’ objection as'‘to
admissibility ‘that may apply ‘in the event'that any:such response, or the information contained
therein, is sought:to‘be.used in court. FCA US'expressly reserves all such objections.
REQUEST NO. ‘I All pre-delivery repair orders. relating to’the subject vehicle:in your
‘possession:
RESPONSE NO: 1: FCA/US will produce a copy of the:warranty claim records:for‘t the
2014 Rait'2500, VIN 3C6UR4HJ3EG117531.
, FCA US otherwise objects to this.request because it is overly broad, unduly burdensonié,
and: seeks: information neither relevant, nor reasonably ‘calculated. to, lead. to, the discovery of
‘admissible evidence.
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/25/2019 03:38:29 PMREQUEST NO. 2: All post-delivery repair orders relating to the subject vehicle in your
possession.
RESPONSE NO. 2: FCA US will produce a copy of vehicle repair records obtained from
authorized dealerships for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531. FCA US also
refers Plaintiff to the warranty claim records for the 2014 Ram 2500, VIN
3C6UR4HJ3EG1 17531, produced in response to Plaintiff's Request for Production No. 1.
FCA: US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant ino reasonably calculated to lead -to the discovery of
admissible evidence.
REQUEST NO. 3: All technicians’ and/or mechanics’ notes relating to the’ subject
vehicle in your possession.
RESPONSE NO. 3: FCA US refers. Plaintiff to the vehicle repair records produced in
response to Plaintiffs Request for Production No. 2. FCA. US also refers Plaintiff to the
warranty claim records for the 2014 Ram. 2500, VIN 3C6UR4HJ3EG117531, produced in
response to Plaintiff's Request for Production No. 1.
FCA US otherwise objects to'this request because it is overly broad, unduly burdengoine,
and seeks information neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence.
REQUEST NO. 4: All documents identifying time:stamps and/or time punches relating
to the time spent performing repairs to the subject vehicle in your possession.
, RESPONSE NO. 4: FCA.US refers Plaintiff to the vehicle repair records produced in
response to Plaintiff's Request for Production, No. 2. FCA US also refers Plaintiff to thewarranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531, produced. in
response to Plaintiff's Request for Production No. 1. .
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and. seeks information neither relevant nor reasonably calculated. to lead to the discovery of
admissible evidence.
REQUEST NO..5:. ‘The warranty repair history relating to the subject vehicle as kept in
its ordinary course of business by Defendant. This document includes all computer records’
“evidencing monetary amounts reimbursed to Defendant's authorized dealership(s).
‘RESPONSE. NO. 5: FCA US refers Plaintiff to the warranty claim records for the 2014
Ram 2500, VIN 3C6UR4HJ3EG1 17531, produced. in response: to Plaintiffs Request for
Production No. 1.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information. neither, relevant nor reasonably calculated to lead ‘to ‘the discovery of
admissible evidence.
REQUEST NO. 6: All internal reports, memoranda, correspondence and zone office
reports pertaining to the subject vehicle.
RESPONSE ‘NO. 6: FCA US. will produce a copy: of available. Customer Assistance
Inquiry. Records (CAIRs) containing communications with Plaintiff concerning the 2014 Ram
2500, VIN 3C6UR4HJ3EG117531. FCA.US also refers Plaintiff to the warranty claim records
produced in response to Plaintiff's Request for Production No. 1.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and. seeks information neither relevant nor reasonably ‘calculated to lead’ to the: discovery’ ofadmissible evidence. FCA US further objects to this request to the extent it seeks: information
protected from disclosure by the work product doctrine or attorney-client privilege.
REQUEST NO. 7: All reports, memoranda, correspondence, zone office reports and/or
any other documentation. created by Defendant. or its authorized dealership(s) due'to Plaintiff's
contact with Defendant or its authorized dealership(s) by way of either writing, telephone or in
person.
RESPONSE NO. 7: FCA.US refers Plaintiff to the documents produced in response to
Plaintiff's Request for Production Nos..1, 2, and 6.
FCA US otherwise objects to’ this request because it is overly broad, unduly burdeisome,
and ‘seeks information neither relevant nor reasonably calculated ‘to lead to ‘the discovery of
admissible evidence.
REQUEST NO. 8: All records, invoices, and other documentation relating to the sale of
and/or purchase of the vehicle in your possession,
RESPONSE NO. 8: FCA US was not a party to the sale of the-2014 Ram 2500, VIN
3C6UR4HJ3EG117531, to Plaintiff. FCA US will produce a copy of the Vehicle Information
Detail Report for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant nor ‘reasonably calculated to lead to the discovery of
admissible evidence. FCA US also, objects'to this request for documents that are equally or more
readily available to Plaintiff.
REQUEST NO. 9: All copies of all written warranties issued by Defendant and/or-its
authorized dealership(s) regarding the vehicle. This request is being made to obtain an authentic,
unaltered copy.RESPONSE NO. 9: A booklet: containing written limited warranties accompanied the
2014.Ram 2500, VIN 3C6UR4HJ3EG117531, when it was distributed. FCA US will produce. a
copy of the booklet for the 2014 Ram 2500.
FCA US otherwise objects to this request because the term "warranties" is not defined,
REQUEST NO. 10: Any and all documents relied upon by Defendant in formulating its
answer and affirmative defenses.
RESPONSE NO. 10: In addition to the docunients produced in response to Plaintiff's
Request, for Production Nos. 1, 2, 6, 8, and 9, FCA US will produce ‘a. copy of the owner’s
‘Manual and user guide for the 2014 Ram 2500.
FCA US otherwise: objects. becatise this request is premature as discovery has just
commenced, FCA US will supplement this response pursuant to'the deadlines established in the
scheduling order. FCA US also objects to this request to the extent it: seeks information
protected from disclosure by the attorney-client privilege or work product doctrine.
REQUEST NO. 11: All documents. upon which Defendant relies in believing its
arbitration program meets the substantive provisions of the Magnuson-Moss Warranty. Act; 16
CFR Part:703; and/or any applicable state law provisions.
RESPONSE NO. 11: FCA US doés not offer an informal dispute resolution procedure
pursuant to 16 CFR §703.
REQUEST NO. 12: All mechanical documents (as described in the definition section
above) applicable to the same year, make and model for vehicle as identified in your answer to
Interrogatory number 2,
RESPONSE NO:.12: FCA US ‘will produce an index. of Technical. Service Bulletins
(TSB), ‘recalls, and Customer, Satisfaction. Notifications that may be applicable to the 2014 Ram2500.. TSBs, recalls, and Customer Satisfaction Notifications are vehicle-specific and identify
the ‘vehicles ‘to which they apply, sometimes by VIN or build date. The indexes produced will
contain the TSB, recall, or Customer Satisfaction Notification number and a description of the
TSB, recall, or Customer. Satisfaction. Notification. If Plaintiff will identify, by number, a
particular TSB, recall, or Customer Satisfaction Notification that:may be reasonably at issue in
this case, FCA US will respond further. FCA US: will also search for and produce a copy of any
Rapid Response Transmittals it. locates that may be. applicable to this vehicle and may be
reasonably at issue in this case.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant nor reasonably calculated to lead to the discovery of:
admissible evidence.
REQUEST NO. 13: All "Talking Papers," "Quick Service Fixes," "Level Four
documents," "advanced service information," "rapid ‘response," special ‘service information,
technical training materials, continuing education materials, VSSM service. library articles,
‘Manufacture Audit Sampling Reports, Tech II bulletins, Know How Videos, engineering reports,
analysis or memorandum, and any and all. other documents referencing. investigations or
inquiries performed which relate to the allegations made‘herein regarding vehicles of the same
year, make and model as Plaintiff's.
RESPONSE NO. 13: FCA US ‘refers. Plaintiff to FCA. US’s ‘response to Plaintiff's
Request for Production No. 12.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and. seeks information neither relevant nor reasonably calculated to lead to the discovery’ of
admissible evidence.REQUEST NO. 14: The report of any expert witness Defendant intends to call at the
trial of this‘case.
RESPONSE: NO. 14: FCA US objects to this request because it :is premature as
discovery has just commenced and FCA US has not yet identified the expert witnesses it may
call to testify at trial. FCA US will ‘supplement this response pursuant ‘to the deadlines
established inthe scheduling order. FCA US also. objects to:this request to the extent it seeks
information protected from disclosure by the work product doctrine or non-testifying expert rule.
REQUEST NO. 15: Any and all documents made: available to Defendant's expert
witnesses relating to the subject vehicle, Plaintiff, or this lawsuit.
RESPONSE. NO. 15: FCA US objects to this request ‘because it is premature as
discovery has just commenced and FCA US has not yet identified the expert witnesses it may
call to. testify at: trial. FCA US. will ‘supplement this response pursuant to the: deadlines
established in the scheduling order. FCA US also objects to this request:to the'extent it seeks
information protected from disclosure by the work product doctrine or non-testifying expert rule.
REQUEST NO. 16:, Curriculum vitae for any expert witness that Defendant intends to
call in this case.
RESPONSE NO. 16: FCA US objects to ‘this request: because it is premature. as
discovery has just. commenced and FCA US has not yet-identified the expert witnesses it. may
call to testify at trial. FCA US will supplement ‘this response ‘pursuant to the deadlines
established in the scheduling order. FCA-US also objects'to this request to the extent it seeks
‘information protected from disclosure by the work product doctrine or non-testifying expert rule.
REQUEST NO. 17: Any non-privileged.communications provided to. Defendant's expert
witnesses relating to the subject vehicle.RESPONSE NO. 17: FCA US objects to this request because it is premature as
discovery-has just commenced and FCA US. has not yet identified the expert witnesses it may
call, to testify. at ‘trial. FCA.US will: supplement. this response: pursuant to. the deadlines
established in the scheduling order. FCA US also objects to this request to’the extent it. seeks
information protected.from disclosure by the work product doctrine or non-testifying expert rule.
REQUEST NO. 18: Any and all documents prepared or received by Defendant's expert.
witness, including but not limited to: notes, reports, memorandum, and communications relating
to the subject vehicle.
RESPONSE NO. 18: FCA US objects to this request because it is premature as
discovery has just commenced and FCA US has not yet: identified the expert witnesses it may
call to: testify at trial. FCA US will supplement ‘this response pursuant to the deadlines
established:in the scheduling order: FCA US also objects 'to this request to the extent it seeks
information protected from disclosure by the work product doctrine or non-testifying expert rule.
REQUEST NO. 19: Any and all documents, papers, correspondence, memos, repair
orders, work orders, computer print-outs; vehicle inquiry reports, documents, or. receipts
evidencing the performance of any Tepair work, whether covered under Defendant's warranty or
not, relating to the subject vehicle.
‘RESPONSE 'NO. 19: FCA US refers Plaintiff to the documents produced in response to
Plaintiff's Request for Production Nos. 1 and 6.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant: nor reasonably calculated to lead: to the discovery of
admissible evidence.REQUEST NO. 20:. All sales brochures, sales‘manuals, literature, pictures,:or any other
promotional literature produced for the vehicle which is the subject matter of this litigation:
RESPONSE:NO. 20: FCA US will produce a copy of the sales brochure for the 2014
Ram 2500.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant nor reasonably’ calculated to lead ‘to the discovery of
admissible evidence.
REQUEST NO. 21: Any franchise contract(s) between. Defendant and its authorized
dealership(s) that performed repairs to the vehicle.
RESPONSE NO. 21: FCA US objects:to this request because it is overly broad, unduly
burdensome, and seéeks .information. neither relevant: nor reasonably calculated to lead. to the
discovery of admissible evidence.
REQUEST NO. 22: Every’ documient that constitutes an’ extended. service contract or
warranty given by Defendant, its authorized. dealership(s) or some third party 'to the Plaintiff
covering the vehicle.
RESPONSE NO..22: FCA US objects to this request because it is overly broad, unduly
burdensome, and seeks information neither relevant. nor, reasonably: calculated to lead to the
discovery of admissible. evidence. FCA. US also objects to. this réquest because it seeks
documents more readily available to Plaintiffs.
REQUEST NO. 23: All written communications in Defendant's possession relating to
the subject’ vehicle and its alleged defects or non-conformities, and/or Plaintiffs request ‘that
Defendant accept the return of the vehicle.RESPONSE NO. 23: ‘FCA US refers Plaintiff to the documents produced in response to
Plaintiff's Request for Production No. 6.
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information. neither relevant nor. reasonably calculated. to lead to the discovery’ of
admissible evidence.
REQUEST NO. 24: Provide all documentation supporting Defendant's and its authorized
dealership(s) policies to‘perform "goodwill" repairs (or any repairs performed that were free of
charge to Plaintiff but not covered under Defendant's written warranty) to the subject vehicle.
RESPONSE NO: 24: FCA US will produce'a copy of the. portion of the Warranty
Administration Manual that refers to warranty goodwill adjustments,
FCA US otherwise objects to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant nor reasonably calculated to lead ‘to the discovery of
admissible evidence.
REQUEST NO. 25: Provide all documentation evidencing the performance of. :
"goodwill" repairs (or any repairs performed that were free of charge to Plaintiff but not covered
under Defendant's written warranty) to the vehicle whether authorized by Defendant or its
authorized dealership(s).
RESPONSE NO. 25: All known. repairs performed ‘and reimbursed pursuant to the
applicable written. limited warranties appear in the warranty claim records for the 2014 Ram
2500, VIN 3C6UR4HJ3EG117531, produced. in-response to Plaintiff's Request for Production.
No. 1.
10FCA US otherwise objects 'to this request because it is overly broad, unduly burdensome,
and seeks information neither relevant: nor, reasonably calculated to lead to the discovery’ of
admissible evidence.
REQUEST: NO. 26: All documents identifying or deciphering any diagnostic, codes or
repair codes that Defendant ‘instructs its authorized dealership(s) to document on the repair
orders.
RESPONSE NO. 26: FCA US refers Plaintiff to the warranty claim records for the 2014
Ram 2500, VIN 3C6UR4HJ3EG117531, produced in. response:-to Plaintiffs Request for
Production No. 1. If Plaintiff will, identify any codes on documents: produced that it needs
deciphered, FCA US will respond further.
FCA US otherwise objects to this requést because it is overly broad, unduly burdensome,
and seeks information neither relevant nor reasonably calculated to lead to the discovery ‘of.
admissible evidence.
REQUEST NO. 27: Copies of Lemon Law documents or other materials which
‘Defendant provides to its authorized service dealerships regarding the "Lemon Law" or other
‘breach of warranty laws.
RESPONSE NO.'27: FCA US objects ‘to this request because it:is overly broad, unduly
burdensome, and seeks information neither relevant nor reasonably: calculated. to lead to the
discovery of admissible evidence.
REQUEST NO. 28: All documents-in your possession relating to Plaintiff's participation
in Defendant's informal dispute resolution mechanism.
11RESPONSE NO. 28: FCA US objects to this request because it is overly. broad, unduly
burderisome;, and. seeks information neither ‘relevant. nor reasonably calculated. to: lead to. the
discovery of admissible evidence. .
REQUEST NO. 29: Defendant's: Warranty Policy and Procedure Manual or: document.
similarly called that provides Defendant's authorized repair facilities with instructions and
information regarding Defendant's warranty policies and. repair: policies, i.e: how to submit
warranty claims, and how to document. warranty claims and findings by technicians when
making repairs.
RESPONSE NO. 29: FCA US objects to this request because it is overly broad, unduly
burdensome, and. seeks information neither relevant nor reasonably calculated to: lead to: the
discovery of admissible evidence.
REQUEST NO. 30: All communications between Plaintiff and Defendant or between
Plaintiff and Defendant's authorized dealers relating to the subject vehicle.
RESPONSE. NO. 30: FCA. US ‘refers Plaintiff to the Customer Assistance Inquiry
‘Records (CAIRs) containing communications with Plaintiff concerning the 2014. Ram 2500, VIN
3C6UR4HJ3EG117531, produced in response to Plaintiff's Request for Production No. 6. FCA
US will also produce a copy of available communications. with. any ‘authorized repair facility
concerning service of the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531.
FCA US otherwise objects to this request becatise it is overly broad, unduly burdensome,
and seeks information neither. relevant nor reasonably calculated to lead to ‘the discovery of
admissible evidence.
12DATED this OS ne 2019.
Ee GLENN LLP
(ohn 4. Glenn, Esq.
{da Bar No.:.957860
jglenn@asglaw.com
Wilnar J. Julmiste, Esq.
Florida Bar No.: 037172
julmiste@asglaw.com
2650 North Military Trail, Suite 430
Boca Raton, Florida 33341
Tel.: (561) 893-9192
Fax:.(561).893-9194
CERTIFICATE OF SERVICE
I HEREBY CERTIFY: that. on this Se of June, 2019, I electronically filed. the
‘foregoing document with the Clerk of the Court using Florida Court’s E-Filing Portal and certify
that all counsel of record have been served via transmission of Notice of Electronic Filing
generated by Florida Court E-Filing Portal or in some other authorized manner for those counsel
or parties who are not authorized to receive electronically Notices of Electronic Filing.
Ye
John J.AGfenn, Esq
13
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Filing # 91653269 E-Filed 06/25/2019 03:38:29 PM IN THE CIRCUIT COURT OF THE TWENTIETH: JUDICIAL CIRCUIT IN AND: FOR,.COLLIER COUNTY; FLORIDA So CASE NO! 11-2019-CA-001892-0001-XX. ‘NAPLES SERVICE & SUPPLY-INC, Plaintiff, v ‘FCA US LLC, Defendant:. / FCA-US-LLC’S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION FCA US LLC.(“FCA US”) responds to Plaintiff's Request for Production’as follows: These résponses are made solély for'the ptitpose of this action.. Eacly response is made subject. to all ‘objections as'to competence, materiality, selevance or ‘other’ objection as'‘to admissibility ‘that may apply ‘in the event'that any:such response, or the information contained therein, is sought:to‘be.used in court. FCA US'expressly reserves all such objections. REQUEST NO. ‘I All pre-delivery repair orders. relating to’the subject vehicle:in your ‘possession: RESPONSE NO: 1: FCA/US will produce a copy of the:warranty claim records:for‘t the 2014 Rait'2500, VIN 3C6UR4HJ3EG117531. , FCA US otherwise objects to this.request because it is overly broad, unduly burdensonié, and: seeks: information neither relevant, nor reasonably ‘calculated. to, lead. to, the discovery of ‘admissible evidence. FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/25/2019 03:38:29 PMREQUEST NO. 2: All post-delivery repair orders relating to the subject vehicle in your possession. RESPONSE NO. 2: FCA US will produce a copy of vehicle repair records obtained from authorized dealerships for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531. FCA US also refers Plaintiff to the warranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG1 17531, produced in response to Plaintiff's Request for Production No. 1. FCA: US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant ino reasonably calculated to lead -to the discovery of admissible evidence. REQUEST NO. 3: All technicians’ and/or mechanics’ notes relating to the’ subject vehicle in your possession. RESPONSE NO. 3: FCA US refers. Plaintiff to the vehicle repair records produced in response to Plaintiffs Request for Production No. 2. FCA. US also refers Plaintiff to the warranty claim records for the 2014 Ram. 2500, VIN 3C6UR4HJ3EG117531, produced in response to Plaintiff's Request for Production No. 1. FCA US otherwise objects to'this request because it is overly broad, unduly burdengoine, and seeks information neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST NO. 4: All documents identifying time:stamps and/or time punches relating to the time spent performing repairs to the subject vehicle in your possession. , RESPONSE NO. 4: FCA.US refers Plaintiff to the vehicle repair records produced in response to Plaintiff's Request for Production, No. 2. FCA US also refers Plaintiff to thewarranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531, produced. in response to Plaintiff's Request for Production No. 1. . FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and. seeks information neither relevant nor reasonably calculated. to lead to the discovery of admissible evidence. REQUEST NO..5:. ‘The warranty repair history relating to the subject vehicle as kept in its ordinary course of business by Defendant. This document includes all computer records’ “evidencing monetary amounts reimbursed to Defendant's authorized dealership(s). ‘RESPONSE. NO. 5: FCA US refers Plaintiff to the warranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG1 17531, produced. in response: to Plaintiffs Request for Production No. 1. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information. neither, relevant nor reasonably calculated to lead ‘to ‘the discovery of admissible evidence. REQUEST NO. 6: All internal reports, memoranda, correspondence and zone office reports pertaining to the subject vehicle. RESPONSE ‘NO. 6: FCA US. will produce a copy: of available. Customer Assistance Inquiry. Records (CAIRs) containing communications with Plaintiff concerning the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531. FCA.US also refers Plaintiff to the warranty claim records produced in response to Plaintiff's Request for Production No. 1. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and. seeks information neither relevant nor reasonably ‘calculated to lead’ to the: discovery’ ofadmissible evidence. FCA US further objects to this request to the extent it seeks: information protected from disclosure by the work product doctrine or attorney-client privilege. REQUEST NO. 7: All reports, memoranda, correspondence, zone office reports and/or any other documentation. created by Defendant. or its authorized dealership(s) due'to Plaintiff's contact with Defendant or its authorized dealership(s) by way of either writing, telephone or in person. RESPONSE NO. 7: FCA.US refers Plaintiff to the documents produced in response to Plaintiff's Request for Production Nos..1, 2, and 6. FCA US otherwise objects to’ this request because it is overly broad, unduly burdeisome, and ‘seeks information neither relevant nor reasonably calculated ‘to lead to ‘the discovery of admissible evidence. REQUEST NO. 8: All records, invoices, and other documentation relating to the sale of and/or purchase of the vehicle in your possession, RESPONSE NO. 8: FCA US was not a party to the sale of the-2014 Ram 2500, VIN 3C6UR4HJ3EG117531, to Plaintiff. FCA US will produce a copy of the Vehicle Information Detail Report for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant nor ‘reasonably calculated to lead to the discovery of admissible evidence. FCA US also, objects'to this request for documents that are equally or more readily available to Plaintiff. REQUEST NO. 9: All copies of all written warranties issued by Defendant and/or-its authorized dealership(s) regarding the vehicle. This request is being made to obtain an authentic, unaltered copy.RESPONSE NO. 9: A booklet: containing written limited warranties accompanied the 2014.Ram 2500, VIN 3C6UR4HJ3EG117531, when it was distributed. FCA US will produce. a copy of the booklet for the 2014 Ram 2500. FCA US otherwise objects to this request because the term "warranties" is not defined, REQUEST NO. 10: Any and all documents relied upon by Defendant in formulating its answer and affirmative defenses. RESPONSE NO. 10: In addition to the docunients produced in response to Plaintiff's Request, for Production Nos. 1, 2, 6, 8, and 9, FCA US will produce ‘a. copy of the owner’s ‘Manual and user guide for the 2014 Ram 2500. FCA US otherwise: objects. becatise this request is premature as discovery has just commenced, FCA US will supplement this response pursuant to'the deadlines established in the scheduling order. FCA US also objects to this request to the extent it: seeks information protected from disclosure by the attorney-client privilege or work product doctrine. REQUEST NO. 11: All documents. upon which Defendant relies in believing its arbitration program meets the substantive provisions of the Magnuson-Moss Warranty. Act; 16 CFR Part:703; and/or any applicable state law provisions. RESPONSE NO. 11: FCA US doés not offer an informal dispute resolution procedure pursuant to 16 CFR §703. REQUEST NO. 12: All mechanical documents (as described in the definition section above) applicable to the same year, make and model for vehicle as identified in your answer to Interrogatory number 2, RESPONSE NO:.12: FCA US ‘will produce an index. of Technical. Service Bulletins (TSB), ‘recalls, and Customer, Satisfaction. Notifications that may be applicable to the 2014 Ram2500.. TSBs, recalls, and Customer Satisfaction Notifications are vehicle-specific and identify the ‘vehicles ‘to which they apply, sometimes by VIN or build date. The indexes produced will contain the TSB, recall, or Customer Satisfaction Notification number and a description of the TSB, recall, or Customer. Satisfaction. Notification. If Plaintiff will identify, by number, a particular TSB, recall, or Customer Satisfaction Notification that:may be reasonably at issue in this case, FCA US will respond further. FCA US: will also search for and produce a copy of any Rapid Response Transmittals it. locates that may be. applicable to this vehicle and may be reasonably at issue in this case. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant nor reasonably calculated to lead to the discovery of: admissible evidence. REQUEST NO. 13: All "Talking Papers," "Quick Service Fixes," "Level Four documents," "advanced service information," "rapid ‘response," special ‘service information, technical training materials, continuing education materials, VSSM service. library articles, ‘Manufacture Audit Sampling Reports, Tech II bulletins, Know How Videos, engineering reports, analysis or memorandum, and any and all. other documents referencing. investigations or inquiries performed which relate to the allegations made‘herein regarding vehicles of the same year, make and model as Plaintiff's. RESPONSE NO. 13: FCA US ‘refers. Plaintiff to FCA. US’s ‘response to Plaintiff's Request for Production No. 12. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and. seeks information neither relevant nor reasonably calculated to lead to the discovery’ of admissible evidence.REQUEST NO. 14: The report of any expert witness Defendant intends to call at the trial of this‘case. RESPONSE: NO. 14: FCA US objects to this request because it :is premature as discovery has just commenced and FCA US has not yet identified the expert witnesses it may call to testify at trial. FCA US will ‘supplement this response pursuant ‘to the deadlines established inthe scheduling order. FCA US also. objects to:this request to the extent it seeks information protected from disclosure by the work product doctrine or non-testifying expert rule. REQUEST NO. 15: Any and all documents made: available to Defendant's expert witnesses relating to the subject vehicle, Plaintiff, or this lawsuit. RESPONSE. NO. 15: FCA US objects to this request ‘because it is premature as discovery has just commenced and FCA US has not yet identified the expert witnesses it may call to. testify at: trial. FCA US. will ‘supplement this response pursuant to the: deadlines established in the scheduling order. FCA US also objects to this request:to the'extent it seeks information protected from disclosure by the work product doctrine or non-testifying expert rule. REQUEST NO. 16:, Curriculum vitae for any expert witness that Defendant intends to call in this case. RESPONSE NO. 16: FCA US objects to ‘this request: because it is premature. as discovery has just. commenced and FCA US has not yet-identified the expert witnesses it. may call to testify at trial. FCA US will supplement ‘this response ‘pursuant to the deadlines established in the scheduling order. FCA-US also objects'to this request to the extent it seeks ‘information protected from disclosure by the work product doctrine or non-testifying expert rule. REQUEST NO. 17: Any non-privileged.communications provided to. Defendant's expert witnesses relating to the subject vehicle.RESPONSE NO. 17: FCA US objects to this request because it is premature as discovery-has just commenced and FCA US. has not yet identified the expert witnesses it may call, to testify. at ‘trial. FCA.US will: supplement. this response: pursuant to. the deadlines established in the scheduling order. FCA US also objects to this request to’the extent it. seeks information protected.from disclosure by the work product doctrine or non-testifying expert rule. REQUEST NO. 18: Any and all documents prepared or received by Defendant's expert. witness, including but not limited to: notes, reports, memorandum, and communications relating to the subject vehicle. RESPONSE NO. 18: FCA US objects to this request because it is premature as discovery has just commenced and FCA US has not yet: identified the expert witnesses it may call to: testify at trial. FCA US will supplement ‘this response pursuant to the deadlines established:in the scheduling order: FCA US also objects 'to this request to the extent it seeks information protected from disclosure by the work product doctrine or non-testifying expert rule. REQUEST NO. 19: Any and all documents, papers, correspondence, memos, repair orders, work orders, computer print-outs; vehicle inquiry reports, documents, or. receipts evidencing the performance of any Tepair work, whether covered under Defendant's warranty or not, relating to the subject vehicle. ‘RESPONSE 'NO. 19: FCA US refers Plaintiff to the documents produced in response to Plaintiff's Request for Production Nos. 1 and 6. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant: nor reasonably calculated to lead: to the discovery of admissible evidence.REQUEST NO. 20:. All sales brochures, sales‘manuals, literature, pictures,:or any other promotional literature produced for the vehicle which is the subject matter of this litigation: RESPONSE:NO. 20: FCA US will produce a copy of the sales brochure for the 2014 Ram 2500. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant nor reasonably’ calculated to lead ‘to the discovery of admissible evidence. REQUEST NO. 21: Any franchise contract(s) between. Defendant and its authorized dealership(s) that performed repairs to the vehicle. RESPONSE NO. 21: FCA US objects:to this request because it is overly broad, unduly burdensome, and seéeks .information. neither relevant: nor reasonably calculated to lead. to the discovery of admissible evidence. REQUEST NO. 22: Every’ documient that constitutes an’ extended. service contract or warranty given by Defendant, its authorized. dealership(s) or some third party 'to the Plaintiff covering the vehicle. RESPONSE NO..22: FCA US objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant. nor, reasonably: calculated to lead to the discovery of admissible. evidence. FCA. US also objects to. this réquest because it seeks documents more readily available to Plaintiffs. REQUEST NO. 23: All written communications in Defendant's possession relating to the subject’ vehicle and its alleged defects or non-conformities, and/or Plaintiffs request ‘that Defendant accept the return of the vehicle.RESPONSE NO. 23: ‘FCA US refers Plaintiff to the documents produced in response to Plaintiff's Request for Production No. 6. FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information. neither relevant nor. reasonably calculated. to lead to the discovery’ of admissible evidence. REQUEST NO. 24: Provide all documentation supporting Defendant's and its authorized dealership(s) policies to‘perform "goodwill" repairs (or any repairs performed that were free of charge to Plaintiff but not covered under Defendant's written warranty) to the subject vehicle. RESPONSE NO: 24: FCA US will produce'a copy of the. portion of the Warranty Administration Manual that refers to warranty goodwill adjustments, FCA US otherwise objects to this request because it is overly broad, unduly burdensome, and seeks information neither relevant nor reasonably calculated to lead ‘to the discovery of admissible evidence. REQUEST NO. 25: Provide all documentation evidencing the performance of. : "goodwill" repairs (or any repairs performed that were free of charge to Plaintiff but not covered under Defendant's written warranty) to the vehicle whether authorized by Defendant or its authorized dealership(s). RESPONSE NO. 25: All known. repairs performed ‘and reimbursed pursuant to the applicable written. limited warranties appear in the warranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531, produced. in-response to Plaintiff's Request for Production. No. 1. 10FCA US otherwise objects 'to this request because it is overly broad, unduly burdensome, and seeks information neither relevant: nor, reasonably calculated to lead to the discovery’ of admissible evidence. REQUEST: NO. 26: All documents identifying or deciphering any diagnostic, codes or repair codes that Defendant ‘instructs its authorized dealership(s) to document on the repair orders. RESPONSE NO. 26: FCA US refers Plaintiff to the warranty claim records for the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531, produced in. response:-to Plaintiffs Request for Production No. 1. If Plaintiff will, identify any codes on documents: produced that it needs deciphered, FCA US will respond further. FCA US otherwise objects to this requést because it is overly broad, unduly burdensome, and seeks information neither relevant nor reasonably calculated to lead to the discovery ‘of. admissible evidence. REQUEST NO. 27: Copies of Lemon Law documents or other materials which ‘Defendant provides to its authorized service dealerships regarding the "Lemon Law" or other ‘breach of warranty laws. RESPONSE NO.'27: FCA US objects ‘to this request because it:is overly broad, unduly burdensome, and seeks information neither relevant nor reasonably: calculated. to lead to the discovery of admissible evidence. REQUEST NO. 28: All documents-in your possession relating to Plaintiff's participation in Defendant's informal dispute resolution mechanism. 11RESPONSE NO. 28: FCA US objects to this request because it is overly. broad, unduly burderisome;, and. seeks information neither ‘relevant. nor reasonably calculated. to: lead to. the discovery of admissible evidence. . REQUEST NO. 29: Defendant's: Warranty Policy and Procedure Manual or: document. similarly called that provides Defendant's authorized repair facilities with instructions and information regarding Defendant's warranty policies and. repair: policies, i.e: how to submit warranty claims, and how to document. warranty claims and findings by technicians when making repairs. RESPONSE NO. 29: FCA US objects to this request because it is overly broad, unduly burdensome, and. seeks information neither relevant nor reasonably calculated to: lead to: the discovery of admissible evidence. REQUEST NO. 30: All communications between Plaintiff and Defendant or between Plaintiff and Defendant's authorized dealers relating to the subject vehicle. RESPONSE. NO. 30: FCA. US ‘refers Plaintiff to the Customer Assistance Inquiry ‘Records (CAIRs) containing communications with Plaintiff concerning the 2014. Ram 2500, VIN 3C6UR4HJ3EG117531, produced in response to Plaintiff's Request for Production No. 6. FCA US will also produce a copy of available communications. with. any ‘authorized repair facility concerning service of the 2014 Ram 2500, VIN 3C6UR4HJ3EG117531. FCA US otherwise objects to this request becatise it is overly broad, unduly burdensome, and seeks information neither. relevant nor reasonably calculated to lead to ‘the discovery of admissible evidence. 12DATED this OS ne 2019. Ee GLENN LLP (ohn 4. Glenn, Esq. {da Bar No.:.957860 jglenn@asglaw.com Wilnar J. Julmiste, Esq. Florida Bar No.: 037172 julmiste@asglaw.com 2650 North Military Trail, Suite 430 Boca Raton, Florida 33341 Tel.: (561) 893-9192 Fax:.(561).893-9194 CERTIFICATE OF SERVICE I HEREBY CERTIFY: that. on this Se of June, 2019, I electronically filed. the ‘foregoing document with the Clerk of the Court using Florida Court’s E-Filing Portal and certify that all counsel of record have been served via transmission of Notice of Electronic Filing generated by Florida Court E-Filing Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. Ye John J.AGfenn, Esq 13