Preview
JON D. UNIVERSAL, SBN 141255
JAMES P. MAYO, SBN 169897
NEJLA NASSIRIAN, SBN 308730
ADAM KHAN, SBN 296617 ELECTRONICALLY
BRETT H. WANNER, SBN 314025 FILED
UNIVERSAL & SHANNON, LLP Superior Court of Californi
2240 Douglas Boulevard, Suite 290 County of San Francisco
Roseville, California 95661
Telephone: (916) 780-4050 11/19/2018
Facumile: (916) 780-9070 BY: VANESSA WU
Deputy Clerk
Attorneys for Defendant FCA US LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE OF SAN FRANCISCO
DAWN ANN MASON and JAMES MASON, Case No.: CGC-18-564545
an individual,
Plaintiffs, DEFENDANT FCA US LLC’S
SEPARATE STATEMENT IN
vs. SUPPORT OF ITS OPPOSITION TO
PLAINTIFF’S MOTION TO COMPEL
FCA US LLC; and DOES 1 through 10, FURTHER RESPONSES TO
inclusive, PLAINTIFF’S REQUEST FOR
Defendants. PRODUCTION OF DOCUMENTS,
7 SET ONE
Hearing Date: December 4, 2018
Hearing Time: 9:00 a.m.
Department: 302
DISCOVERY
Defendant FCA US LLC (“FCA”) hereby submits its responsive Separate Statement as
follows:
REQUEST FOR PRODUCTION NO. 7: The Warranty Policy and Procedure Manual
published by YOU and provided to YOUR authorized repair facility(s), within the state of
California, from January 2010 to the present. [This request will be understood to include
production of any and all versions of such manual as distributed to YOUR dealerships during the
relevant time frame].
DEFENDANT FCA US LLC’S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF’S MOTION
TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONERESPONSE NO. 7: FCA objects to this request because it is overly broad and seeks
information neither relevant nor reasonably calculated to lead to the discovery of admissible
evidence.
SUPPLEMENTAL RESPONSE NO. 7: FCA will comply in full with this request. By
agreement of the parties, FCA will produce, pursuant to protective order, a copy of the current
Warranty Administration Manual.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 16: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any internal
analysis or investigation by YOU or on YOUR behalf regarding SLIDING DOOR DEFECTS in
vehicles of the same year, make, and model as the SUBJECT VEHICLE. [This request shall be
interpreted to include, but not be limited to, any such investigation to determine the root cause of
such SLIDING DOOR DEFECTS, any such investigation to design a permanent repair procedure
for such SLIDING DOOR DEFECTS, any such investigation into the failure rates of parts
associated with such SLIDING DOOR DEFECTS, any cost analysis for implementing a proposed
repair procedure, any savings analysis not implementing a proposed repair procedure, etc.]
RESPONSE NO. 16: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
TOP!
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LAINTIFF’S REQ
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reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal. 2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING
DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 16: Without waiving any objection, FCA will
comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the
company where such information is likely to be found, and will produce, subject to the entry of a
protective order, documents relating to any documents concerning any internal analysis or
investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING
DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject
vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 17: All DOCUMENTS, including but not limited to
electronically stored information and ‘electronic mails, concerning or relating to any internal
analysis or investigation by YOU or on YOUR behalf regarding ELECTRICAL DEFECTS in
vehicles of the same year, make, and model as the SUBJECT VEHICLE. [This request shall be
interpreted to include, but not be limited to, any such investigation to determine the root cause of
such ELECTRICAL DEFECTS, any such investigation to design a permanent repair procedure for
such ELECTRICAL DEFECTS, any such investigation into the failure rates of parts associated
with such ELECTRICAL DEFECTS, any cost analysis for implementing a proposed repair
procedure, any savings analysis not implementing a proposed repair procedure, etc.]
RESPONSE NO. 17: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
DEFENDAN ‘A US LLO’S SEPARATE STATEMENT IN
TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQ!to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal. 2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL
DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 17: Without waiving any objection, FCA US will
comply in part. FCA US will conduct a reasonable search and diligent inquiry in the areas of the
company where such information is likely to be found, and will produce, subject to the entry of a
protective order, documents relating to any documents concerning any internal analysis or
investigation, not including emails, based upon the conditions alleged in Plaintiff's “ELECTRICAL
DEFECT” definition, for vehicles of the same year, make, and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 20: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any
communications YOU have had regarding customer concems relating to the sliding doors and
sliding door components in vehicles of the same year, make, and model as the SUBJECT
VEHICLE.
RESPONSE NO. 20: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
-4-
DEFENDANT FCA US LLC’S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION |
TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE.eo Oo IN DH BF Bw NY
y Noe ee SS SSeS
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “customer
concerns relating to the sliding doors and sliding door components” lacks foundation and is vague,
ambiguous, argumentative, and misleading. FCA US further objects to this request as violating the
privacy rights of other FCA US motor vehicle owners.
SUPPLEMENTAL RESPONSE NO. 20: Without waiving any objection, FCA will
comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the
company where such information is likely to be found, and will produce, subject to the entry of a
protective order, documents relating to any documents concerning any internal analysis or
investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING
DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject
vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 21: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any
communications YOU have had regarding customer concerns relating to the electrical system in
vehicles of the same year, make, and model as the SUBJECT VEHICLE.
DEFENDANT FCA US LLC'S
TO COMPEL FURTHER RESPO!RESPONSE NO. 21: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “customer
concerns relating to the electrical system” lacks foundation and is vague, ambiguous,
argumentative, and misleading. FCA US further objects to this request as violating the privacy
tights of other FCA US motor vehicle owners.
SUPPLEMENTAL RESPONSE NO. 21: Without waiving any objection, FCA will
comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the
company where such information is likely to be found, and will produce, subject to the entry of a
protective order, documents relating to any documents concerning any internal analysis or
investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL
DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 22: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any decision to
issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls
concerning the SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the
DEFENDAN AUSTI ;EPARATE STA MENT IN
TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S RECDom IY DH FF WN |
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SUBJECT VEHICLE.
RESPONSE NO. 22: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING
DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 22: Without waiving any objection, FCA will
comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to the entry of a protective
order, documents relating to any decision to issue any notices, letters, campaigns, warranty
extensions, technical service bulletins and recalls, not including emails, based upon the conditions
alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make,
and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 23: All DOCUMENTS, including but not limited to
-7-
DEFENDANT FCA US LLC'S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION |
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONEelectronically stored information and electronic mails, concerning or relating to any decision to
issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls
“concerning the ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the
SUBJECT VEHICLE.
RESPONSE NO. 23: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL
DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 23: Without waiving any objection, FCA will
comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to the entry of a protective
order, documents relating to any decision to issue any notices, letters, campaigns, warranty
extensions, technical service bulletins and recalls, not including emails, based upon the conditions
alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make,
and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 25: All DOCUMENTS, including but not limited to
ON TO PLAIN OTIO
[ON OF DOCUMENTS, SET ONE
D DANT FCA USL PARA ATEMENT IN
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REelectronically stored information and electronic mails, concerning or relating to any decision to
issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls
concerning the electrical system in vehicles of the same year, make, and model as the SUBJECT
VEHICLE.
RESPONSE NO. 25: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA Us is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787.
SUPPLEMENTAL RESPONSE NO. 25: Without waiving any objection, FCA will
comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company :
where such information is likely to be found, and will produce, subject to the entry of a protective
order, documents relating to any decision to issue any notices, letters, campaigns, warranty
extensions, technical service bulletins and recalls, not including emails, based upon the conditions
alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make,
and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
IEFENDANT FCA US LLC®
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was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 26: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating in any way to any
decision to modify the sliding doors and/or any of its related parts, in vehicles of the same year,
make, and model as the SUBJECT VEHICLE.
RESPONSE NO. 26: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787.
SUPPLEMENTAL RESPONSE NO. 26: Without waiving any objection, FCA will
comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to protective order, c/1000,
MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices,
letters, campaigns, warranty extensions, technical service bulletins and recalls, not including
emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition,
for vehicles of the same year, make, and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
=10-
DEFENDANT SUPPORT OF ITS OPPOSITION T:
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S R REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONESOo em IN DH F BW NY &
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to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 27: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating in any way to any
decision to modify the electrical system and/or any of its related parts, in vehicles of the same year,
make, and model as the SUBJECT VEHICLE.
RESPONSE NO, 27: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787.
SUPPLEMENTAL RESPONSE NO. 27: Without waiving any objection, FCA will
comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to protective order, c/1000,
MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices,
letters, campaigns, warranty extensions, technical service bulletins and recalls, not including
emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for
vehicles of the same year, make, and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
ANT FCA US
DEFEND; LLC’S SITION TO PLAINTIFF OTIO
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REQUEST FOR PRODUCTION NO. 28: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning customer complaints, claims,
reported failures, and warranty claims related to SLIDING DOOR DEFECTS in vehicles of the
same year, make, and model as the SUBJECT VEHICLE, including but not limited to any databases
in YOUR possession with information from dealers, service departments, parts departments, or
warranty departments, and all documents concerning YOUR response to each complaint, claim or
reported failure
RESPONSE NO. 28: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING
DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
FCA US further objects to this request as violating the privacy rights of other FCA US motor
vehicle owners.
SUPPLEMENTAL RESPONSE NO. 28: Without waiving any objection, FCA will
comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the
company where such information is likely to be found, and will produce, subject to the entry of a
protective order, documents relating to any documents concerning any internal analysis or
investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING
DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject
vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
-12-
DEFE EPARA’ TIT
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
(ON TO PLAINTH [ON]YN A Ww BF YW WD
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 29: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning customer complaints, claims,
reported failures, and warranty claims related to ELECTRICAL DEFECTS in vehicles of the same
year, make, and model as the SUBJECT VEHICLE, including but not limited to any databases in
YOUR possession with information from dealers, service departments, parts departments, or
warranty departments, and all documents concerning YOUR response to each complaint, claim or
reported failure.
RESPONSE NO. 29: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL
DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. FCA US
further objects to this request as violating the privacy rights of other FCA US motor vehicle owners.
SUPPLEMENTAL RESPONSE NO. 29: Without waiving any objection, FCA will
comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to protective order, warranty
DEFENDANT FCA US [LS SEPARATE STATEMENT IN
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S RE
TON TO PLAIN MOTIO
ION OF DOCUMENTS, SET ONEclaims data based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition,
for vehicles of the same year, make, and model as the subject vehicle.
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 32: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning failure rates of vehicles of the
same year, make, and model as the SUBJECT VEHICLE as a result of SLIDING DOOR
DEFECTS.
RESPONSE NO. 32: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information.
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING
DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 32: Without waiving any objection, FCA will
comply in part and search for and produce, subject to the protective order previously entered in this
matter, documents relating to C/1000 and MOP/MIS data, not including emails, based upon the
conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same
year, make, and model as the subject vehicle.
DEFENDANT FCA US LLC P
TO COMPEL FURTHER RESPO!REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 33: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning failure rates of vehicles of the
same year, make, and model as the SUBJECT VEHICLE as a result of ELECTRICAL DEFECTS.
RESPONSE NO. 33: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase
“ELECTRICAL DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and
misleading.
SUPPLEMENTAL RESPONSE NO. 33: Without waiving any objection, FCA will
comply in part and search for and produce, subject to the protective order previously entered in this
matter, documents relating to C/1000 and MOP/MIS data, not including emails, based upon the
conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same
year, make, and model as the subject vehicle.
DEFENDANT FCA U PARATE STATEMI
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQ!
RT OF ITs POSITION TO PLAINTIFF OTION |
‘T FOR PRODUCTION OF DOCUMENTS, SET ONEw
oO eo ID
10
i
12
1B
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
REQUEST FOR PRODUCTION NO. 34: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any fixes for
SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the SUBJECT
VEHICLE.
RESPONSE NO. 34: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING
DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 34: Without waiving any objection, FCA will
comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to protective order, c/1000,
MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices,
letters, campaigns, warranty extensions, technical service bulletins and recalls, not including
emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition,
for vehicles of the same year, make, and model as the subject vehicle.
NDANTFCA UST EPARA ATEMENTIN
TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQ|REASON WHY NO FURTHER RESPONSE IS REQUIRED
FCA refers to its arguments made in its Opposition, which it incorporates here.
This response has been supplemented, with verification, and, with the entry of the protective
order, the production will occur. Thus, this motion is moot. There is no need for the court to order
any production, but if an order is granted by the court, it should be subject to the protective order
that has been approved by counsel, but not yet entered.
This willingness to produce documents is very broad and generous when the facts known
to FCA show that the only observable complaint with the sliding door on plaintiff's Grand Caravan
was a noise that was fully eliminated with lubrication on one occasion.
REQUEST FOR PRODUCTION NO. 35: All DOCUMENTS, including but not limited to
electronically stored information and electronic mails, concerning or relating to any fixes for
ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the SUBJECT
VEHICLE.
RESPONSE NO. 35: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks
the ability to comply with the demand for inspection because the Request is not compliant with
Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information
to identify the documents or category of documents being sought. FCA US can neither state that it
is complying in full, in part, or lodge applicable objections in the absence of a specific description
of the materials FCA US is being asked to produce. The omnibus request seeking “All
DOCUMENTS... concerning...” is improper because “the custodian of the records is not
reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965)
234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL
DEFECTS?” lacks foundation and is vague, ambiguous, argumentative, and misleading.
SUPPLEMENTAL RESPONSE NO. 35: Without waiving any objection, FCA will
comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company
where such information is likely to be found, and will produce, subject to protective order, c/1000,
MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices,
letters, campaigns, warranty extensions, technical service bulletins and recalls, not includingCo em IN DH BF WHY HY
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JON D. UNIVERSAL, SBN 141255 JAMES P. MAYO, SBN 169897 NEJLA NASSIRIAN, SBN 308730 ADAM KHAN, SBN 296617 ELECTRONICALLY BRETT H. WANNER, SBN 314025 FILED UNIVERSAL & SHANNON, LLP Superior Court of Californi 2240 Douglas Boulevard, Suite 290 County of San Francisco Roseville, California 95661 Telephone: (916) 780-4050 11/19/2018 Facumile: (916) 780-9070 BY: VANESSA WU Deputy Clerk Attorneys for Defendant FCA US LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE OF SAN FRANCISCO DAWN ANN MASON and JAMES MASON, Case No.: CGC-18-564545 an individual, Plaintiffs, DEFENDANT FCA US LLC’S SEPARATE STATEMENT IN vs. SUPPORT OF ITS OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FCA US LLC; and DOES 1 through 10, FURTHER RESPONSES TO inclusive, PLAINTIFF’S REQUEST FOR Defendants. PRODUCTION OF DOCUMENTS, 7 SET ONE Hearing Date: December 4, 2018 Hearing Time: 9:00 a.m. Department: 302 DISCOVERY Defendant FCA US LLC (“FCA”) hereby submits its responsive Separate Statement as follows: REQUEST FOR PRODUCTION NO. 7: The Warranty Policy and Procedure Manual published by YOU and provided to YOUR authorized repair facility(s), within the state of California, from January 2010 to the present. [This request will be understood to include production of any and all versions of such manual as distributed to YOUR dealerships during the relevant time frame]. DEFENDANT FCA US LLC’S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONERESPONSE NO. 7: FCA objects to this request because it is overly broad and seeks information neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. SUPPLEMENTAL RESPONSE NO. 7: FCA will comply in full with this request. By agreement of the parties, FCA will produce, pursuant to protective order, a copy of the current Warranty Administration Manual. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 16: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any internal analysis or investigation by YOU or on YOUR behalf regarding SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE. [This request shall be interpreted to include, but not be limited to, any such investigation to determine the root cause of such SLIDING DOOR DEFECTS, any such investigation to design a permanent repair procedure for such SLIDING DOOR DEFECTS, any such investigation into the failure rates of parts associated with such SLIDING DOOR DEFECTS, any cost analysis for implementing a proposed repair procedure, any savings analysis not implementing a proposed repair procedure, etc.] RESPONSE NO. 16: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not TOP! MENT "ATEMENT IN LAINTIFF’S REQ D NDAN' AUS Ss TO COMPEL FURTHER RESP*Co me YW DH FB BW NH boN bh oN N NY Se Se Se Se es BRURRRBEBREB SERRA BCHSS reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal. 2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 16: Without waiving any objection, FCA will comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any documents concerning any internal analysis or investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 17: All DOCUMENTS, including but not limited to electronically stored information and ‘electronic mails, concerning or relating to any internal analysis or investigation by YOU or on YOUR behalf regarding ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE. [This request shall be interpreted to include, but not be limited to, any such investigation to determine the root cause of such ELECTRICAL DEFECTS, any such investigation to design a permanent repair procedure for such ELECTRICAL DEFECTS, any such investigation into the failure rates of parts associated with such ELECTRICAL DEFECTS, any cost analysis for implementing a proposed repair procedure, any savings analysis not implementing a proposed repair procedure, etc.] RESPONSE NO. 17: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information DEFENDAN ‘A US LLO’S SEPARATE STATEMENT IN TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQ!to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal. 2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 17: Without waiving any objection, FCA US will comply in part. FCA US will conduct a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any documents concerning any internal analysis or investigation, not including emails, based upon the conditions alleged in Plaintiff's “ELECTRICAL DEFECT” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 20: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any communications YOU have had regarding customer concems relating to the sliding doors and sliding door components in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 20: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it -4- DEFENDANT FCA US LLC’S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION | TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE.eo Oo IN DH BF Bw NY y Noe ee SS SSeS is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “customer concerns relating to the sliding doors and sliding door components” lacks foundation and is vague, ambiguous, argumentative, and misleading. FCA US further objects to this request as violating the privacy rights of other FCA US motor vehicle owners. SUPPLEMENTAL RESPONSE NO. 20: Without waiving any objection, FCA will comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any documents concerning any internal analysis or investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 21: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any communications YOU have had regarding customer concerns relating to the electrical system in vehicles of the same year, make, and model as the SUBJECT VEHICLE. DEFENDANT FCA US LLC'S TO COMPEL FURTHER RESPO!RESPONSE NO. 21: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “customer concerns relating to the electrical system” lacks foundation and is vague, ambiguous, argumentative, and misleading. FCA US further objects to this request as violating the privacy tights of other FCA US motor vehicle owners. SUPPLEMENTAL RESPONSE NO. 21: Without waiving any objection, FCA will comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any documents concerning any internal analysis or investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 22: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls concerning the SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the DEFENDAN AUSTI ;EPARATE STA MENT IN TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S RECDom IY DH FF WN | N YPN NN Ye Be Be Be eB ewe Be eB Be BRNRRRBEBEB SSE ATDEBTHAS SUBJECT VEHICLE. RESPONSE NO. 22: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 22: Without waiving any objection, FCA will comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 23: All DOCUMENTS, including but not limited to -7- DEFENDANT FCA US LLC'S SEPARATE STATEMENT IN SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION | TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONEelectronically stored information and electronic mails, concerning or relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls “concerning the ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 23: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 23: Without waiving any objection, FCA will comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 25: All DOCUMENTS, including but not limited to ON TO PLAIN OTIO [ON OF DOCUMENTS, SET ONE D DANT FCA USL PARA ATEMENT IN TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REelectronically stored information and electronic mails, concerning or relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls concerning the electrical system in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 25: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA Us is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. SUPPLEMENTAL RESPONSE NO. 25: Without waiving any objection, FCA will comply in part. FCA conducted a reasonable search and diligent inquiry in the areas of the company : where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan IEFENDANT FCA US LLC® TO COMPEL FURTHER RESeo Oe YN DA HW BF Bw NY a fee a eae ee BRSRPEBBRRESSEREWAAESEE AS was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 26: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating in any way to any decision to modify the sliding doors and/or any of its related parts, in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 26: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. SUPPLEMENTAL RESPONSE NO. 26: Without waiving any objection, FCA will comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company where such information is likely to be found, and will produce, subject to protective order, c/1000, MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known =10- DEFENDANT SUPPORT OF ITS OPPOSITION T: TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S R REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONESOo em IN DH F BW NY & RN YW NY RY NR NR KN NY Ye ee es Be Be ee eB oD A A BF Oo NH fF FS GD we AW DH BF WN FE OS to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 27: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating in any way to any decision to modify the electrical system and/or any of its related parts, in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO, 27: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. SUPPLEMENTAL RESPONSE NO. 27: Without waiving any objection, FCA will comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company where such information is likely to be found, and will produce, subject to protective order, c/1000, MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. ANT FCA US DEFEND; LLC’S SITION TO PLAINTIFF OTIO TO COMPEL FURTHER RESPONSES TO PLAINTIFF! Ss TS REO! [ON OF DOCUMENTS, SET ONEoO em NY DH FF BW YY RP NM RNR YP NR NR KR NY Se Be Be Be Se Se eB Be eB eo WU AA BF oO NHN Ff SD wM ADAH RB WH SF REQUEST FOR PRODUCTION NO. 28: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning customer complaints, claims, reported failures, and warranty claims related to SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE, including but not limited to any databases in YOUR possession with information from dealers, service departments, parts departments, or warranty departments, and all documents concerning YOUR response to each complaint, claim or reported failure RESPONSE NO. 28: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. FCA US further objects to this request as violating the privacy rights of other FCA US motor vehicle owners. SUPPLEMENTAL RESPONSE NO. 28: Without waiving any objection, FCA will comply in part. FCA will conduct a reasonable search and diligent inquiry in the areas of the company where such information is likely to be found, and will produce, subject to the entry of a protective order, documents relating to any documents concerning any internal analysis or investigation, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. -12- DEFE EPARA’ TIT TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE (ON TO PLAINTH [ON]YN A Ww BF YW WD This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 29: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning customer complaints, claims, reported failures, and warranty claims related to ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE, including but not limited to any databases in YOUR possession with information from dealers, service departments, parts departments, or warranty departments, and all documents concerning YOUR response to each complaint, claim or reported failure. RESPONSE NO. 29: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. FCA US further objects to this request as violating the privacy rights of other FCA US motor vehicle owners. SUPPLEMENTAL RESPONSE NO. 29: Without waiving any objection, FCA will comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company where such information is likely to be found, and will produce, subject to protective order, warranty DEFENDANT FCA US [LS SEPARATE STATEMENT IN TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S RE TON TO PLAIN MOTIO ION OF DOCUMENTS, SET ONEclaims data based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 32: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning failure rates of vehicles of the same year, make, and model as the SUBJECT VEHICLE as a result of SLIDING DOOR DEFECTS. RESPONSE NO. 32: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information. to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 32: Without waiving any objection, FCA will comply in part and search for and produce, subject to the protective order previously entered in this matter, documents relating to C/1000 and MOP/MIS data, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. DEFENDANT FCA US LLC P TO COMPEL FURTHER RESPO!REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on Plaintiffs’ Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 33: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning failure rates of vehicles of the same year, make, and model as the SUBJECT VEHICLE as a result of ELECTRICAL DEFECTS. RESPONSE NO. 33: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 33: Without waiving any objection, FCA will comply in part and search for and produce, subject to the protective order previously entered in this matter, documents relating to C/1000 and MOP/MIS data, not including emails, based upon the conditions alleged in Plaintiffs’ “ELECTRICAL DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. DEFENDANT FCA U PARATE STATEMI TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQ! RT OF ITs POSITION TO PLAINTIFF OTION | ‘T FOR PRODUCTION OF DOCUMENTS, SET ONEw oO eo ID 10 i 12 1B 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. REQUEST FOR PRODUCTION NO. 34: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any fixes for SLIDING DOOR DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 34: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “SLIDING DOOR DEFECTS” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 34: Without waiving any objection, FCA will comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company where such information is likely to be found, and will produce, subject to protective order, c/1000, MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not including emails, based upon the conditions alleged in Plaintiffs’ “SLIDING DOOR DEFECTS” definition, for vehicles of the same year, make, and model as the subject vehicle. NDANTFCA UST EPARA ATEMENTIN TO COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQ|REASON WHY NO FURTHER RESPONSE IS REQUIRED FCA refers to its arguments made in its Opposition, which it incorporates here. This response has been supplemented, with verification, and, with the entry of the protective order, the production will occur. Thus, this motion is moot. There is no need for the court to order any production, but if an order is granted by the court, it should be subject to the protective order that has been approved by counsel, but not yet entered. This willingness to produce documents is very broad and generous when the facts known to FCA show that the only observable complaint with the sliding door on plaintiff's Grand Caravan was a noise that was fully eliminated with lubrication on one occasion. REQUEST FOR PRODUCTION NO. 35: All DOCUMENTS, including but not limited to electronically stored information and electronic mails, concerning or relating to any fixes for ELECTRICAL DEFECTS in vehicles of the same year, make, and model as the SUBJECT VEHICLE. RESPONSE NO. 35: Pursuant to Code of Civil Procedure §2031.210(a)(2), FCA US lacks the ability to comply with the demand for inspection because the Request is not compliant with Code of Civil Procedure §2031.030(c)(1) and does not provide FCA US with sufficient information to identify the documents or category of documents being sought. FCA US can neither state that it is complying in full, in part, or lodge applicable objections in the absence of a specific description of the materials FCA US is being asked to produce. The omnibus request seeking “All DOCUMENTS... concerning...” is improper because “the custodian of the records is not reasonably apprised of what he must produce.” Flora Crane Service Inc. v. Superior Court (1965) 234 Cal.2d. 767, 786-787. FCA US also objects to this request because the phrase “ELECTRICAL DEFECTS?” lacks foundation and is vague, ambiguous, argumentative, and misleading. SUPPLEMENTAL RESPONSE NO. 35: Without waiving any objection, FCA will comply in part. FCA conducted a diligent search and reasonable inquiry in the areas of the company where such information is likely to be found, and will produce, subject to protective order, c/1000, MOP/MIS, warranty claim data, and any documents relating to any decision to issue any notices, letters, campaigns, warranty extensions, technical service bulletins and recalls, not includingCo em IN DH BF WHY HY Re ee ees Ee Een tee Geeta BR