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Christine Haw (SBN 289351)
Email: chaw@slpattorney.com
Gabriella Pedone (SBN 308384)
ELECTRONICALLY
Email: gpedone@slpattorney.com
Strategic Legal Practices, APC FILED
1840 Century Park East, Suite 430 Superior Court of California,
County of San Francisco
Los Angeles, CA 90067
Telephone: (310) 929-4900 10/31/2018
Clerk of the Court
Facsimile: (310) 943-3838 BY: VANESSA WU
Deputy Clerk
Attorneys for Plaintiffs DAWN ANN MASON and JAMES MASON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
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DAWN ANN MASON and JAMES MASON,| Case No.: CGC-18-564545
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Plaintiffs, DISCOVERY
12
Hon. Harold E. Kahn
vs.
13 Dept. 302
14 FCA US, LLC; and DOES 1 through 10, DECLARATION OF GABRIELLA
inclusive, PEDONE IN SUPPORT OF PLAINTIFFS’
15 MOTION TO COMPEL FURTHER
Defendants. RESPONSES TO PLAINTIFFS’
16
REQUEST FOR PRODUCTION OF
17 DOCUMENTS
18 Date: December 4, 2018
Time: 9:00 a.m.
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Dept.: 302
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES
DECLARATION OF GABRIELLA PEDONE
I, Gabriella Pedone, declare as follows:
1 Tam over the age of 18 and not a party to the action. I am an attorney at law, duly
admitted and licensed to practice before all courts of this State and I am an associate of
STRATEGIC LEGAL PRACTICES, APC 1840 Century Park East, Suite 430, Los Angeles, CA
90067. I am one of the attorneys for Plaintiffs DAWN ANN MASON and JAMES MASON
(“Plaintiffs”) in this action and my knowledge of the information and events described herein
derives from a combination of my personal knowledge and a careful review of the file, relevant
court records and communications with other Plaintiffs’ counsel, and if called as a witness, I
10 could and would competently testify thereto.
11 2. I submit this declaration in support of Plaintiffs’ Motion to Compel Further
12 Responses to Plaintiffs’ Request for Production of Documents, Set One.
13 Plaintiffs’ Experiences with the Subject Vehicle
14 3 On or about April 23, 2011, Plaintiffs purchased the subject 2010 Dodge
15 Caravan, vehicle identification number 2D4RN5D1XAR316721 (hereinafter “Subject
16 Vehicle”).
17 4 Attached as Exhibit 1 are true and correct copies of the relevant repair orders
18 documenting the repeated sliding door defect and electrical-related problems with the Subject
19 Vehicle. According to the records, Plaintiffs visited the dealer no fewer than five (5) times with
20 concerns relating to the Sliding Door Defect and Electrical Defect. None of the attempts have
21 permanently repaired the Subject Vehicle’s defect.
22 5 On July 15, 2011, with only 17,982 miles on the odometer, Plaintiffs took the
23 Subject Vehicle to Defendant’s dealership with electrical concerns. Defendant’s technician
24 performed Recall L25 and replaced the ignition node detent.
25 6 On July 25, 2011, with only 18,000 miles on the odometer, Plaintiffs took the
26 Subject Vehicle to Defendant's dealership with electrical concerns. Plaintiffs complained that
27 upon start-up there is a delay in the Subject Vehicle’s accessories (radio, heater, etc.) from
28 turning on, Defendant’s technician could not diagnose Plaintiffs’ concerns.
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
7
On October 11, 2011, with only 18,974 miles on the odometer, Plaintiffs took the
Subject Vehicle to Defendant’s dealership for sliding door concerns. Plaintiffs informed
Defendant’s dealership that the right-side sliding door makes a clacking noise when operating
the inside button and/or manually opening the door. Defendant’s technician could not diagnose
Plaintiffs’ concerns.
8 On May 21, 2014, with only 28,180 miles on the odometer, Plaintiffs returned to
Defendant’s dealership with the Subject Vehicle for electrical concerns. Plaintiffs informed
Defendant that upon start-up the Subject Vehicle’s electrical (radio, dash, windows, turn signal,
etc.) are inoperable. Defendant’s technician discovered that the detent on the Subject Vehicle
10 was replaced during applicable of recall L25. The detent was not required on the Subject
11 Vehicle and was removed.
12 9 On September 6, 2017, only with 37,493 miles on the odometer, Plaintiffs took
13 the Subject Vehicle to Defendant’s dealership with sliding door concerns. Plaintiffs complained
14 that while opening the sliding door via the push button, the sliding door would open halfway
15 then close. Defendant’s technician could not verify Plaintiffs’ concern verified Plaintiff's
16 concer. The technician inspected the Subject Vehicle and confirmed a ticking noise from the
17 engine valve train. The technician found the engine tick noise to be normal. The technician
18 also updated the powertrain control module.
19 10. None of the attempts have permanently repaired the Subject Vehicle’s defect as
20 Plaintiff continues to experience problems with the Subject Vehicle.
21 Defendant’s Awareness of the Sliding Door and Electrical Defect in_its 2010 Dodge Caravan
22 Vehicles
23 IL. Based on my experience, I have become familiar with Technical Service
24 Bulletins (TSB’s) within the automotive industry. It is my understanding that TSB’s are
25 essentially a repair procedure published by Defendant and distributed to its repair facilities
26 which outlines how a common problem should be repaired. My firm has conducted its own
27 research into TSBs in 2010 Dodge Caravan vehicles, and it is clear that FCA is aware of the
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
sliding door, and electrical defects in 2010 Dodge Caravan given the vast amount of TSBs that
exist for such an issue in this year, make, and model vehicle.
12. Attached hereto as Exhibit 2 is a true and correct copy of TSB 23-005-10, issued
on March 2, 2010, regarding the power sliding door not opening. Plaintiffs experienced this
concern.
13. Attached hereto as Exhibit 3 is a true and correct copy of TSB 08-021-10 Rev.
B., issued on September 29, 2010, regarding inoperable sliding doors. Plaintiffs experienced
this concern.
14. Attached hereto as Exhibit 4 is a true and correct copy of TSB 23-017-12 issued
10 on May 26, 2012, addressing sliding door binding when fully open. Plaintiffs experienced this
11 concern.
12 1s. Attached hereto as Exhibit 5 is a true and correct copy of TSB 08-017-09 issued
13 on October 27, 2009, regarding sliding door obstruction detection too sensitive. Plaintiffs
14 experienced this concern.
15 16. Attached hereto as Exhibit 6 is a true and correct copy of Safety Recall R03
16 NHTSA 14V-373 revised on July 15, regarding WIN module FOBIK replacement. Plaintiffs
17 experienced this concern.
18 17. Attached hereto as Exhibit 7 is a true and correct copy of Recall L25 issued on
19 July 2011, regarding wireless ignition node module detents. Plaintiffs experienced this concern.
20 18. Attached hereto as Exhibit 8 is a true and correct copy of TSB NHTSA
21 11V139000 issued on March 1, 2011, regarding ignition switch replacement. Plaintiffs
22 experienced this concern.
23 Prelitigation Request for Repurchas
24 19, After numerous repair attempts by FCA, Plaintiffs called FCA’s call center on or
25 about September 14, 2017 to request that the Subject Vehicle be brought back because of the
26 numerous repairs done on the Subject Vehicle. FCA denied the buyback.
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
Discovery Requests and Defendant’s Insufficient Responses
20. On February 22, 2018, Plaintiffs filed their Complaint, alleging various Song-
Beverly claims against Defendant.
21. Defendant’s Answer was filed on or about April 13, 2018, generally denying all
allegations in Plaintiffs’ Complaint and asserting numerous affirmative defenses.
22. Attached as Exhibit 9 is a true and correct copy of Plaintiffs’ Request for
Production, Set One (“RFP(1)”) which was mailed served by Plaintiffs on June 18, 2018.
23. Attached as Exhibit 10 is a true and correct copy of Defendant’s Responses to
RFP(1), including boilerplate objections and non-code-complaint responses, which Defendant
10 mail served on July 23, 2018.
11 Meet and Confer Efforts
12 24, I have made diligent efforts on behalf of Plaintiffs to meet and confer with
13 Defendant regarding Defendant’s deficient discovery responses, as delineated below.
14 25. Attached as Exhibit 11 is a true and correct copy of Plaintiffs’ June 18, 2018
15 meet & confer letter regarding discovery of electronically stored information, sent in accordance
16 with California Rules of Court 3.724.
17 26. Attached as Exhibit 12 is a true and correct copy of Plaintiffs’ September 19,
18 2018 meet and confer letter regarding Defendant’s boilerplate objections and deficient responses
19 to RFP(1) and how the discovery should be produced under controlling law. Plaintiffs offered
20 to stipulate to the LASC Model Confidential Protective Order as a compromise to alleviate
21 Defendant’s concerns of confidentiality or trade secret. Plaintiffs requested a response from
22 Defendant by September 21, 2018. Plaintiffs also requested a two-week and/or three-week
23 extension to file their motion to compel.
24 27. Attached as Exhibit 13 is a true and correct copy of Defendant’s September 24.
25 2018 email granting Plaintiffs an extension to file their motion to compel to October 31, 2018.
26 28. Attached as Exhibit 14 is a true and correct copy of Defendant’s October 9, 2018
27 responsive meet and confer letter addressing Plaintiffs’ September 19, 2018 letter, and also
28 responding to Plaintiffs’ ESI meet and confer letter. Defendant stood by its objections to the
4
DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
discovery of ESI — in direct contravention of California Rules of Court 3.724. Indeed,
Defendant agreed to supplement some of its discovery responses, but to date have not produced
any supplemental documents as agreed upon. Lastly, Defendant agreed to produce some other
documents pursuant to “the LASC form protective order.”
29. Attached as Exhibit 15 is a true and correct copy of Plaintiffs’ October 19, 2018
further meet and confer letter. In their letter Plaintiffs to stipulate to the LASC Confidential
Model Protective Order. Plaintiffs also agreed to accept supplemental production on Request
No. 7, 10, and those requests regarding “those that outline how Defendant expects its agents,
employees and dealerships to handle lemon law matters...” Plaintiffs also informed Defendant
10 that it failed to supplement on the vast majority of requests that were included in the underlying
11 motion.
12 30. Attached as Exhibit 16 is a true and correct copy of Defendant’s October 20,
13 2018 email to Plaintiffs, informing them of its intention to respond to Plaintiffs’ October 19,
14 2018 further meet and confer letter by October 26, 2018. Defendant failed to respond.
15 31. As Defendant has unjustifiably refused to engage in good faith meet and confer
16 efforts with Plaintiffs and refused to withdraw its boilerplate objections or produce any further
17 responsive documents, Plaintiffs were forced to file the instant motion on the agreed upon filing
18 deadline.
19 Defendant's Unjustifiable Refusal to Produce Relevant Documents
20 32. To date, Defendant has produced no emails, memos, or investigations that could
21 help Plaintiff understand the circumstances behind the repeated problems with the Subject
22 Vehicle. Also, Defendant has not produced any policies and/or procedures used for evaluation
23 of consumers’ request for vehicle repurchase. Defendant failed to even provide repair orders,
24 technical service bulletins, or recall notices.
25 33, Attached hereto as Exhibit 17 is a true and correct copy of the court order
26 denying defendant’s motion for relief from waiver and granting plaintiff's motion to compel in
27 the matter of Lindsey v. Ford Motor Company (Santa Clara Superior Court, Case No. 14-CV-
28 260620). As found by the court: “Plaintiffs contend that these documents [concerning internal
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
investigations and Defendant’s awareness of a widespread defect] will also assist them in
demonstrating that Ford’s refusal to replace their Vehicle was not made in good faith. This
argument is meritorious. The documents at issue might demonstrate that FCA, US, LLC was
aware that the engine in the 2010 Dodge Caravan contained an incurable defect, yet still refused
to replace Plaintiffs’ vehicle. Such evidence would permit a jury to infer that Ford did not act in
good faith in refusing to replace their Vehicle.”
34. Attached hereto as Exhibit 18 is a true and correct copy of the court’s ruling
granting plaintiff's motion to compel in the matter of Hogg v. Ford Motor Company (Los
Angeles County Superior Court, Case No. BC555578).
10 35. Attached hereto as Exhibit 19 is a true and correct copy of the court’s ruling
11 granting plaintiff's motion to compel in the matter of Clark v. Ford Motor Company (Los
12 Angeles County Superior Court, Case No. BC555811).
13 36. Attached hereto as Exhibit 20 is a true and correct copy of the court’s ruling
14 granting plaintiff's motion to compel in the matter of Mateos v. Ford Motor Company (Marin
15 County Superior Court, Case No. 14CECG03260).
16 37. Attached hereto as Exhibit 21 is a true and correct copy of the court’s ruling
17 granting plaintiffs motion to compel in the matter of Diggs v. Ford Motor Company
18 (Sacramento County Superior Court, Case No. 34-2014-00171712-CU-BC-GDS).
19 38. Attached hereto as Exhibit 22 is a true and correct copy of the court’s ruling
20 granting plaintiff's motion to compel in the Song-Beverly matter of Strickfaden v. BMW of
21 North America, LLC (Los Angeles County Superior Court, Case No. BC563082). As noted by
22 the court: “BMW also argues that the request is overbroad because it the term "engine defect" is
23 not well defined. Strickfaden argues that because he is a consumer, he is only under an
24 obligation to tell BMW what the symptoms of the defect are, not the cause. (citation) Therefore,
25 Strickfaden is under no obligation to discover the technical cause of the defect himself in order
26 to help BMW narrow down the definition of "engine defect" at issue. In fact, Strickfaden bases
27 the definition of "engine defect" on the specific concerns identified in the subject Mini's repair
28 history, created by BMW technicians. (citation) The definition of defect is as specific as a
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
consumer would be expected to be able to make."
39, Attached as Exhibit 23 is a true and correct copy of the unpublished opinion in
the matter of Needham v. General Motors Corporation, 2004 WL 2153790 which is being
provided, not as binding authority, but to demonstrate the relevance and admissibility of the
Warranty Policy and Procedure Manual.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
DATED: October 31, 2018
10 Gas Pedone
Attorney for Plaintiffs
11
DAWN ANN MASON and
12 JAMES MASON
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DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES.
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Christine Haw (SBN 289351) Email: chaw@slpattorney.com Gabriella Pedone (SBN 308384) ELECTRONICALLY Email: gpedone@slpattorney.com Strategic Legal Practices, APC FILED 1840 Century Park East, Suite 430 Superior Court of California, County of San Francisco Los Angeles, CA 90067 Telephone: (310) 929-4900 10/31/2018 Clerk of the Court Facsimile: (310) 943-3838 BY: VANESSA WU Deputy Clerk Attorneys for Plaintiffs DAWN ANN MASON and JAMES MASON SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO 10 DAWN ANN MASON and JAMES MASON,| Case No.: CGC-18-564545 11 Plaintiffs, DISCOVERY 12 Hon. Harold E. Kahn vs. 13 Dept. 302 14 FCA US, LLC; and DOES 1 through 10, DECLARATION OF GABRIELLA inclusive, PEDONE IN SUPPORT OF PLAINTIFFS’ 15 MOTION TO COMPEL FURTHER Defendants. RESPONSES TO PLAINTIFFS’ 16 REQUEST FOR PRODUCTION OF 17 DOCUMENTS 18 Date: December 4, 2018 Time: 9:00 a.m. 19 Dept.: 302 20 21 22 23 24 25 26 27 28 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES DECLARATION OF GABRIELLA PEDONE I, Gabriella Pedone, declare as follows: 1 Tam over the age of 18 and not a party to the action. I am an attorney at law, duly admitted and licensed to practice before all courts of this State and I am an associate of STRATEGIC LEGAL PRACTICES, APC 1840 Century Park East, Suite 430, Los Angeles, CA 90067. I am one of the attorneys for Plaintiffs DAWN ANN MASON and JAMES MASON (“Plaintiffs”) in this action and my knowledge of the information and events described herein derives from a combination of my personal knowledge and a careful review of the file, relevant court records and communications with other Plaintiffs’ counsel, and if called as a witness, I 10 could and would competently testify thereto. 11 2. I submit this declaration in support of Plaintiffs’ Motion to Compel Further 12 Responses to Plaintiffs’ Request for Production of Documents, Set One. 13 Plaintiffs’ Experiences with the Subject Vehicle 14 3 On or about April 23, 2011, Plaintiffs purchased the subject 2010 Dodge 15 Caravan, vehicle identification number 2D4RN5D1XAR316721 (hereinafter “Subject 16 Vehicle”). 17 4 Attached as Exhibit 1 are true and correct copies of the relevant repair orders 18 documenting the repeated sliding door defect and electrical-related problems with the Subject 19 Vehicle. According to the records, Plaintiffs visited the dealer no fewer than five (5) times with 20 concerns relating to the Sliding Door Defect and Electrical Defect. None of the attempts have 21 permanently repaired the Subject Vehicle’s defect. 22 5 On July 15, 2011, with only 17,982 miles on the odometer, Plaintiffs took the 23 Subject Vehicle to Defendant’s dealership with electrical concerns. Defendant’s technician 24 performed Recall L25 and replaced the ignition node detent. 25 6 On July 25, 2011, with only 18,000 miles on the odometer, Plaintiffs took the 26 Subject Vehicle to Defendant's dealership with electrical concerns. Plaintiffs complained that 27 upon start-up there is a delay in the Subject Vehicle’s accessories (radio, heater, etc.) from 28 turning on, Defendant’s technician could not diagnose Plaintiffs’ concerns. 1 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. 7 On October 11, 2011, with only 18,974 miles on the odometer, Plaintiffs took the Subject Vehicle to Defendant’s dealership for sliding door concerns. Plaintiffs informed Defendant’s dealership that the right-side sliding door makes a clacking noise when operating the inside button and/or manually opening the door. Defendant’s technician could not diagnose Plaintiffs’ concerns. 8 On May 21, 2014, with only 28,180 miles on the odometer, Plaintiffs returned to Defendant’s dealership with the Subject Vehicle for electrical concerns. Plaintiffs informed Defendant that upon start-up the Subject Vehicle’s electrical (radio, dash, windows, turn signal, etc.) are inoperable. Defendant’s technician discovered that the detent on the Subject Vehicle 10 was replaced during applicable of recall L25. The detent was not required on the Subject 11 Vehicle and was removed. 12 9 On September 6, 2017, only with 37,493 miles on the odometer, Plaintiffs took 13 the Subject Vehicle to Defendant’s dealership with sliding door concerns. Plaintiffs complained 14 that while opening the sliding door via the push button, the sliding door would open halfway 15 then close. Defendant’s technician could not verify Plaintiffs’ concern verified Plaintiff's 16 concer. The technician inspected the Subject Vehicle and confirmed a ticking noise from the 17 engine valve train. The technician found the engine tick noise to be normal. The technician 18 also updated the powertrain control module. 19 10. None of the attempts have permanently repaired the Subject Vehicle’s defect as 20 Plaintiff continues to experience problems with the Subject Vehicle. 21 Defendant’s Awareness of the Sliding Door and Electrical Defect in_its 2010 Dodge Caravan 22 Vehicles 23 IL. Based on my experience, I have become familiar with Technical Service 24 Bulletins (TSB’s) within the automotive industry. It is my understanding that TSB’s are 25 essentially a repair procedure published by Defendant and distributed to its repair facilities 26 which outlines how a common problem should be repaired. My firm has conducted its own 27 research into TSBs in 2010 Dodge Caravan vehicles, and it is clear that FCA is aware of the 28 22 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. sliding door, and electrical defects in 2010 Dodge Caravan given the vast amount of TSBs that exist for such an issue in this year, make, and model vehicle. 12. Attached hereto as Exhibit 2 is a true and correct copy of TSB 23-005-10, issued on March 2, 2010, regarding the power sliding door not opening. Plaintiffs experienced this concern. 13. Attached hereto as Exhibit 3 is a true and correct copy of TSB 08-021-10 Rev. B., issued on September 29, 2010, regarding inoperable sliding doors. Plaintiffs experienced this concern. 14. Attached hereto as Exhibit 4 is a true and correct copy of TSB 23-017-12 issued 10 on May 26, 2012, addressing sliding door binding when fully open. Plaintiffs experienced this 11 concern. 12 1s. Attached hereto as Exhibit 5 is a true and correct copy of TSB 08-017-09 issued 13 on October 27, 2009, regarding sliding door obstruction detection too sensitive. Plaintiffs 14 experienced this concern. 15 16. Attached hereto as Exhibit 6 is a true and correct copy of Safety Recall R03 16 NHTSA 14V-373 revised on July 15, regarding WIN module FOBIK replacement. Plaintiffs 17 experienced this concern. 18 17. Attached hereto as Exhibit 7 is a true and correct copy of Recall L25 issued on 19 July 2011, regarding wireless ignition node module detents. Plaintiffs experienced this concern. 20 18. Attached hereto as Exhibit 8 is a true and correct copy of TSB NHTSA 21 11V139000 issued on March 1, 2011, regarding ignition switch replacement. Plaintiffs 22 experienced this concern. 23 Prelitigation Request for Repurchas 24 19, After numerous repair attempts by FCA, Plaintiffs called FCA’s call center on or 25 about September 14, 2017 to request that the Subject Vehicle be brought back because of the 26 numerous repairs done on the Subject Vehicle. FCA denied the buyback. 27 \ 28 \\ 3 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. Discovery Requests and Defendant’s Insufficient Responses 20. On February 22, 2018, Plaintiffs filed their Complaint, alleging various Song- Beverly claims against Defendant. 21. Defendant’s Answer was filed on or about April 13, 2018, generally denying all allegations in Plaintiffs’ Complaint and asserting numerous affirmative defenses. 22. Attached as Exhibit 9 is a true and correct copy of Plaintiffs’ Request for Production, Set One (“RFP(1)”) which was mailed served by Plaintiffs on June 18, 2018. 23. Attached as Exhibit 10 is a true and correct copy of Defendant’s Responses to RFP(1), including boilerplate objections and non-code-complaint responses, which Defendant 10 mail served on July 23, 2018. 11 Meet and Confer Efforts 12 24, I have made diligent efforts on behalf of Plaintiffs to meet and confer with 13 Defendant regarding Defendant’s deficient discovery responses, as delineated below. 14 25. Attached as Exhibit 11 is a true and correct copy of Plaintiffs’ June 18, 2018 15 meet & confer letter regarding discovery of electronically stored information, sent in accordance 16 with California Rules of Court 3.724. 17 26. Attached as Exhibit 12 is a true and correct copy of Plaintiffs’ September 19, 18 2018 meet and confer letter regarding Defendant’s boilerplate objections and deficient responses 19 to RFP(1) and how the discovery should be produced under controlling law. Plaintiffs offered 20 to stipulate to the LASC Model Confidential Protective Order as a compromise to alleviate 21 Defendant’s concerns of confidentiality or trade secret. Plaintiffs requested a response from 22 Defendant by September 21, 2018. Plaintiffs also requested a two-week and/or three-week 23 extension to file their motion to compel. 24 27. Attached as Exhibit 13 is a true and correct copy of Defendant’s September 24. 25 2018 email granting Plaintiffs an extension to file their motion to compel to October 31, 2018. 26 28. Attached as Exhibit 14 is a true and correct copy of Defendant’s October 9, 2018 27 responsive meet and confer letter addressing Plaintiffs’ September 19, 2018 letter, and also 28 responding to Plaintiffs’ ESI meet and confer letter. Defendant stood by its objections to the 4 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. discovery of ESI — in direct contravention of California Rules of Court 3.724. Indeed, Defendant agreed to supplement some of its discovery responses, but to date have not produced any supplemental documents as agreed upon. Lastly, Defendant agreed to produce some other documents pursuant to “the LASC form protective order.” 29. Attached as Exhibit 15 is a true and correct copy of Plaintiffs’ October 19, 2018 further meet and confer letter. In their letter Plaintiffs to stipulate to the LASC Confidential Model Protective Order. Plaintiffs also agreed to accept supplemental production on Request No. 7, 10, and those requests regarding “those that outline how Defendant expects its agents, employees and dealerships to handle lemon law matters...” Plaintiffs also informed Defendant 10 that it failed to supplement on the vast majority of requests that were included in the underlying 11 motion. 12 30. Attached as Exhibit 16 is a true and correct copy of Defendant’s October 20, 13 2018 email to Plaintiffs, informing them of its intention to respond to Plaintiffs’ October 19, 14 2018 further meet and confer letter by October 26, 2018. Defendant failed to respond. 15 31. As Defendant has unjustifiably refused to engage in good faith meet and confer 16 efforts with Plaintiffs and refused to withdraw its boilerplate objections or produce any further 17 responsive documents, Plaintiffs were forced to file the instant motion on the agreed upon filing 18 deadline. 19 Defendant's Unjustifiable Refusal to Produce Relevant Documents 20 32. To date, Defendant has produced no emails, memos, or investigations that could 21 help Plaintiff understand the circumstances behind the repeated problems with the Subject 22 Vehicle. Also, Defendant has not produced any policies and/or procedures used for evaluation 23 of consumers’ request for vehicle repurchase. Defendant failed to even provide repair orders, 24 technical service bulletins, or recall notices. 25 33, Attached hereto as Exhibit 17 is a true and correct copy of the court order 26 denying defendant’s motion for relief from waiver and granting plaintiff's motion to compel in 27 the matter of Lindsey v. Ford Motor Company (Santa Clara Superior Court, Case No. 14-CV- 28 260620). As found by the court: “Plaintiffs contend that these documents [concerning internal 3 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. investigations and Defendant’s awareness of a widespread defect] will also assist them in demonstrating that Ford’s refusal to replace their Vehicle was not made in good faith. This argument is meritorious. The documents at issue might demonstrate that FCA, US, LLC was aware that the engine in the 2010 Dodge Caravan contained an incurable defect, yet still refused to replace Plaintiffs’ vehicle. Such evidence would permit a jury to infer that Ford did not act in good faith in refusing to replace their Vehicle.” 34. Attached hereto as Exhibit 18 is a true and correct copy of the court’s ruling granting plaintiff's motion to compel in the matter of Hogg v. Ford Motor Company (Los Angeles County Superior Court, Case No. BC555578). 10 35. Attached hereto as Exhibit 19 is a true and correct copy of the court’s ruling 11 granting plaintiff's motion to compel in the matter of Clark v. Ford Motor Company (Los 12 Angeles County Superior Court, Case No. BC555811). 13 36. Attached hereto as Exhibit 20 is a true and correct copy of the court’s ruling 14 granting plaintiff's motion to compel in the matter of Mateos v. Ford Motor Company (Marin 15 County Superior Court, Case No. 14CECG03260). 16 37. Attached hereto as Exhibit 21 is a true and correct copy of the court’s ruling 17 granting plaintiffs motion to compel in the matter of Diggs v. Ford Motor Company 18 (Sacramento County Superior Court, Case No. 34-2014-00171712-CU-BC-GDS). 19 38. Attached hereto as Exhibit 22 is a true and correct copy of the court’s ruling 20 granting plaintiff's motion to compel in the Song-Beverly matter of Strickfaden v. BMW of 21 North America, LLC (Los Angeles County Superior Court, Case No. BC563082). As noted by 22 the court: “BMW also argues that the request is overbroad because it the term "engine defect" is 23 not well defined. Strickfaden argues that because he is a consumer, he is only under an 24 obligation to tell BMW what the symptoms of the defect are, not the cause. (citation) Therefore, 25 Strickfaden is under no obligation to discover the technical cause of the defect himself in order 26 to help BMW narrow down the definition of "engine defect" at issue. In fact, Strickfaden bases 27 the definition of "engine defect" on the specific concerns identified in the subject Mini's repair 28 history, created by BMW technicians. (citation) The definition of defect is as specific as a 6 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. consumer would be expected to be able to make." 39, Attached as Exhibit 23 is a true and correct copy of the unpublished opinion in the matter of Needham v. General Motors Corporation, 2004 WL 2153790 which is being provided, not as binding authority, but to demonstrate the relevance and admissibility of the Warranty Policy and Procedure Manual. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED: October 31, 2018 10 Gas Pedone Attorney for Plaintiffs 11 DAWN ANN MASON and 12 JAMES MASON 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 DECLARATION OF GABRIELLA PEDONE IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES. EXHIBIT 1 sy £ sil Pe 7 * ie “. 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SERVICE CONT feINDIAVAL ABLE 0 IN THEIR VEHI CATES SERVICE £ CONTRACTS vA Wen ce PERE, TOTAL FOTAL HISC DISt TAX 0.00 0.00 APPROPTATE BOX 0.00 \ ED LABOR COST TOTAL INVOICE $ TO OUR CUSTOMERS: AUTOWOR!10 arses ‘THE EST TMATENDUSTRYE WARLOUS AU VE OF REPAIRS AND JFACTURER’S RECOMME DEPART: ZED avert THE PUB LIC ESTI ATI ONS. “Aub. Ou Ont CE IV TSICE”NOT BASED MATE D PR RICE FOR LABOR: IR AND MENT EXPERIENCE. TECHN TCTANS INTHE REPA ON ACTUAL TIME Si ENT BY QUR SERVICE E DI IF YOUR VEHICLE. CUSTOME? STGHATURE bo | MASON 00005 zn ? —— is TERMS; CASH * CHECK SERVICE DEPT. HOURS: VISA® MASTERCARD j/QODGe deap 7:30 A.M. 8:00 PM. MONDAY THROUGH FRIDAY 1370 ae Center Drive » Petaluma, CA 94952 Phone (707) 762-2712 Parts Direct (707) 795-2496 or (707) 762-0118 Paris Direct Fax (707) 762-7190 *** VICTORY YAMAHA OUTBOARDS & MORE *** WE THANK YOU FOR YOUR ORDER TODAY CALL US FOR ALL YOUR CHRYSLER , DODGE JEEP AND SPRINTER NEEDS. Sek einebrbin een ent emmeene FIVE STAR DEALI THANK YOU FOR YOUR BUSINESS ota B ota] Aeneas) (eI anne) Bisltana va Glolie} (Niverretsitey-bu iixWrellol=t 18986 PENDING DAVID MACE 07/15/11 57871 DOWMASONGCOMCAST. NET CHR 415-558-3211 JAMES MASON REFER TO RO 379430 MN 1708 PEGGY CT PER 1274 PETALUMA, CA 94952 ele Rae CDG le ely clase yell ame] ik ete (lop NTI ule Ne) 0 |68029829-AB KEY BLANK 2301 7004 KEYS 29.40) 29.40} 29.40 NOTICE: Nel Due 10th of the Month Following Date of Invoice. Merchandise Nol Returnable After 10 ‘SUBTOTAL 29.40 ‘Days. Retumned Merchandise Subject lo 20% Handling Charge. No Refunds on Special Ordars, Hot Stocked, Electrical Parts, Carourolor Assombiles and Electronic Componants, ‘ALL CLAIMS AND RETURNED GOOD MUST BE ACCOMPANIED BY THIS BIL, TAX 2.36 NO RETURNS AFTER 10 DAYS. THIS RECEIPT PARTS ANDIOR ACCESSORIES SOLD HEREBY DISCLAMER OF WARRANTIES: ANY WARRANTIES ON THEEXPREBGLY ARE THOSE MUST BE WADE BY THE MANUFACTURER. THE SELLER, HEREBY DIACLAIIG ALL WARDANTIES, OTHER EXPRESS PRESENTED (OA IMPLICD. CL UDG AMY REPLIED WARVIAMTY OF MERCHANTABASTY OF FITMEES FON A PAITIOULAR PURPOTE, Jano WeaTHieR ASSURED NOR AUTTIONOID AKT OTRIEA SEAGON Ta ABDI POR MT AH LIABILITY 1H COMMECEION WHEN PICKING UP WII THE BALE OF THESE PARTE ANDVOR ACCEBEOMIES, FREIGHT 3 p98 SPE CIAL ORDER 2 7 _ WE THANK YOU PAY THIS AMOUNT PARTS. ChSTONER Sane. aZinr.na AHeTARED AADV NFTAONS PAGE OF1 MASON 0 0006 fe uct pyyele gust oe i A SLL. TERMS: CASH * CHECK “a SERVICE DEPT. HOURS: VISA * MASTERCARD moma deep 7:30 A.M. 6:00 P.M. MONDAY THROUGH FRIDAY 1370 Auto Center Drive + Petaluma, CA 94952 RECOMMENDED SERVICES Phone (707) #62-2712 aula eral Welsreguaren) mn naiie Giana i Cigaaohessoaliaden) Berne eure OlcHZO1s 18000 MILE SERVICE Mr SERVICE HISTORY eis aivoaeca See Eee face acd Cision Gaoesseaaion SALESPERSON NO. SERV I CE STATE REG# AL136290 FROST ORE] BRON TENET 3D4RN5D1XAR316721 [10/B00GE /cARAVAN/VAN Pasian FWD SE 379430 "| CAE ONE | CANEY MILES | SLING DENLETAO PRONE JAMES MASON “7086 | Py AS/ 13) 1708 PEGGY CT CHL ‘CONTR PRATTOGRIT | ERNENTION EES FRR:9 | PETALUMA, CA 94952 WHITE/ |DONMASON@COMCAST NET TiesioENE PONE TRS (ae Ze eery [x | i7,982|" 1274 TUCAS POWERS 707-762-5734 (415-558-3211 am | Oey TY 1:59pm rl APPOWTRENT| TanoA RAE on x ORIGINAL CUSTOMER ESTIMATE: reteo 4 W 10CH213 DRIVEABILITY RECALL CUSTOMER REQUEST TO PERFORM RECALL L25-IGNITION NODE 2 CC 46CHzTIRE TIRE PRESSURE CARB CHECK AND RECORD ‘IRE PRESSURES PER CARB INFLATE AS NECESSARY REPROGRAM TIRE PRESSURE MONITOR IF EQUIPPED OK 903 & MASON 00007 pee. N ae i ‘TERMS: CASH » CHECK VISA * MASTEROARD any ca ropa Jeon SERVICE DEPT. HOURS: 7:30 A.M, TO 5:30 PM. MONDAY THROUGH FRIDAY 1870 Auto Center Drive = Petaluma, CA 94932 a0 AMATO 4:00 PM, RECOMMENDED SERVICES . Phone (707) 762-2712 feifaaon Cisaaeesccontaton! eas cn pene Gn sone arene} Rous O1cHZ018 A8000 MILE SERVICE MI SEAVICE HISTORY. ONS pag ghenelas i Ria eerie Meenienneiasa! aan Gewuenisscianon SALESPERSON NO. SERVICE STATE REG# AL 136290 PAOOUGTION BNE TOON $BARNSD1XAR316721 | 10/000GE/CARAVAN/VAN_FWD SE “BLAM717 [380124 CUSTOMER NO. TeLVENY OAE | CELERY Maes | SLRS ORAL ESO |S TATE JAMES MASON 18986 7 f25/1: tre 1708 PEGGY CT GOMIARET RG. PTR GATE] EATON WALES EARS PETALUMA, CA 94952 DONMASON@COMCAST. NET chez | Y “vf A ‘1g ,000| 1274 “STUCAS POWERS 415-558 zu 59pm | ern TR RE Ove Bo ORIGINAL CUSTOMER ESTIMATE: TOTAL, x 1 40CHZ DRIVEABILITY CUSTOMER STATES WHEN STARTING THE VEHICLE, THE ACCESSORIES( RADIO, HEATER,ETC) TAKE A LONG TIME TO COME ON-CHECK AND ADVISE MASON 00008 ce ‘TERMS: GASH » CHECK eunvenon SERVICE DEPT. HOURS: VISA * MASTERCARD: WMecnce Jeep 7:30 A.M.TO 5:30 PM. 1370 Auto Center Drive * Petaluma, CA 94952 MONDAY THROUGH FRIDAY Phone (707) 762-2712 8:30 A.M.TO 4:00 PM. Parts Direct (707) 795-2436 or (707) 762-0118 Parts Direct Fax (707) 762-7190 aR TOERNE, 18986 LUCAS POWERS: 1274] 1889 07/25/11 CHCS380124. ABA RATE SCR WT JAMES MASON Jocem717 18,000 WHITE/ 1708 PEGGY CT DRLERY OaTE Seer PETALUMA, CA 94952 1.0/DODGE/CARAVAN/VAN FWD SE venice SRLS DEALER HO, PRODTOHON TATE 2D4RNSDIXAR3SLE721 ETE We re DONMASON@COMCAST . NET 07/25/11 comes 107-762-5734 415-558-3211 MO: 18000; OB CHARGES: jie 1 10 INTERNAL custowen’§ SITES WHEN STARTING THE VEHICLE, The ASSES ne. HEATER, ETC) TAKE A LONG TIME TO COE ON-CHE TRSPecTED ‘THE IGNITION SWITCH, SWITCH IS OPERATING TO aI, THE SWITCH WILL GET EASIER TO HOVE WHT jJ08# 1 TOTALS JOB# 1 JOURNAL PREFIX CHCS JOB# 1 TOTAL 0,00 TOTALS: syawevebes. 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