Motion-Secondary: JOSE AYALA, ET AL. VS GENERAL MOTORS, LLC

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/24/2021 08:53 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk




                     1      DAVID N. BARRY, ESQ. (SBN 219230)
                            ELIZABETH EABISA, ESQ. (SBN 338025)
                     2      THE BARRY LAW FIRM
                            11845 W. Olympic Blvd., Suite 1270W
                     3      Los Angeles, CA 90064
                            Telephone: 310.684.5859
                     4      Facsimile: 310.862.4539
                     5      Attorneys for Plaintiffs, JOSE AYALA and ROXANA AYALA
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                                                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                      FOR THE COUNTY OF LOS ANGELES - STANLEY MOSK COURTHOUSE
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                   11       JOSE AYALA, an individual;                                                        Case No. 21STCV02946
                   12       ROXANA AYALA, an individual,                                                      PLAINTIFFS' REPLY BRIEF IN
                                                                                                              SUPPORT OF MOTION TO COMPEL
                   13                                                                                         DEFENDANT GENERAL MOTORS, LLC'S
                                                           Plaintiffs,                                        FURTHER RESPONSES TO FORM
                   14                                                                                         INTERROGATORY 12.1
                                       V.
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                                                                                        Reservation ID.: 753383386759
                   16                                                                   Date: December 2, 2021
                            GENERAL MOTORS                              LLC, A Delaware Time: 9:30 a.m.
                   17                                                                   Dept:69
                            Limited Liability Company; and DOES 1
                   18                                                                                         Action Filed: January 25, 2021
                            through 20, inclusive,                                                            Trial Date: March 7, 2022
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                                                           Defendants.                                       Assigned for all purposes to the Hon. William
                   20                                                                                        F. Fahey in Dept. 69

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                   23       I. INTRODUCTION
                   24                  Defendant General Motors LLC ("Defendant" or "GM) incorrectly asserts in its Opposition

                   25      papers that Plaintiffs Jose and Roxanna Ayala ("Plaintiffs") did not meet and confer in good faith,

                   26       GM fully responded appropriately, and there is nothing for this Court to compel Defendant to do

                   27       any further. As the Declaration of Elizabeth Eabisa makes it clear in Plaintiffs' moving papers,

                   28       Plaintiffs did adequately meet and confer, including attempted telephonic meet and confer.
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                             PLAINTIFFS' REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT GENERAL MOTORS LLC'S
                                              FURTHER RESPONSES TO FORM INTERROGATORY NO. 12.1