Motion-Secondary: MARIA BARAJAS QUINTERO, ET AL. VS KIA MOTORS AMERICA, INC., A CALIFORNIA CORPORATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/31/2023 08:51 PM David W. Slayton, Executive Officer/Clerk of Court, by D. Jones,Deputy Clerk



               1     LEHRMAN, VILLEGAS, CHINERY & DOUGLAS, LLP
                     KATE S. LEHRMAN [Bar No. 123050]
               2     JACQUELINE BRUCE CHINERY [Bar No. 187544]
                     KHACHATUR CHRIS OURKHAN [Bar No. 336653]
               3     12121 Wilshire Boulevard, Suite 1300
                     Los Angeles, CA 90025
               4     (310) 917-4500

               5     Attorneys for Defendant
                     KIA AMERICA, INC. (formerly known as
               6     KIA MOTORS AMERICA, INC.)
               7
                                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                    COUNTY OF LOS ANGELES – CENTRAL DISTRICT
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                     MARIA BARAJAS QUINTERO and                                     )     Case No. 19STCV13263
             11      OSCAR QUINTERO,                                                )     [Filed: April 17, 2019]
                                                                                    )
             12                             Plaintiffs,                             )     Hon. Bruce G. Iwasaki
             13                                                                     )     Dept. 58
                                 v.                                                 )
             14                                                                     )     MEMORANDUM OF POINTS AND
                     KIA MOTOR AMERICA, INC. a                                      )     AUTHORITIES OF DEFENDANT KIA
             15      California Corporation, and DOES 1                             )     AMERICA, INC. IN OPPOSITION TO
                     through 10, inclusive,                                         )     PLAINTIFFS’ MOTION IN LIMINE NO. 12
             16                                                                     )     TO PRECLUDE ARGUMENT THAT
                                            Defendants.                             )     VEHICLE INSURANCE AND
             17                                                                     )     REGISTRATION INCURRED AFTER THE
                                                                                    )     VEHICLE QUALIFIED FOR A REPURCHASE
             18                                                                     )     ARE NOT RECOVERABLE UNDER THE
                                                                                    )     SONG-BEVERLY ACT, OR ARE
             19                                                                     )     OTHERWISE THE STANDARD COSTS OF
                                                                                    )     OWNERSHIP
             20                                                                     )
                                                                                    )     DISCOVERY CUT-OFF:                               01/23/23
             21                                                                     )     MOTION CUT-OFF:                                  02/06/23
                                                                                    )     TRIAL DATE:                                      02/21/23
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                                 Defendant Kia America, Inc. (formerly known as Kia Motors America, Inc., hereinafter
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                     KA or Defendant) respectfully submits the following Memorandum of Points and Authorities In
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                     Opposition to Plaintiffs’ Motion In Limine No. 12 To Preclude Argument That Vehicle
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                     Insurance And Registration Incurred After The Vehicle Qualified For A Repurchase Are Not
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                     Recoverable Under The Song-Beverly Act, Or Are Otherwise The Standard Costs Of
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                     Ownership:
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             29      {301.140. - 00775724.DOC}                                                  1                                                     19STCV13263
                     MEMORANDUM OF POINTS AND AUTHORITIES OF DEFENDANT IN OPPOSITION TO PLAINTIFFS’ MOTION
                         IN LIMINE NO. 12 TO PRECLUDE ARGUMENT THAT VEHICLE INSURANCE AND REGISTRATION
             30      INCURRED AFTER THE VEHICLE QUALIFIED FOR A REPURCHASE ARE NOT RECOVERABLE UNDER THE
                              SONG-BEVERLY ACT, OR ARE OTHERWISE THE STANDARD COSTS OF OWNERSHIP
             31