Preview
V ORiGINAL
KNIGHT LAW GROUP LLP
Roger Kimos (SBN 283 1 63)
RogerK@knightlaw.com
Phil A Thomas (SBN 2485 17)
philt@knightlaw.com
10250 Constellation Blvd., Suite 2500
Los Angeles, CA 90067
SUPERIORFCSULR-T SF EAUFORNIA
Tel: (3 10) 552—2250
COUNTY OF SAN BERNARDINO
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\OWNOUI-PUJNH
Fax; (3 10) 552-7973 sAN
APR 2 7 2023
Attorneys for Plaintiffs,
JOSE LOZANO and
CHELSEA LOZANO av
”'
JACQUE
L >2 d4“
1N? HARNESS, DEPU'W
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
JOSE LOZANO and CHELSEA LOZANO, Case No.: CIVSBZZI8471
Unlimited Jurisdiction
Plaintiffs, PLAINTIFFS’ SEPARATE
STATEMENT IN SUPPORTOF A8
VS
MOTION T0 COMPEL FURTHER
‘
DISCOVERY RESPONSES FROM
DEFENDANT, AND REQUEST FOR
SANCTIONS XVd
GENERAL MOTORS LLC, a Delaware
Limited Liability Company, and DOES 1 [Submitted concurrently With Notice Of.
through 10, inclusive, Motlon to Compel, Memorandum of Pomts
NNNNNNNNNHr—Hb—ar—‘HHp—np—n—n
and Authorities in Support 0f Plaintiffs’
Motion, [Proposed] Order and Declaration of
Phil A Thomas.]
OONONUIhUJNb—‘OOOONONUI-bwh-JP‘O
Defendants.
Hearing Date: July 17, 2023
Hearing Time: 8:30 a.m.
Department: S-31
Date Filed: August 22, 2022
Trial Date: Not Set
-1 _
PLAINTIFFS’ SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER
DISCOVERY RESPONSES '
TO ALL INTERESTED PARTIES AND TO ATTORNEYS OF RECORD:
Plaintiffs JOSE LOZANO and CHELSEA LOZANO (“Plaintiffs”),
submit the following
Separate Statement in Support 0f the Motion to Compel Further Discovery Responses from
Defendant General Motors, LLC and Request for Sanctions.
\OOO\IO\Ul-5LNN>—‘
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION
JUDICIAL COUNCIL DEFINITIONS
The following definitions are approved by the California Judicial Council and are not
subject to objection:
1. The words “YOU” and “YOUR” refer to GENERAL MOTORS LLC and/or any
related entity, predecessor, parent, subsidiary and/or affiliate,
employee, agent (including, but not
limited to, any mortgage servicing agent), or any person acting or purpOITing to act on Defendant,
GENERAL MOTORS LLC’s behalf.
2. The word “DOCUMENT” and “DOCUMENTS” refers to all matters that fall
within the definition 0f Evidence Code §250, and includes written or printed matter
0f any kind,
including the originals and all non-identical copies thereof, whether different from the original
by
reason of any notation made on such copies or otherwise including, but not limited to, the
NNNNNNNNNb—AHHHHHHy—dr—dr—A
following: advertisements, booklets, brochures, pamphlets, circulars, notices,
periodicals, papers,
contracts, agreements, photographs, minutes, memoranda, messages, appraisals, analyses, reports,
OONQM-bWNHOCWNONUl-QWNHO
financial calculations and representations, invoices, accounting and diary entries,
inventory sheets,
diaries, appointment books or calendars, teletypes, facsimiles, ledgers, trial balances,
correspondence, telegrams, press releases, notes, working papers, drawings, schedules,
tabulations, projections, mails, information or programs stored in a computer (whether or not ever
printed out or displayed), and all drafts, alterations, modifications, changes 0r amendments 0f any
of the foregoing, and all graphic 0r manual records or representations of any kind including, but
not limited t0, the following: microfiche, microfilm, audiotapes, videotapes, recordings and motion
pictures, and all electronic, mechanical or electronic records or representations of any kind
including, but not limited to, the following: Tapes, cassettes, discs, magnetic cards and
recordings.
-2-
PLAINTIFFS’ SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER
DISCOVERY RESPONSES
Preview
V ORiGINAL KNIGHT LAW GROUP LLP Roger Kimos (SBN 283 1 63) RogerK@knightlaw.com Phil A Thomas (SBN 2485 17) philt@knightlaw.com 10250 Constellation Blvd., Suite 2500 Los Angeles, CA 90067 SUPERIORFCSULR-T SF EAUFORNIA Tel: (3 10) 552—2250 COUNTY OF SAN BERNARDINO Bmwmnmo msmm \OWNOUI-PUJNH Fax; (3 10) 552-7973 sAN APR 2 7 2023 Attorneys for Plaintiffs, JOSE LOZANO and CHELSEA LOZANO av ”' JACQUE L >2 d4“ 1N? HARNESS, DEPU'W SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO JOSE LOZANO and CHELSEA LOZANO, Case No.: CIVSBZZI8471 Unlimited Jurisdiction Plaintiffs, PLAINTIFFS’ SEPARATE STATEMENT IN SUPPORTOF A8 VS MOTION T0 COMPEL FURTHER ‘ DISCOVERY RESPONSES FROM DEFENDANT, AND REQUEST FOR SANCTIONS XVd GENERAL MOTORS LLC, a Delaware Limited Liability Company, and DOES 1 [Submitted concurrently With Notice Of. through 10, inclusive, Motlon to Compel, Memorandum of Pomts NNNNNNNNNHr—Hb—ar—‘HHp—np—n—n and Authorities in Support 0f Plaintiffs’ Motion, [Proposed] Order and Declaration of Phil A Thomas.] OONONUIhUJNb—‘OOOONONUI-bwh-JP‘O Defendants. Hearing Date: July 17, 2023 Hearing Time: 8:30 a.m. Department: S-31 Date Filed: August 22, 2022 Trial Date: Not Set -1 _ PLAINTIFFS’ SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES ' TO ALL INTERESTED PARTIES AND TO ATTORNEYS OF RECORD: Plaintiffs JOSE LOZANO and CHELSEA LOZANO (“Plaintiffs”), submit the following Separate Statement in Support 0f the Motion to Compel Further Discovery Responses from Defendant General Motors, LLC and Request for Sanctions. \OOO\IO\Ul-5LNN>—‘ PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION JUDICIAL COUNCIL DEFINITIONS The following definitions are approved by the California Judicial Council and are not subject to objection: 1. The words “YOU” and “YOUR” refer to GENERAL MOTORS LLC and/or any related entity, predecessor, parent, subsidiary and/or affiliate, employee, agent (including, but not limited to, any mortgage servicing agent), or any person acting or purpOITing to act on Defendant, GENERAL MOTORS LLC’s behalf. 2. The word “DOCUMENT” and “DOCUMENTS” refers to all matters that fall within the definition 0f Evidence Code §250, and includes written or printed matter 0f any kind, including the originals and all non-identical copies thereof, whether different from the original by reason of any notation made on such copies or otherwise including, but not limited to, the NNNNNNNNNb—AHHHHHHy—dr—dr—A following: advertisements, booklets, brochures, pamphlets, circulars, notices, periodicals, papers, contracts, agreements, photographs, minutes, memoranda, messages, appraisals, analyses, reports, OONQM-bWNHOCWNONUl-QWNHO financial calculations and representations, invoices, accounting and diary entries, inventory sheets, diaries, appointment books or calendars, teletypes, facsimiles, ledgers, trial balances, correspondence, telegrams, press releases, notes, working papers, drawings, schedules, tabulations, projections, mails, information or programs stored in a computer (whether or not ever printed out or displayed), and all drafts, alterations, modifications, changes 0r amendments 0f any of the foregoing, and all graphic 0r manual records or representations of any kind including, but not limited t0, the following: microfiche, microfilm, audiotapes, videotapes, recordings and motion pictures, and all electronic, mechanical or electronic records or representations of any kind including, but not limited to, the following: Tapes, cassettes, discs, magnetic cards and recordings. -2- PLAINTIFFS’ SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES