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~ ORT'GINAL
KNIGHT LAW GROUP LLP
Roger Kimos (SBN 283163)
RogerK@knightlaw.com
Maxwell Kreymer (SBN 33 1240) SUPERIORFCOIUIRTEF EALIFORNIA
Maxwellk@knightlaw.c0m C&JBTEEESAgADB'INBOEIRaréKTRggo
10250 Constellation B1Vd., Suite 2500
Los Angeles, CA 90067
DEC 14 2022
Tel: (310) 552-2250
\OOONQUI-bUJNr—I
Fax: (323) 552-7973
‘
BY .
Attorneys for Plaintiffs, GLOR‘A MARIN, DEPUTY
RUBEN ROSALES and
LAURA DOMINGUEZ-ROSALES
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
RUBEN ROSALES and Case No.: CIV832205939
Unlimited Jurisdiction
LAURA DOMINGUEz-ROSALES,
Plaintiffs, PLAINTIFFS’ SEPARATE A8
STATEMENT IN SUPPORT 0F
MOTION TO COMPEL FURTHER
VS' DISCOVERY RESPONSES FROM XVd
DEFENDANT, AND REQUEST FOR
SANCTIONS
GENERAL MOTORS LLC, a Delaware
[Submitted concurrently with Notice 0f
L- d L- b-l-t C mp a ny’ an d DOES 1
-t .
133 illlcllzsivoe Motlon t0 Compel, Memorandum of Pomts
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“1:111:11 9 9
and Authorities in Suppofl of Plaintiffs’
Motion, [Proposed] Order and Declaration of
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Maxwell Kreymer.]
Defendants.
Hearing Date: February 6, 2023
Hearing Time: 8:30 am.
Department: $28
Date Filed: March 21, 2022
Trial Date: November 6, 2023
-1-
PLAINTIFF’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER
DISCOVERY RESPONSES
TO ALL INTERESTED PARTIES AND TO ATTORNEYS OF RECORD:
Plaintiffs RUBEN ROSALES and LAURA DOMINGUES-ROSALES (“Plaintiffs”)
submits the following Separate Statement in Support of the Motion to Compel Further Discovery
\OOONONUl-hwwt—
Responses from Defendant General Motors, LLC and Request for Sanctions.
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION
JUDICIAL COUNCIL DEFINITIONS
The following definitions are approved by the California Judicial Council and are not
subject to objection:
1. The words “YOU” and “YOUR” refer to GENERAL MOTORS LLC and/or any
related entity, predecessor, parent, subsidiary and/or affiliate, employee, agent (including, but not
limited to, any mortgage servicing agent), or any person acting or purporting to act 0n Defendant,
GENERAL MOTORS LLC’s behalf.
2. The word “DOCUMENT” and “DOCUMENTS” refers to all matters that fall
within the definition of Evidence Code §250, and includes written or printed matter of any kind,
including the originals and all non-identical copies thereof, whether different from the original by
reason of any notation made on such copies or otherwise including, but not limited to, the
following: advertisements, booklets, brochures, pamphlets, circulars, notices, periodicals, papers,
NNNNNNNNNHHb—dr—tr—dp—WHHH
contracts, agreements, photographs, minutes, memoranda, messages, appraisals, analyses, reports,
OONONM$WN~O©OOQOMAUJNHO
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, proj ections, mails, information or programs stored in a computer (whether or not ever
printed out or displayed), and all drafts, alterations, modifications, changes or amendments of any
of the foregoing, and all graphic or manual records or representations of any kind including, but
not limited to, 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.
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PLAINTIFF’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER
DISCOVERY RESPONSES
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~ ORT'GINAL KNIGHT LAW GROUP LLP Roger Kimos (SBN 283163) RogerK@knightlaw.com Maxwell Kreymer (SBN 33 1240) SUPERIORFCOIUIRTEF EALIFORNIA Maxwellk@knightlaw.c0m C&JBTEEESAgADB'INBOEIRaréKTRggo 10250 Constellation B1Vd., Suite 2500 Los Angeles, CA 90067 DEC 14 2022 Tel: (310) 552-2250 \OOONQUI-bUJNr—I Fax: (323) 552-7973 ‘ BY . Attorneys for Plaintiffs, GLOR‘A MARIN, DEPUTY RUBEN ROSALES and LAURA DOMINGUEZ-ROSALES SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO RUBEN ROSALES and Case No.: CIV832205939 Unlimited Jurisdiction LAURA DOMINGUEz-ROSALES, Plaintiffs, PLAINTIFFS’ SEPARATE A8 STATEMENT IN SUPPORT 0F MOTION TO COMPEL FURTHER VS' DISCOVERY RESPONSES FROM XVd DEFENDANT, AND REQUEST FOR SANCTIONS GENERAL MOTORS LLC, a Delaware [Submitted concurrently with Notice 0f L- d L- b-l-t C mp a ny’ an d DOES 1 -t . 133 illlcllzsivoe Motlon t0 Compel, Memorandum of Pomts NNNNNNNNNb—dv—Ab—ap—dt—tp—nr—AHHH “1:111:11 9 9 and Authorities in Suppofl of Plaintiffs’ Motion, [Proposed] Order and Declaration of mflam¥WNHO©OOQQM#WNt—‘O Maxwell Kreymer.] Defendants. Hearing Date: February 6, 2023 Hearing Time: 8:30 am. Department: $28 Date Filed: March 21, 2022 Trial Date: November 6, 2023 -1- PLAINTIFF’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES TO ALL INTERESTED PARTIES AND TO ATTORNEYS OF RECORD: Plaintiffs RUBEN ROSALES and LAURA DOMINGUES-ROSALES (“Plaintiffs”) submits the following Separate Statement in Support of the Motion to Compel Further Discovery \OOONONUl-hwwt— Responses from Defendant General Motors, LLC and Request for Sanctions. PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION JUDICIAL COUNCIL DEFINITIONS The following definitions are approved by the California Judicial Council and are not subject to objection: 1. The words “YOU” and “YOUR” refer to GENERAL MOTORS LLC and/or any related entity, predecessor, parent, subsidiary and/or affiliate, employee, agent (including, but not limited to, any mortgage servicing agent), or any person acting or purporting to act 0n Defendant, GENERAL MOTORS LLC’s behalf. 2. The word “DOCUMENT” and “DOCUMENTS” refers to all matters that fall within the definition of Evidence Code §250, and includes written or printed matter of any kind, including the originals and all non-identical copies thereof, whether different from the original by reason of any notation made on such copies or otherwise including, but not limited to, the following: advertisements, booklets, brochures, pamphlets, circulars, notices, periodicals, papers, NNNNNNNNNHHb—dr—tr—dp—WHHH contracts, agreements, photographs, minutes, memoranda, messages, appraisals, analyses, reports, OONONM$WN~O©OOQOMAUJNHO 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, proj ections, mails, information or programs stored in a computer (whether or not ever printed out or displayed), and all drafts, alterations, modifications, changes or amendments of any of the foregoing, and all graphic or manual records or representations of any kind including, but not limited to, 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- PLAINTIFF’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES