On July 15, 2021 a
Party Discovery
was filed
involving a dispute between
Rowan, Sandra,
and
Does 1 Through 10, Inclusive,
General Motors Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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Tionna Dolin (SBN 299010) L E .-
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e-mail: tdolin@slpattomey.com
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OF SAN B’ERPfiBDg‘NTC
SUCPO‘L‘Rtlgv
Nino Sanaia (SBN 343765) SAN BERN/‘RCWG
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e-mail: nsanaia@slpattomey.com
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STRATEGIC LEGAL PRACTICES JUN 0 6 2023
A PROFESSIONAL CORPORATION
1888 Century Park East, 19th Floor
MWx/flé": 13‘, Ha-.-
Los Angeles, CA 90067 FY ”Www— DEa-m'
Telephone: (310) 929-4900 V
.
Facsimile: (3 1 0) 943-3838
Attorneys for Plaintiff,
SANDRA ROWAN
\OOOQO\
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
SANDRA ROWAN, Case No. CIVSB21 19439
11
Plaintiff, Case Initiated: July 15, 2021
12
13 VS. Assigned To: Hon. Michael A. Sachs
Department: $28
14 GENERAL MOTORS LLC, DOES 1
through 10, inclusive, INFORMAL DISCOVERY
PLAINTIFF’S
15
CONFERENCE STATEMENT RE:
Defendants. DEFENDANT’S OBJECTIONS TO
16
PLAINTIFF’S NOTICE OF
17
DEPOSITION OF PERSON MOST
KNOWLEDGABLE AND REQUEST
18
FOR PRODUCTION, SET ONE
19 Date: June 16, 2023
Time: 10:00 a.m.
20 Dept: 828
21
22
23
24
25
26
27
28
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PLAINTIFF’S INFORMAL DISCOVERY CQEFERENCE STATEWNT
Plaintiff SANDRA ROWAN (“Plaintiff”) respectfully submits her Informal Discovery
Conference (“IDC”) Statement of Position regarding her discovery dispute with Defendant
General Motors, LLC’s (“Defendant” or “GM”) response to Plaintiff’s Notice of Deposition of
the Person Most Knowledgeable (PMK) for GM and response to Plaintiff’s Request for
Production of Documents, Set One (“RFP(1)”).
I. GM Has Refused to Provide a Date t0 Depose Its PMK Witness
On January 18, 2023, Plaintiff served its Amended Notice of Deposition of the Person
\OOONO‘x
Most Knowledgeable (PMK) for General Motors, LLC to take place on February 13, 2023. On
February 6, 2023, GM served its Objection to the Amended Notice of PMK Deposition stating
10 that it was unilaterally set, but that it would provide alternative dates. GM never provided a date.
11 On February 10, 2023, Plaintiff sent a meet and confer letter to Defendant regarding GM’s
12 inadequate responses and meritless objections to Plaintiff‘s Notice of Deposition of Defendant’s
13 PMK and Demand to Produce Documents at Deposition. Plaintiff provided case law to support
14 its position that the deposition categories were necessary to prove her case at trial and requested
15 a confirmed PMK date. GM never provided a date.
16 On February 23, 2023, GM responded to Plaintiff‘s February 10, 2023, meet and confer
17 letter and once again said “GM will provide a date.” GM never provided a date.
18 The three categories 0f testimony and documents that Plaintiff seeks are regarding: 1) the
19 Subject Vehicle and its repair history; 2) GM’s internal investigation and analysis and
20 fixes/repairs for the Transmission and A/C Defects; and 3) GM’s warranty and vehicle
21 repurchase policies, procedures, and practices.
22 Plaintiff carefully drafted the Transmission and A/C Defects definitions based on her own
23 experiences with the Subject Vehicle, the Subject Vehicle’s repair history, and GM’s own repair
24 procedures. The scope 0f the deposition is what is relevant to the allegations in Plaintiff s
25 Complaint and defenses to those allegations.
26 GM agrees to produce a witness on categories 1-5, 8-27, and 32-38, but has failed to do
27 so. Furthermore, GM refuses to produce a witness on categories 6, 7, 28, 29, 30, and 31. These
28
1
PLAINTIFF’S INFORMAL DISCOVERY CONFERENCE STATEMENT
23011166“
“" """" "‘" "
Document Filed Date
June 06, 2023
Case Filing Date
July 15, 2021
Category
Breach of Contract/Warranty Unlimited
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V >1§£s§fl®lflNtAL V Tionna Dolin (SBN 299010) L E .- D . ... . 3 4R I . 7A e-mail: tdolin@slpattomey.com "‘- . COURT O!- Cf: .llr OF SAN B’ERPfiBDg‘NTC SUCPO‘L‘Rtlgv Nino Sanaia (SBN 343765) SAN BERN/‘RCWG Db RI I l e-mail: nsanaia@slpattomey.com L») STRATEGIC LEGAL PRACTICES JUN 0 6 2023 A PROFESSIONAL CORPORATION 1888 Century Park East, 19th Floor MWx/flé": 13‘, Ha-.- Los Angeles, CA 90067 FY ”Www— DEa-m' Telephone: (310) 929-4900 V . Facsimile: (3 1 0) 943-3838 Attorneys for Plaintiff, SANDRA ROWAN \OOOQO\ SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 SANDRA ROWAN, Case No. CIVSB21 19439 11 Plaintiff, Case Initiated: July 15, 2021 12 13 VS. Assigned To: Hon. Michael A. Sachs Department: $28 14 GENERAL MOTORS LLC, DOES 1 through 10, inclusive, INFORMAL DISCOVERY PLAINTIFF’S 15 CONFERENCE STATEMENT RE: Defendants. DEFENDANT’S OBJECTIONS TO 16 PLAINTIFF’S NOTICE OF 17 DEPOSITION OF PERSON MOST KNOWLEDGABLE AND REQUEST 18 FOR PRODUCTION, SET ONE 19 Date: June 16, 2023 Time: 10:00 a.m. 20 Dept: 828 21 22 23 24 25 26 27 28 ~-: ,4." PLAINTIFF’S INFORMAL DISCOVERY CQEFERENCE STATEWNT Plaintiff SANDRA ROWAN (“Plaintiff”) respectfully submits her Informal Discovery Conference (“IDC”) Statement of Position regarding her discovery dispute with Defendant General Motors, LLC’s (“Defendant” or “GM”) response to Plaintiff’s Notice of Deposition of the Person Most Knowledgeable (PMK) for GM and response to Plaintiff’s Request for Production of Documents, Set One (“RFP(1)”). I. GM Has Refused to Provide a Date t0 Depose Its PMK Witness On January 18, 2023, Plaintiff served its Amended Notice of Deposition of the Person \OOONO‘x Most Knowledgeable (PMK) for General Motors, LLC to take place on February 13, 2023. On February 6, 2023, GM served its Objection to the Amended Notice of PMK Deposition stating 10 that it was unilaterally set, but that it would provide alternative dates. GM never provided a date. 11 On February 10, 2023, Plaintiff sent a meet and confer letter to Defendant regarding GM’s 12 inadequate responses and meritless objections to Plaintiff‘s Notice of Deposition of Defendant’s 13 PMK and Demand to Produce Documents at Deposition. Plaintiff provided case law to support 14 its position that the deposition categories were necessary to prove her case at trial and requested 15 a confirmed PMK date. GM never provided a date. 16 On February 23, 2023, GM responded to Plaintiff‘s February 10, 2023, meet and confer 17 letter and once again said “GM will provide a date.” GM never provided a date. 18 The three categories 0f testimony and documents that Plaintiff seeks are regarding: 1) the 19 Subject Vehicle and its repair history; 2) GM’s internal investigation and analysis and 20 fixes/repairs for the Transmission and A/C Defects; and 3) GM’s warranty and vehicle 21 repurchase policies, procedures, and practices. 22 Plaintiff carefully drafted the Transmission and A/C Defects definitions based on her own 23 experiences with the Subject Vehicle, the Subject Vehicle’s repair history, and GM’s own repair 24 procedures. The scope 0f the deposition is what is relevant to the allegations in Plaintiff s 25 Complaint and defenses to those allegations. 26 GM agrees to produce a witness on categories 1-5, 8-27, and 32-38, but has failed to do 27 so. Furthermore, GM refuses to produce a witness on categories 6, 7, 28, 29, 30, and 31. These 28 1 PLAINTIFF’S INFORMAL DISCOVERY CONFERENCE STATEMENT 23011166“ “" """" "‘" "