On October 04, 2021 a
Party Discovery
was filed
involving a dispute between
Medina, Ernesto,
Rodriguez, Porfirio,
and
Does 1 To 10,
General Motors, Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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ORIGINAL
Mary Arens McBride. Esq. (SBN: 282459)
Jesse Valencia. Esq. (SBN: 338579)
ERSKINE LAW GROUP, APC
-
D
“J'ERIOR COURT CF CMJFORN'A
1592 N. Batavia Street. Suite IA
Orangc, CA 92867
fl “RMRDNO
COUNTY OF SAN BERNARDtNO
DSTPcT
Telephone: (949) 777-6032 AUG 09 2023
Facsimile: (714) 844-9035
Email: marensmcbride@crskinelaw.com .
©00\IO\MAWN—
BY
Email: jvalcncia@erskinelaw.com
AMHONY MZ. 60W
Attorneys for Defendant.
GENERAL MOTORS LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNADINO
PORFIRIO RODRIGUEZ. an individual. AND Case No.2 CIVSBZ 128483
ERNESTO MEDINA, an individual.
Assigned to the Hon. Bryan Foster in
Department $33
Plaintiffs,
GENERAL MOTORS LLC’S
V.
MEMORANDUM OF POINTS AND
AUTHORITIES IN OPPOSITION TO
GENERAL MOTORS LLC, a Delaware Limited
MOTION TO COMPEL
PLAINTIFFS'
Liability Company, and DOES l through 10, FURTHER RESPONSES TO
inclusive,
REQUESTS FOR PRODUCTION OF
DOCUMENTS, SET ONE
Defendants.
Filed Concurrently With:
l) Separate Statement
mfiamhw-o©mfl®m§WN~o
NNNNNNNNNHH—‘HH—H———
2) Declaration of Jesse Valencia
Date: August 21. 2023
Time: 8:30 a.m.
Dcpt.: S32
Complaint October 4, 2021
Filed:
Trial Date: September 5, 2023
MEMORANDUM OF POINTS AND AUTHORITIES
l. INTRODUCTION
AWN
Plaintiffs’ motion to compel should be denied on the merits. In this simple breach of warranty
case about a 2019 Chevrolet Silverado. Plaintiffs have already served GM with fl discovery requests:
37 Requests for Production. 21 Form Interrogatories, 67 Special Interrogatories. and
25 Requests for
Admission. GM has timely responded to all .15_0 requests and, with its responses and objections.
produced all ofthesc materials:
0 the 2019 Chevrolet Silverado Limited Warranty and Owner Assistance
Information (i.e.. the
document containing the warranty at issue):
0 GM's Global Warranty History Reports for Plaintiffs' Silverado, including that vehicle‘s
Transaction History documenting all the warranty repairs for which — not Plaintiffs — GM
paid;
o BARS Invoice reflecting thc components included in Plaintiffs’ Silverado at thc time of
delivery and the corresponding MSRP value;
0 GM‘s Customer Assistance Center records reflecting communications regarding Plaintiffs‘
Silverado (12a, thc Service Request Activity History);
0 the Owner‘s Manual for the 2019 Chevrolet Silverado;
0 thc Service Manual for the 2019 Chevrolet Silverado;
0 Vehicle History Report and Repair Order Details for Plaintiffs” Silverado;
0 CA CEC Case Assessment:
0 two manufacturer‘s product brochures for the 2019 Chevrolet Silverado; and
0 recalls, bulletins, a list of Technical Service Bulletins, and a list of Information Service
Bulletins for the 2019 Chevrolet Silverado.
Plaintiffs docs not need one single page more from GM to pursue their claims. This motion
demands the production of documents about vehicles other than their Silverado and the warranty
repairs that were performed on Plaintiffs’ Silverado at no expense to them. Plaintiffs’ motion should be
denied.
II. PROCEDURAL HISTORY
GM’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION T0 PLAINTIFFS’ MOTION T0
COMPEL FURTHER RESPONSES T0 REQUESTS FOR PRODUCTION OF DOCUMENTS, SET T‘VO
1
Document Filed Date
August 09, 2023
Case Filing Date
October 04, 2021
Category
Breach of Contract/Warranty Unlimited
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ORIGINAL Mary Arens McBride. Esq. (SBN: 282459) Jesse Valencia. Esq. (SBN: 338579) ERSKINE LAW GROUP, APC - D “J'ERIOR COURT CF CMJFORN'A 1592 N. Batavia Street. Suite IA Orangc, CA 92867 fl “RMRDNO COUNTY OF SAN BERNARDtNO DSTPcT Telephone: (949) 777-6032 AUG 09 2023 Facsimile: (714) 844-9035 Email: marensmcbride@crskinelaw.com . ©00\IO\MAWN— BY Email: jvalcncia@erskinelaw.com AMHONY MZ. 60W Attorneys for Defendant. GENERAL MOTORS LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNADINO PORFIRIO RODRIGUEZ. an individual. AND Case No.2 CIVSBZ 128483 ERNESTO MEDINA, an individual. Assigned to the Hon. Bryan Foster in Department $33 Plaintiffs, GENERAL MOTORS LLC’S V. MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO GENERAL MOTORS LLC, a Delaware Limited MOTION TO COMPEL PLAINTIFFS' Liability Company, and DOES l through 10, FURTHER RESPONSES TO inclusive, REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE Defendants. Filed Concurrently With: l) Separate Statement mfiamhw-o©mfl®m§WN~o NNNNNNNNNHH—‘HH—H——— 2) Declaration of Jesse Valencia Date: August 21. 2023 Time: 8:30 a.m. Dcpt.: S32 Complaint October 4, 2021 Filed: Trial Date: September 5, 2023 MEMORANDUM OF POINTS AND AUTHORITIES l. INTRODUCTION AWN Plaintiffs’ motion to compel should be denied on the merits. In this simple breach of warranty case about a 2019 Chevrolet Silverado. Plaintiffs have already served GM with fl discovery requests: 37 Requests for Production. 21 Form Interrogatories, 67 Special Interrogatories. and 25 Requests for Admission. GM has timely responded to all .15_0 requests and, with its responses and objections. produced all ofthesc materials: 0 the 2019 Chevrolet Silverado Limited Warranty and Owner Assistance Information (i.e.. the document containing the warranty at issue): 0 GM's Global Warranty History Reports for Plaintiffs' Silverado, including that vehicle‘s Transaction History documenting all the warranty repairs for which — not Plaintiffs — GM paid; o BARS Invoice reflecting thc components included in Plaintiffs’ Silverado at thc time of delivery and the corresponding MSRP value; 0 GM‘s Customer Assistance Center records reflecting communications regarding Plaintiffs‘ Silverado (12a, thc Service Request Activity History); 0 the Owner‘s Manual for the 2019 Chevrolet Silverado; 0 thc Service Manual for the 2019 Chevrolet Silverado; 0 Vehicle History Report and Repair Order Details for Plaintiffs” Silverado; 0 CA CEC Case Assessment: 0 two manufacturer‘s product brochures for the 2019 Chevrolet Silverado; and 0 recalls, bulletins, a list of Technical Service Bulletins, and a list of Information Service Bulletins for the 2019 Chevrolet Silverado. Plaintiffs docs not need one single page more from GM to pursue their claims. This motion demands the production of documents about vehicles other than their Silverado and the warranty repairs that were performed on Plaintiffs’ Silverado at no expense to them. Plaintiffs’ motion should be denied. II. PROCEDURAL HISTORY GM’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION T0 PLAINTIFFS’ MOTION T0 COMPEL FURTHER RESPONSES T0 REQUESTS FOR PRODUCTION OF DOCUMENTS, SET T‘VO 1