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V ORIGHNAL v
F LED
l
SUPERIOR count 0F CALIFORNIA
Jonathan M. Shugart, Esq. SBN 278221 COUNTY OF SAN BERNARDINO
Jesse Valencia, Esq. (SBN 338579)
ERSKINE LAW GROUP, APC AUG 2 9 2023
1592 N. Batavia Street, Suite 1A
Orange, CA92867
Phone: (949) 777-6032 BY: Nonena Ontlvoroa Deputy
FM Fax: (714) 844-9035
‘
Email: marensmcbride@erskinelaw.com
BY Email: jvalencia@crskinclaw.com
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT OF CALIFORNIA
10
COUNTY OF SAN BERNARDINO
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MARIO VENTURA, an individual, Case No.: CIVSBZZIS820 (Dept.: $14)
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Plaintiff, Assigned to the Hon. Jeffrey R. Erickson
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V.
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GENERAL MOTORS LLC’S RESPONSES
15 GENERAL MOTORS LLC, a Delaware T0 pLAlNTlFF’S SPECIAL
Limited Liability Company, and DOES 1 INTERROGATORIES, SET ONE
16 through 10, inclusive,
l7 Defendants-
Date Filed: July 21, 2022
l8 TrialDate: NotSet
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PROPOUNDING PARTY: MARIO VENTURA
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RESPONDING PARTY: GENERAL MOTORS LLC
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GENERAL MOTORS LLC’S RESPONSES TO
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PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE
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GENERAL MOTORS LLC (“GM") responds to Plaintiff‘s Special Interrogatories, Set
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One, as follows:
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GM’S responses are subject t0 its General Objections and any specific objection in an
26
individual response. These responses arc complete based upon information reasonably available to
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GM at this time. GM has not completed its investigation or discovery in this matter, so GM reserves
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GM‘S RESPONSES T0 PLAINTIFF‘S SPECIAL INTERROGATORIES, SET ONE
the right to amend or supplement its responses and to present subsequently discovered facts or
evidence at trial. GM also reserves the right t0 object to future discovery on the same or related
matters and to object t0 the admissibility of any response 0r document produced, in whole or in
MAWN
part, at the trial in this action, on any grounds, including without limitation materiality, relevance,
and privilege.
GENERAL OBJECTIONS
These objections are incorporated into GM’s response to each Interrogatory below:
\OWQQ
(a) GM objects to the Interrogatories to the extent they seek information beyond GM’s
possession, custody. or control. These responses are made on behalf of General Motors LLC only.
10 GM objects to this discovery to the extent it seeks information from any other entity.
ll (b) GM objects to the Interrogatories to the extent they seek information about vehicles,
12 systems or components other than systems or components in thc 2022 Chevrolet Silverado, VIN:
13 3GCPWBEK2NGI89904 (the “SUBJECT VEHICLE"). Any such lnterrogatories are overbroad,
l4 unduly burdensome, and not relevant to the subject matter of this action or reasonably calculated
15 to lead to the discovery of admissible evidence.
l6 (c) GM objects t0 the Interrogatories to the extent they seek information protected by
l7 attomey-client privilege, the work-product doctrine, and/or California Code of Civil Procedure
18 section 2034.0 l 0, et seq.
l9 (d) GM objects to the Interrogatories to the extent they seek confidential, proprietary,
20 competitively sensitive and/or trade secret information.
21 RESPONSES TO SPECIAL INTERROGATORIES
22 SPECIAL INTERROGATORY NO. l:
23 State the terms of coverage, time limitations, mileage limitations, and exclusion of each of
24 YOUR written warranties for the SUBJECT VEHICLE.
25 The words “YOU" and “YOUR” refer to GENERAL MOTORS LLC and/or any related
26 entity, predecessor, parent, subsidiary and/or affiliate, employee, agent (including, but not limited
27 to, any mortgage servicing agent), or any person acting or purporting to act on Defendant,
28 GENERAL MOTORS LLC’S behalf.
2
GM‘S RESPONSES T0 PLAINTIFF‘S SPECIAL INTERROGATORIES. SET ONE
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V ORIGHNAL v F LED l SUPERIOR count 0F CALIFORNIA Jonathan M. Shugart, Esq. SBN 278221 COUNTY OF SAN BERNARDINO Jesse Valencia, Esq. (SBN 338579) ERSKINE LAW GROUP, APC AUG 2 9 2023 1592 N. Batavia Street, Suite 1A Orange, CA92867 Phone: (949) 777-6032 BY: Nonena Ontlvoroa Deputy FM Fax: (714) 844-9035 ‘ Email: marensmcbride@erskinelaw.com BY Email: jvalencia@crskinclaw.com Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 MARIO VENTURA, an individual, Case No.: CIVSBZZIS820 (Dept.: $14) 12 Plaintiff, Assigned to the Hon. Jeffrey R. Erickson 13 V. 14 GENERAL MOTORS LLC’S RESPONSES 15 GENERAL MOTORS LLC, a Delaware T0 pLAlNTlFF’S SPECIAL Limited Liability Company, and DOES 1 INTERROGATORIES, SET ONE 16 through 10, inclusive, l7 Defendants- Date Filed: July 21, 2022 l8 TrialDate: NotSet 19 PROPOUNDING PARTY: MARIO VENTURA 20 RESPONDING PARTY: GENERAL MOTORS LLC 21 GENERAL MOTORS LLC’S RESPONSES TO 22 PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE 23 GENERAL MOTORS LLC (“GM") responds to Plaintiff‘s Special Interrogatories, Set 24 One, as follows: 25 GM’S responses are subject t0 its General Objections and any specific objection in an 26 individual response. These responses arc complete based upon information reasonably available to 27 GM at this time. GM has not completed its investigation or discovery in this matter, so GM reserves 28 GM‘S RESPONSES T0 PLAINTIFF‘S SPECIAL INTERROGATORIES, SET ONE the right to amend or supplement its responses and to present subsequently discovered facts or evidence at trial. GM also reserves the right t0 object to future discovery on the same or related matters and to object t0 the admissibility of any response 0r document produced, in whole or in MAWN part, at the trial in this action, on any grounds, including without limitation materiality, relevance, and privilege. GENERAL OBJECTIONS These objections are incorporated into GM’s response to each Interrogatory below: \OWQQ (a) GM objects to the Interrogatories to the extent they seek information beyond GM’s possession, custody. or control. These responses are made on behalf of General Motors LLC only. 10 GM objects to this discovery to the extent it seeks information from any other entity. ll (b) GM objects to the Interrogatories to the extent they seek information about vehicles, 12 systems or components other than systems or components in thc 2022 Chevrolet Silverado, VIN: 13 3GCPWBEK2NGI89904 (the “SUBJECT VEHICLE"). Any such lnterrogatories are overbroad, l4 unduly burdensome, and not relevant to the subject matter of this action or reasonably calculated 15 to lead to the discovery of admissible evidence. l6 (c) GM objects t0 the Interrogatories to the extent they seek information protected by l7 attomey-client privilege, the work-product doctrine, and/or California Code of Civil Procedure 18 section 2034.0 l 0, et seq. l9 (d) GM objects to the Interrogatories to the extent they seek confidential, proprietary, 20 competitively sensitive and/or trade secret information. 21 RESPONSES TO SPECIAL INTERROGATORIES 22 SPECIAL INTERROGATORY NO. l: 23 State the terms of coverage, time limitations, mileage limitations, and exclusion of each of 24 YOUR written warranties for the SUBJECT VEHICLE. 25 The words “YOU" and “YOUR” refer to GENERAL MOTORS LLC and/or any related 26 entity, predecessor, parent, subsidiary and/or affiliate, employee, agent (including, but not limited 27 to, any mortgage servicing agent), or any person acting or purporting to act on Defendant, 28 GENERAL MOTORS LLC’S behalf. 2 GM‘S RESPONSES T0 PLAINTIFF‘S SPECIAL INTERROGATORIES. SET ONE