On July 21, 2022 a
Party Discovery
was filed
involving a dispute between
Ventura, Mario,
and
Does 1-10,
General Motors, Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
V ORIG‘NAL v
F LED
I
Jonathan M. Shugart, Esq. 278221SBN sggifiblgvfigggzg ggncrskAFORNlA
Jesse Valencia, Esq. (SBN 338579) D'No
ERSKINE LAW GROUP, APC
1592 N. Batavia Street, Suite 1A
AUG 2 9 2023
FAX
Orange, CA 92867
Phone: (949) 777-6032
BY Fax: (714) 844-9035
3Y2 Noreena Omiveros,
Deputy
Email: marensmcbride@erskinelaw.com
Email: jvalencia@crskinelaw.com
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT 0F CALIFORNIA
COUNTY OF SAN BERNARDINO
MARIO VENTURA, an individual, Case No.2 CIVSBZZISSZO (Dept.: Sl4)
Plaintiff, Assigned to the Hon. Jeffrey R. Erickson
V.
GENERAL MOTORS LLC’S RESPONSES TO
GENERAL MOTORS LLC, a Delaware PLAINTIFF’S FIRST SET 0F REQUESTS
lelted Llablllty Company, and DOES 1 FOR pRODUCTION
through 10, inclusive,
Defendants-
Date Filed; July 21, 2022
Trial Date: NotSet
PROPOUNDING PARTY: MARIO VENTURA
RESPONDING PARTY: GENERAL MOTORS LLC
GENERAL MOTORS LLC’S RESPONSES TO
PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
GENERAL MOTORS LLC (“GM”) responds to Plaintiff’s First Set of Requests for
Production, as follows:
GM’s responses are subject to its General Objections and any specific objection in an
individual response. These responses are complete based upon information reasonably available
to GM at this time. GM has not completed its investigation or discovery in this matter, so GM
GM‘S RESPONSES T0 PLAINTIFF’S FIRST SET 0F REQUESTS FOR PRODUCTION
reserves the right to amend or supplement its responses and to present subsequently discovered
facts or evidence at trial. GM also reserves the right to object to future discovery on the same or
related matters and to object to the admissibility of any response or document produced, in whole
or in part, at the trial in this action, on any grounds, including without limitation materiality.
relevance, and privilege.
NOS
GENERAL OBJECTIONS
These objections are incorporated into GM’s response to each Request below:
(a) GM objects to the Requests 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.
11 (b) GM objects to the Requests to the extent they seek infomation about vehicles,
12 systems, or components other than the systems or components in the 2022 Chevrolet Silverado,
13 VIN: SGCPWBEKZNGI89904 (the “SUBJECT VEHICLE“). Any such Requests are overbroad,
14 unduly burdensome, and not relevant to the subject matter of this action or reasonably calculated
15 to lead to the discovery of admissible evidence.
16 (c) GM objects t0 the Requests to the extent they seek information protected by
17 attomey-client privilege, the work-product doctrine, and/or California Code of Civil Procedure
18 Section 2034.010, et seq.
19 (d) GM objects to the Requests to the extent they seek confidential, proprietary,
20 competitively sensitive and/or trade secret information.
21 RESPONSES TO REQUESTS FOR PRODUCTION
22 REQUEST FOR PRODUCTION N0. l:
23 All DOCUMENTS regarding the SUBJECT VEHICLE that are within YOUR Customer
24 Relations Center.
25 RESPONSE TO REQUEST FOR PRODUCTION NO. l:
26 GM objects to this Request on grounds it is overbroad, unduly burdensome, oppressive, and
27 seeks documents that are irrelevant and not reasonably calculated t0 lead to the discovery of
28 admissible evidence, as it is not limited to the issues in this action. GM also objects to the extent
2
GM’S RESPONSES T0 PLAINTIFF‘S FIRST SET 0F REQUESTS FOR PRODUCTION
Document Filed Date
August 29, 2023
Case Filing Date
July 21, 2022
Category
Breach of Contract/Warranty Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
V ORIG‘NAL v F LED I Jonathan M. Shugart, Esq. 278221SBN sggifiblgvfigggzg ggncrskAFORNlA Jesse Valencia, Esq. (SBN 338579) D'No ERSKINE LAW GROUP, APC 1592 N. Batavia Street, Suite 1A AUG 2 9 2023 FAX Orange, CA 92867 Phone: (949) 777-6032 BY Fax: (714) 844-9035 3Y2 Noreena Omiveros, Deputy Email: marensmcbride@erskinelaw.com Email: jvalencia@crskinelaw.com Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT 0F CALIFORNIA COUNTY OF SAN BERNARDINO MARIO VENTURA, an individual, Case No.2 CIVSBZZISSZO (Dept.: Sl4) Plaintiff, Assigned to the Hon. Jeffrey R. Erickson V. GENERAL MOTORS LLC’S RESPONSES TO GENERAL MOTORS LLC, a Delaware PLAINTIFF’S FIRST SET 0F REQUESTS lelted Llablllty Company, and DOES 1 FOR pRODUCTION through 10, inclusive, Defendants- Date Filed; July 21, 2022 Trial Date: NotSet PROPOUNDING PARTY: MARIO VENTURA RESPONDING PARTY: GENERAL MOTORS LLC GENERAL MOTORS LLC’S RESPONSES TO PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION GENERAL MOTORS LLC (“GM”) responds to Plaintiff’s First Set of Requests for Production, as follows: GM’s responses are subject to its General Objections and any specific objection in an individual response. These responses are complete based upon information reasonably available to GM at this time. GM has not completed its investigation or discovery in this matter, so GM GM‘S RESPONSES T0 PLAINTIFF’S FIRST SET 0F REQUESTS FOR PRODUCTION reserves the right to amend or supplement its responses and to present subsequently discovered facts or evidence at trial. GM also reserves the right to object to future discovery on the same or related matters and to object to the admissibility of any response or document produced, in whole or in part, at the trial in this action, on any grounds, including without limitation materiality. relevance, and privilege. NOS GENERAL OBJECTIONS These objections are incorporated into GM’s response to each Request below: (a) GM objects to the Requests 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. 11 (b) GM objects to the Requests to the extent they seek infomation about vehicles, 12 systems, or components other than the systems or components in the 2022 Chevrolet Silverado, 13 VIN: SGCPWBEKZNGI89904 (the “SUBJECT VEHICLE“). Any such Requests are overbroad, 14 unduly burdensome, and not relevant to the subject matter of this action or reasonably calculated 15 to lead to the discovery of admissible evidence. 16 (c) GM objects t0 the Requests to the extent they seek information protected by 17 attomey-client privilege, the work-product doctrine, and/or California Code of Civil Procedure 18 Section 2034.010, et seq. 19 (d) GM objects to the Requests to the extent they seek confidential, proprietary, 20 competitively sensitive and/or trade secret information. 21 RESPONSES TO REQUESTS FOR PRODUCTION 22 REQUEST FOR PRODUCTION N0. l: 23 All DOCUMENTS regarding the SUBJECT VEHICLE that are within YOUR Customer 24 Relations Center. 25 RESPONSE TO REQUEST FOR PRODUCTION NO. l: 26 GM objects to this Request on grounds it is overbroad, unduly burdensome, oppressive, and 27 seeks documents that are irrelevant and not reasonably calculated t0 lead to the discovery of 28 admissible evidence, as it is not limited to the issues in this action. GM also objects to the extent 2 GM’S RESPONSES T0 PLAINTIFF‘S FIRST SET 0F REQUESTS FOR PRODUCTION