On September 21, 2020 a
Party Discovery
was filed
involving a dispute between
Brussard, James,
and
Does 1 Through 20,
General Motors, Llca Delaware Limited Liability Company,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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DAVID N. BARRY, ESQ. (SBN 219230)
THE BARRY LAW FIRM '
F E L EU
11845 W. Olympic Blvd., Suite 1270W SLgBERIOR COURT 0F CALIFORNIA
Los Angeles, CA 90064 $§§E§5Awmsr§§5é§m
" * CT “
Telephgne: 310.684.5859
Facsumle: 310.862.4539
(JCT 20 2021
Attorneys for JAMES BRUSSARD ‘
mm
Plaintiff, 1.-.‘
BY -
‘
GLomA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO — SAN BERNARDINO JUSTICE CENTER
10 .
Case N0. CIVDSZOl9921
JAMES BRUSSARD, an 1ndividual,
11
PLAINTIFF’S REPLY BRIEF IN
12 Plaintiff, SUPPORT OF PLAINTIFF’S MOTION
TO COMPEL THE DEPOSITION OF
13 V, DEFENDANT GENERAL MOTORS,
LLC’S PERSON(S) MOST
14
KNOWLEDGEABLE, WITH
PRODUCTION OF DOCUMENTS;
15
GENERAL MOTORS, LLC, A Delaware DECLARATION OF DAVID N. BARRY
16
Limited Liability Company; and DOES 1
Date: October 26,2021
. .
T' : 9:00 AM
through 20, Incluswe, D33; 525
17 QCO
18 Defendants. Action Filed: §éptember 21, 2020
Trial Date: July 20, 2021
19
Assignedfor all purposes t0 the
20 Hon. Khymberli S. Apaloo in Dept. S25
21
It is unclear whether Defendant ("General Motors," "Defendant," "GM") or its counsel
22
reviewed the relevant law and facts of this case, this Motion, or even its document production
23
before drafting its Opposition, which is replete with mischaracterizations. Plaintiff, James
24
Brussard ("Plaintiff“), therefore submits this Reply in Support of his Motion to Compel the
25
Deposition 0f Defendant General Motors, LLC's Person(s) Most Knowledgeable ("PMK"), with
26
Production of Documents. For the reasons below, Plaintiffs Motion should be granted in its
27
entirety.
28
_1_
PLAINTIFF’S REPLY BRIEF IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL THE DEPOSITION
0F DEFENDANT GENERAL MOTORS, LLC’S PERSON(S) MOST KNOWLEDGEABLE, WITH
PRODUCTION OF DOCUMENTS; DECLARATION OF DAVID N. BARRY
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Document Filed Date
October 20, 2021
Case Filing Date
September 21, 2020
Category
Breach of Contract/Warranty Unlimited
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DAVID N. BARRY, ESQ. (SBN 219230) THE BARRY LAW FIRM ' F E L EU 11845 W. Olympic Blvd., Suite 1270W SLgBERIOR COURT 0F CALIFORNIA Los Angeles, CA 90064 $§§E§5Awmsr§§5é§m " * CT “ Telephgne: 310.684.5859 Facsumle: 310.862.4539 (JCT 20 2021 Attorneys for JAMES BRUSSARD ‘ mm Plaintiff, 1.-.‘ BY - ‘ GLomA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO — SAN BERNARDINO JUSTICE CENTER 10 . Case N0. CIVDSZOl9921 JAMES BRUSSARD, an 1ndividual, 11 PLAINTIFF’S REPLY BRIEF IN 12 Plaintiff, SUPPORT OF PLAINTIFF’S MOTION TO COMPEL THE DEPOSITION OF 13 V, DEFENDANT GENERAL MOTORS, LLC’S PERSON(S) MOST 14 KNOWLEDGEABLE, WITH PRODUCTION OF DOCUMENTS; 15 GENERAL MOTORS, LLC, A Delaware DECLARATION OF DAVID N. BARRY 16 Limited Liability Company; and DOES 1 Date: October 26,2021 . . T' : 9:00 AM through 20, Incluswe, D33; 525 17 QCO 18 Defendants. Action Filed: §éptember 21, 2020 Trial Date: July 20, 2021 19 Assignedfor all purposes t0 the 20 Hon. Khymberli S. Apaloo in Dept. S25 21 It is unclear whether Defendant ("General Motors," "Defendant," "GM") or its counsel 22 reviewed the relevant law and facts of this case, this Motion, or even its document production 23 before drafting its Opposition, which is replete with mischaracterizations. Plaintiff, James 24 Brussard ("Plaintiff“), therefore submits this Reply in Support of his Motion to Compel the 25 Deposition 0f Defendant General Motors, LLC's Person(s) Most Knowledgeable ("PMK"), with 26 Production of Documents. For the reasons below, Plaintiffs Motion should be granted in its 27 entirety. 28 _1_ PLAINTIFF’S REPLY BRIEF IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL THE DEPOSITION 0F DEFENDANT GENERAL MOTORS, LLC’S PERSON(S) MOST KNOWLEDGEABLE, WITH PRODUCTION OF DOCUMENTS; DECLARATION OF DAVID N. BARRY r a f t , ( l . r m 7 . r g . 3 1 w . . . . a : a ( r. 3 , , N i 3 b 3. . S . 0