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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Mary Arens McBride, Esq. (SBN 282459)
Cameron Major, Esq. (SBN 325986)
ERSKINE LAW GROUP, PC
1592 N. Batavia St., Suite 1A ELECTRONICALLY FILED
Orange, CA 92867 SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Tel: (949) 777-6032 SAN BERNARDINO DISTRICT
Fax: (714) 844-9035
Email: marensmcbride@erskinelaw.com 10/1 1/2023 8:47 PM
Email: cmajor@erskinelaw.com By: Paola Iniguez Solorio, DEPUTY
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
11
JAMES BRUSSARD, an individual, CASE NO.: CIVDSZO 1 9921
12
13
Plaintiff, ASSIGNED T0:
Honorable Jeffrey R. Erickson
14 vs. Department SI 4
15 GENERAL MOTORS LLC, a Delaware Date Filed: September 21, 2020
Limited Liability Company; and DOES Trial Date: October 23, 2023
16
1 through 20, inclusive,
17
Defendants. DEFENDANT GENERAL MOTORS LLC’S
18 OBJECTION TO PLAINTIFF’S NOTICE TO
GENERAL MOTORS LLC’S EMPLOYEES
19 LAURENCE BRADDELL AND MICHELLE
20
MOCK TO APPEAR AND PRODUCE
DOCUMENTS AT TRIAL
21
22
23
24
25 General Motors LLC (“GM”) hereby obj ects t0 Plaintiff” s Notice t0 General Motors LLC’s
26 Employees, Laurence Braddell and Michelle Mock, t0 Appear and Produce Documents at Trial (the
27
“N0tice”) scheduled for October 23, 2023, at 9:00 a.m., at 247 W 3rd St, Department Sl4, San
28 Bernardino, CA 92415 as follows:
Page 1 0f 10
DEFENDANT GENERAL MOTORS LLC’S OBJECTION TO PLAINTIFF’S NOTICE TO GENERAL MOTORS LLC’S
EMPLOYEES LAURENCE BRADDELL AND MICHELLE MOCK TO APPEAR AND PRODUCE DOCUMENTS AT TRIAL
GENERAL OBJECTIONS
1. GM obj ects t0 the Notice as unreasonable, as it was not served with sufficient time
in advance 0f trial, so as t0 allow the witnesses a reasonable time for preparation and travel pursuant
t0 Code 0f Civil Procedure Section 1987(0).
2. GM objects t0 the Notice because the time set for production 0f documents is
unreasonable, as it was not served a sufficient time in advance 0f trial pursuant t0 Code 0f Civil
Procedure Section 1987(0).
3. GM objects t0 the Notice because it seeks t0 compel the physical attendance 0f a
witness who is not a resident 0f the State 0f California, and therefore, violates Code 0f Civil
10 Procedure Section 1989.
11 4. GM objects t0 the Notice 0n grounds the appearance 0f Mr. Braddell 0r Ms. Mock
12 is not likely t0 lead t0 the discovery 0f admissible information 0r evidence.
13 5. GM objects t0 the Notice 0n grounds Mr. Braddell’s 0r Ms. Mock’s appearance at
14 trial would be unduly burdensome, and Plaintiffs reasoning for noticing Mr. Braddell’s and Ms.
15 Mock’s appearance at trial has not been stated with reasonable particularity.
16 6. GM obj ects t0 the Notice t0 the extent it seeks information and testimony protected
17 from disclosure by the attorney-client privilege 0r attorney work-product doctrine.
18 7. GM objects t0 the Notice as it requests documents which GM has previously
19 produced.
20 GM incorporates each 0f these General Objections into each 0f the specific responses set
21 forth below.
22
23 REQUEST NO. 1:
24 A11 documents related t0 the Subject Vehicle, including but not limited t0 the entire
25 warranty history and all warranties that accompanied Plaintiffs Vehicle at the time 0f purchase;
26 OBJECTION TO REQUEST NO. 1:
27 GM obj ects t0 this Request 0n the grounds that it does not state the exact materials 0r things
28 t0 be produced as required by Code 0f Civil Procedure Section 1987(0). GM also objects t0 this
Page 2 0f 10
DEFENDANT GENERAL MOTORS LLC’S OBJECTION TO PLAINTIFF’S NOTICE TO GENERAL MOTORS LLC’S
EMPLOYEES LAURENCE BRADDELL AND MICHELLE MOCK TO APPEAR AND PRODUCE DOCUMENTS AT TRIAL
Document Filed Date
October 11, 2023
Case Filing Date
September 21, 2020
Category
Breach of Contract/Warranty Unlimited
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Mary Arens McBride, Esq. (SBN 282459) Cameron Major, Esq. (SBN 325986) ERSKINE LAW GROUP, PC 1592 N. Batavia St., Suite 1A ELECTRONICALLY FILED Orange, CA 92867 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO Tel: (949) 777-6032 SAN BERNARDINO DISTRICT Fax: (714) 844-9035 Email: marensmcbride@erskinelaw.com 10/1 1/2023 8:47 PM Email: cmajor@erskinelaw.com By: Paola Iniguez Solorio, DEPUTY Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 JAMES BRUSSARD, an individual, CASE NO.: CIVDSZO 1 9921 12 13 Plaintiff, ASSIGNED T0: Honorable Jeffrey R. Erickson 14 vs. Department SI 4 15 GENERAL MOTORS LLC, a Delaware Date Filed: September 21, 2020 Limited Liability Company; and DOES Trial Date: October 23, 2023 16 1 through 20, inclusive, 17 Defendants. DEFENDANT GENERAL MOTORS LLC’S 18 OBJECTION TO PLAINTIFF’S NOTICE TO GENERAL MOTORS LLC’S EMPLOYEES 19 LAURENCE BRADDELL AND MICHELLE 20 MOCK TO APPEAR AND PRODUCE DOCUMENTS AT TRIAL 21 22 23 24 25 General Motors LLC (“GM”) hereby obj ects t0 Plaintiff” s Notice t0 General Motors LLC’s 26 Employees, Laurence Braddell and Michelle Mock, t0 Appear and Produce Documents at Trial (the 27 “N0tice”) scheduled for October 23, 2023, at 9:00 a.m., at 247 W 3rd St, Department Sl4, San 28 Bernardino, CA 92415 as follows: Page 1 0f 10 DEFENDANT GENERAL MOTORS LLC’S OBJECTION TO PLAINTIFF’S NOTICE TO GENERAL MOTORS LLC’S EMPLOYEES LAURENCE BRADDELL AND MICHELLE MOCK TO APPEAR AND PRODUCE DOCUMENTS AT TRIAL GENERAL OBJECTIONS 1. GM obj ects t0 the Notice as unreasonable, as it was not served with sufficient time in advance 0f trial, so as t0 allow the witnesses a reasonable time for preparation and travel pursuant t0 Code 0f Civil Procedure Section 1987(0). 2. GM objects t0 the Notice because the time set for production 0f documents is unreasonable, as it was not served a sufficient time in advance 0f trial pursuant t0 Code 0f Civil Procedure Section 1987(0). 3. GM objects t0 the Notice because it seeks t0 compel the physical attendance 0f a witness who is not a resident 0f the State 0f California, and therefore, violates Code 0f Civil 10 Procedure Section 1989. 11 4. GM objects t0 the Notice 0n grounds the appearance 0f Mr. Braddell 0r Ms. Mock 12 is not likely t0 lead t0 the discovery 0f admissible information 0r evidence. 13 5. GM objects t0 the Notice 0n grounds Mr. Braddell’s 0r Ms. Mock’s appearance at 14 trial would be unduly burdensome, and Plaintiffs reasoning for noticing Mr. Braddell’s and Ms. 15 Mock’s appearance at trial has not been stated with reasonable particularity. 16 6. GM obj ects t0 the Notice t0 the extent it seeks information and testimony protected 17 from disclosure by the attorney-client privilege 0r attorney work-product doctrine. 18 7. GM objects t0 the Notice as it requests documents which GM has previously 19 produced. 20 GM incorporates each 0f these General Objections into each 0f the specific responses set 21 forth below. 22 23 REQUEST NO. 1: 24 A11 documents related t0 the Subject Vehicle, including but not limited t0 the entire 25 warranty history and all warranties that accompanied Plaintiffs Vehicle at the time 0f purchase; 26 OBJECTION TO REQUEST NO. 1: 27 GM obj ects t0 this Request 0n the grounds that it does not state the exact materials 0r things 28 t0 be produced as required by Code 0f Civil Procedure Section 1987(0). GM also objects t0 this Page 2 0f 10 DEFENDANT GENERAL MOTORS LLC’S OBJECTION TO PLAINTIFF’S NOTICE TO GENERAL MOTORS LLC’S EMPLOYEES LAURENCE BRADDELL AND MICHELLE MOCK TO APPEAR AND PRODUCE DOCUMENTS AT TRIAL