On November 30, 2021 a
Motion-Secondary
was filed
involving a dispute between
Hohl, Lakiesha,
Hohl, Louis,
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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Paul R. Johnson, No. 115817
pjohnson@kslaw. com
KING & SPALDING LLP
633 W. 5th Street, Suite 1600
Los Angeles. California 90071
+1 213 443 4355
+1 213 443 4310 (fax)
@Wflmmhwww
Troy D. McMahan, No. 148694
tmcmahan@kslaw.com
KING & SPALDING LLP
50 CaliforniaStreet, Suite 3300
San Francisco, California 941 11 FILED
+1 415 318 1200 SUPERIOR COURT OF CALIFORNIA
+1 415 318 1300 (fax) COUNTY OF SAN BERNARDINO
Mary Arens McBride, No. 282459 MAY 2 2 2023
Jonathan M. Shugart, No. 278221
ERSKINE LAW GROUP, APC
1592 N. Batavia Street, 1A
BY‘ i
Orange, CA 92867 Joédyn Drake. Deputy
+1 949 777 6032
+1 714 844 9035
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
NNNNNNH—HHHn—nu—n—oy—Afl
LOUIS HOHL, an individual, and Case No. CIVSBZI33316
LAKIESHA HOHL, an individual,
Assignedfor all purposes to the Hon. Jeffi‘ey R.
Plaintiffs, Erickson in Dept. SI4
V. DECLARATION OF TROY MCMAHAN
SUPPORTING GENERAL MOTORS LLC’S
GENERAL MOTORS, LLC, A Delaware MOTION SUMMARY JUDGMENT OR, IN
Limited Liability Company, and DOES l THE ALTERNATIVE, SUMMARY
through 10, inclusive, ADJUDICATION
Defendants. [Filed Concurrently with Notice ofMotion and
Motion; Memorandum ofPoints and Authorities;
Separate Statement of Undisputed Facts;
Declaration ofJames Oaks; and Documentary
Evidence]
Date: August 3, 2022
Time: 8:30 am
Dept: S l4
Before the Hon. Jeffrey R. Erickson
Action filed: November 30, 2021
Trial date: September 5, 2023
1
Declaration of Troy McMahan Supporting GM's motion for summary judgment etc.
I, Troy D. McMahan, declare:
1. I am an attorney with King & Spalding LLP, counsel to General Motors LLC
(“GM”), the lone defendant in this lawsuit. I am duly admitted to practice before all courts in the
\OOO-QO\m-FMNr—‘ State of California, and I have personal knowledge of the facts set forth below and, if called to
testify, could and would testify competently to them.
2. I submit this declaration in support of GM’s Motion for Summary Judgment or, in
the Alternative, Summary Adjudication, in the above—captioned matter.
3. Attached as Exhibit A is a true and correct copy of the Retail Installment Sales
Contract between Plaintiffs Louis Hohl and Lakiesha Hohl (“Buyers”) and Rock Honda (“Seller-
Creditor”) for the purchased of the used model year 201 7 Chevrolet Tahoe (the “Tahoe”), VIN
IGNSCBKCXHRI 59366, which was produced by Plaintiff in the above—captioned matter.
4. Attached as Exhibit E is a Rotolo Chevrolet repair receipt, which GM produced to
Plaintiff in discovery, showing that the Tahoe, bearing 58,329 miles, was serviced on January 14,
NNNva—nu—iv—nflp—‘t—In—au—nu—a
20 l 9.
I declare under penalty of perj ury under the laws of the State of California that the
foregoing is true and correct.
Executed on the 18th day of May 2023.
Tro .ficMahan
2
Declaration of Troy McMahan Supporting GM‘s motion for summalyjudgment etc.
Document Filed Date
May 22, 2023
Case Filing Date
November 30, 2021
Category
Breach of Contract/Warranty Unlimited
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Paul R. Johnson, No. 115817 pjohnson@kslaw. com KING & SPALDING LLP 633 W. 5th Street, Suite 1600 Los Angeles. California 90071 +1 213 443 4355 +1 213 443 4310 (fax) @Wflmmhwww Troy D. McMahan, No. 148694 tmcmahan@kslaw.com KING & SPALDING LLP 50 CaliforniaStreet, Suite 3300 San Francisco, California 941 11 FILED +1 415 318 1200 SUPERIOR COURT OF CALIFORNIA +1 415 318 1300 (fax) COUNTY OF SAN BERNARDINO Mary Arens McBride, No. 282459 MAY 2 2 2023 Jonathan M. Shugart, No. 278221 ERSKINE LAW GROUP, APC 1592 N. Batavia Street, 1A BY‘ i Orange, CA 92867 Joédyn Drake. Deputy +1 949 777 6032 +1 714 844 9035 Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO NNNNNNH—HHHn—nu—n—oy—Afl LOUIS HOHL, an individual, and Case No. CIVSBZI33316 LAKIESHA HOHL, an individual, Assignedfor all purposes to the Hon. Jeffi‘ey R. Plaintiffs, Erickson in Dept. SI4 V. DECLARATION OF TROY MCMAHAN SUPPORTING GENERAL MOTORS LLC’S GENERAL MOTORS, LLC, A Delaware MOTION SUMMARY JUDGMENT OR, IN Limited Liability Company, and DOES l THE ALTERNATIVE, SUMMARY through 10, inclusive, ADJUDICATION Defendants. [Filed Concurrently with Notice ofMotion and Motion; Memorandum ofPoints and Authorities; Separate Statement of Undisputed Facts; Declaration ofJames Oaks; and Documentary Evidence] Date: August 3, 2022 Time: 8:30 am Dept: S l4 Before the Hon. Jeffrey R. Erickson Action filed: November 30, 2021 Trial date: September 5, 2023 1 Declaration of Troy McMahan Supporting GM's motion for summary judgment etc. I, Troy D. McMahan, declare: 1. I am an attorney with King & Spalding LLP, counsel to General Motors LLC (“GM”), the lone defendant in this lawsuit. I am duly admitted to practice before all courts in the \OOO-QO\m-FMNr—‘ State of California, and I have personal knowledge of the facts set forth below and, if called to testify, could and would testify competently to them. 2. I submit this declaration in support of GM’s Motion for Summary Judgment or, in the Alternative, Summary Adjudication, in the above—captioned matter. 3. Attached as Exhibit A is a true and correct copy of the Retail Installment Sales Contract between Plaintiffs Louis Hohl and Lakiesha Hohl (“Buyers”) and Rock Honda (“Seller- Creditor”) for the purchased of the used model year 201 7 Chevrolet Tahoe (the “Tahoe”), VIN IGNSCBKCXHRI 59366, which was produced by Plaintiff in the above—captioned matter. 4. Attached as Exhibit E is a Rotolo Chevrolet repair receipt, which GM produced to Plaintiff in discovery, showing that the Tahoe, bearing 58,329 miles, was serviced on January 14, NNNva—nu—iv—nflp—‘t—In—au—nu—a 20 l 9. I declare under penalty of perj ury under the laws of the State of California that the foregoing is true and correct. Executed on the 18th day of May 2023. Tro .ficMahan 2 Declaration of Troy McMahan Supporting GM‘s motion for summalyjudgment etc.