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Paul R. Johnson, No. 115817
pjohnson@kslaw.c0m
KING & SPALDING LLP
633 W. 5th Street, Suite 1600
Los Angeles, California 90071
+1 213 443 4355
+1 213 443 4310 (fax)
Troy D. McMahan, N0. 148694
\DOOQOUI#UJNr—I
tmcmahan@kslaw.com F LED
l
KING & SPALDING LLP SUPERIOR COURT 0F CALIFORNIA
50 CaliforniaStreet, Suite 3300 COUNTY 0F SAN BERNARDINO
San Francisco, California 941 11
+1 415 318 1200 MAY 2 2 2023 flHfl
+1 415 318 1300 (fax)
Mary Arens McBride, No. 282459
Jonathan M. Shugart, No. 278221 BY‘ i
Joadyn Drake. Deputy WWMQ
ERSKINE LAW GROUP, APC
1592 N. Batavia Street, 1A
Orange, CA 92867
+1 949 777 6032
+1 714 844 9035
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT OF CALIFORNIA flaxvfi
COUNTY OF SAN BERNARDINO
LOUIS HOHL, an individual, and Case No. CIVSB21333 16
LAKIESHA HOHL, an individual,
Assignedfor all purposes t0 the Hon. Jeflrey R,
Plaintiffs, Erickson in Dept. $14
NNNNNNNNNHp—I—IHHHHHH—I
V. DECLARATION OF JAMES OAKS
OOQONUI#WNHO\OOONONM#WNHO
SUPPORTING GENERAL MOTORS LLC’S
GENERAL MOTORS, LLC, A Delaware MOTION SUMMARY JUDGMENT OR, IN
DOES
Limited Liability Company, and 1 THE ALTERNATIVE, SUMMARY
through 10, inclusive, ADJUDICATION
Defendants. [Filed Concurrently with Notice ofMotion and
Motion; Memorandum ofPoints and Authorities;
Separate Statement 0f Undisputed Facts;
Declaration 0f Troy D. McMahan; and
Documentary Evidence]
Date: August 3, 2022
Time: 8:30 am
Dept: Sl4
Before the Hon. Jeffrey R. Erickson
Action filed: November 30, 2021
Trial date: September 5, 2023
l
Declaration of James Oaks supporting GM’s motion for summary judgment etc.
DECLARATION 0F JAMES OAKS
I, James Oaks, declare as follows:
l. I have personal knowledge of the facts in this declaration supporting GM’s Motion
thN for Summary Judgement or, in the Alternative, Summary Adjudication, and, if called to testify, I
could and would competently testify t0 these facts.
2. I am the Customer Resource Manager Technical for the Western Region Customer
Care and Aftersales in Westlake Village, CA which provides customer assistance services to
OOOOQON
California residents.
3. 1 have been employed by GM for more than one year, where I regularly review
warranty information and warranty claims concerning GM vehicles. This includes Warranty
11 Booklets which contains the terms 0f GM’s New Vehicle Limited Warranty which are issued for a
12 particular vehicle. This also includes “View Vehicle Delivery Information” reports and “View
13 Vehicle Summaries” which contain information about a particular vehicle’s delivery to the
14 invoicing dealership, its warranty terms, and warranty repairs performed.
15 4. I have reviewed a copy of the Retail Installment Sales Contract between Plaintiffs
16 Louis Hohl and Lakiesha Hohl (“Buyers”) and Rock Honda (“Seller-Creditor”) for the model year
17 2017 Chevrolet Tahoe (the “Tahoe”), VIN 1GNSCBKCXHR159366, which I understand was
18 produced by Plaintiff in the above-captioned matter and is attached hereto as Exhibit A.
19 5. According t0 the contract, I understand that the Plaintiff in this lawsuit purchased a
20 Tahoe as a used vehicle With 44,268 miles 0n the odometer, from Rock Honda.
21 6. GM was not a party to the transaction between Plaintiff and Rock Honda.
22 7. Rock Honda is not a GM-authorized dealership.
23 8. GM did not issue or provide any new or additional warranty coverage concerning
24 the Tahoe at the time Plaintiff purchased the Tahoe.
25 9. Attached as Exhibit B is a true and correct copy of GM’s “View Vehicle Delivery
26 Information” report, which GM produced t0 Plaintiff.
27
28
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Declaration of James Oaks supporting GM’s motion for summary judgment etc.
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Paul R. Johnson, No. 115817 pjohnson@kslaw.c0m KING & SPALDING LLP 633 W. 5th Street, Suite 1600 Los Angeles, California 90071 +1 213 443 4355 +1 213 443 4310 (fax) Troy D. McMahan, N0. 148694 \DOOQOUI#UJNr—I tmcmahan@kslaw.com F LED l KING & SPALDING LLP SUPERIOR COURT 0F CALIFORNIA 50 CaliforniaStreet, Suite 3300 COUNTY 0F SAN BERNARDINO San Francisco, California 941 11 +1 415 318 1200 MAY 2 2 2023 flHfl +1 415 318 1300 (fax) Mary Arens McBride, No. 282459 Jonathan M. Shugart, No. 278221 BY‘ i Joadyn Drake. Deputy WWMQ ERSKINE LAW GROUP, APC 1592 N. Batavia Street, 1A Orange, CA 92867 +1 949 777 6032 +1 714 844 9035 Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT OF CALIFORNIA flaxvfi COUNTY OF SAN BERNARDINO LOUIS HOHL, an individual, and Case No. CIVSB21333 16 LAKIESHA HOHL, an individual, Assignedfor all purposes t0 the Hon. Jeflrey R, Plaintiffs, Erickson in Dept. $14 NNNNNNNNNHp—I—IHHHHHH—I V. DECLARATION OF JAMES OAKS OOQONUI#WNHO\OOONONM#WNHO SUPPORTING GENERAL MOTORS LLC’S GENERAL MOTORS, LLC, A Delaware MOTION SUMMARY JUDGMENT OR, IN DOES Limited Liability Company, and 1 THE ALTERNATIVE, SUMMARY through 10, inclusive, ADJUDICATION Defendants. [Filed Concurrently with Notice ofMotion and Motion; Memorandum ofPoints and Authorities; Separate Statement 0f Undisputed Facts; Declaration 0f Troy D. McMahan; and Documentary Evidence] Date: August 3, 2022 Time: 8:30 am Dept: Sl4 Before the Hon. Jeffrey R. Erickson Action filed: November 30, 2021 Trial date: September 5, 2023 l Declaration of James Oaks supporting GM’s motion for summary judgment etc. DECLARATION 0F JAMES OAKS I, James Oaks, declare as follows: l. I have personal knowledge of the facts in this declaration supporting GM’s Motion thN for Summary Judgement or, in the Alternative, Summary Adjudication, and, if called to testify, I could and would competently testify t0 these facts. 2. I am the Customer Resource Manager Technical for the Western Region Customer Care and Aftersales in Westlake Village, CA which provides customer assistance services to OOOOQON California residents. 3. 1 have been employed by GM for more than one year, where I regularly review warranty information and warranty claims concerning GM vehicles. This includes Warranty 11 Booklets which contains the terms 0f GM’s New Vehicle Limited Warranty which are issued for a 12 particular vehicle. This also includes “View Vehicle Delivery Information” reports and “View 13 Vehicle Summaries” which contain information about a particular vehicle’s delivery to the 14 invoicing dealership, its warranty terms, and warranty repairs performed. 15 4. I have reviewed a copy of the Retail Installment Sales Contract between Plaintiffs 16 Louis Hohl and Lakiesha Hohl (“Buyers”) and Rock Honda (“Seller-Creditor”) for the model year 17 2017 Chevrolet Tahoe (the “Tahoe”), VIN 1GNSCBKCXHR159366, which I understand was 18 produced by Plaintiff in the above-captioned matter and is attached hereto as Exhibit A. 19 5. According t0 the contract, I understand that the Plaintiff in this lawsuit purchased a 20 Tahoe as a used vehicle With 44,268 miles 0n the odometer, from Rock Honda. 21 6. GM was not a party to the transaction between Plaintiff and Rock Honda. 22 7. Rock Honda is not a GM-authorized dealership. 23 8. GM did not issue or provide any new or additional warranty coverage concerning 24 the Tahoe at the time Plaintiff purchased the Tahoe. 25 9. Attached as Exhibit B is a true and correct copy of GM’s “View Vehicle Delivery 26 Information” report, which GM produced t0 Plaintiff. 27 28 2 Declaration of James Oaks supporting GM’s motion for summary judgment etc.