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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
WILSON TURNER KOSMO LLP COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
ELIZABETH C. REIN (297593)
OLIVIA J. MINER (306546) 11/1 5/2023 8:37 AM
ANDRES F. MICHEL (292626) _
402 West Broadway, Suite 1600 By= Leslle Zepedaa DEPUTY
San Diego, California 92101
Telephone: (619) 236-9600
Facsimile: (619) 236-9669
E-mail: erein@wilsonturnerkosmo.com
E-mail: ominer@wilsonturnerkosmo.com
E-mail: amichel@wilsonturnerkosmo.com
E-mail: hondaeservice@wilsontumerkosmo.com
Attorneys for Defendant
AMERICAN HONDA MOTOR CO., INC
(erroneously sued herein as a California
Corporation)
10
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF SAN BERNARDINO
13
14 RHONDA MCDOWELL, an individual, Case N0. CIVSB221 1661
15 Plaintiffs, SEPARATE STATEMENT IN
SUPPORT OF DEFENDANT
16 V. AMERICAN HONDA MOTOR CO.,
INC.’S MOTION TO COMPEL
17 AMERICAN HONDA MOTOR CO., INC, a FURTHER RESPONSES TO
California Corporation, and DOES through 10,
1 FURTHER RESPONSES TO
18 inclusive, REQUEST FOR PRODUCTION OF
DOCUMENTS AND FOR SANCTIONS
19 Defendants.
Complaint Filed: June 9, 2022
20
Date: January 29, 2024
21 Time: 8:30 am.
Dept: S30
22 Judge: Hon. Brian S McCarville
Trial Date: Not set
23
24
Pursuant t0 California Rule 0f Court 3.1345(c), Defendant AMERICAN HONDA MOTOR
25
CO., INC. (“AHM”) hereby submits its separate statement in support 0f AHM’S Motion t0 Compel
26
to Plaintiff RHONDA MCDOWELL Responses t0 Request for Production 0f Documents, Set One:
27
28
1
SEPARATE STATEMENT IN SUPPORT OF DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S MOTION
TO COMPEL FURTHER RESPONSES TO FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF
DOCUMENTS AND FOR SANCTIONS
REQUEST FOR PRODUCTION NO. 1:
Any and all DOCUMENTS Which concern, 0r relate t0 in any way, the purchase and
ownership of the VEHICLE.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
"Plaintiff objects t0 this Request on the grounds that it is vague, ambiguous, and compound.
Plaintiff objects to this Request to the extent that it is overly broad Plaintiff objects to this Request
on the grounds that it calls for a legal conclusion. Plaintiff obj ects to this Request to the extent that it
seeks information protected from disclosure by any privilege 0r immunity including, Without
limitation, the attorney-client privilege, 0r the work product immunity from discovery. Plaintiff
10 objects to this Request on the grounds that it seeks premature disclosure of expert witness opinion in
11 Violation 0f Code of Civil Procedure, section 2034.210. Plaintiff also objects to this Request as it
12 seeks the legal reasoning and theories 0f Plaintiff’s contention. Plaintiffs are not required t0 prepare
13 the defendant's case (Sav-On Drugs, Inc. v. Superior Court, 15 Cal.3d 1, at p. 5 (1975).) Further, a
14 party is not obligated t0 perform legal research for another party. (Id.) Finally, Plaintiff objects
15 because this Request is not full and complete in and 0f itself, contains sub-parts, and/or contains a
16 conjunctive or disjunctive question and therefore does not comply With Code of Civil Procedure,
17 section 2030.060 et seq.
18 However, without waiving the forgoing objections, Plaintiff responds as follows: Plaintiff
19 Will comply With this request t0 the extent responsive, non-priVileged documents are in Plaintiff’s
20 possession, custody and control by producing Plaintiff’s Retail Installment Sale Contract dated July
21 11, 2020, attached hereto as Exhibit “A,” and Plaintiff’s registration card, attached hereto as Exhibit
22 “C”
23 Discovery is still ongoing, and Plaintiff reserves the right to supplement or amend this
24 response should additional information become available.
25 STATEMENT OF INSUFFICIENCY:
26 Plaintiff asserts boilerplate objections which lack specificity and should be disregarded. (See
27 Korea Data, supra, 51 Cal.App.4th 1513 [boilerplate objections lack the required specificity and
28 may be sanctionable]; see also Burlington Northelén & Santa Fe Ry. C0. v. U.S. Dist. Courtfor Dist.
SEPARATE STATEMENT IN SUPPORT OF DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S MOTION
TO COMPEL FURTHER RESPONSES TO FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF
DOCUMENTS AND FOR SANCTIONS
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA WILSON TURNER KOSMO LLP COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT ELIZABETH C. REIN (297593) OLIVIA J. MINER (306546) 11/1 5/2023 8:37 AM ANDRES F. MICHEL (292626) _ 402 West Broadway, Suite 1600 By= Leslle Zepedaa DEPUTY San Diego, California 92101 Telephone: (619) 236-9600 Facsimile: (619) 236-9669 E-mail: erein@wilsonturnerkosmo.com E-mail: ominer@wilsonturnerkosmo.com E-mail: amichel@wilsonturnerkosmo.com E-mail: hondaeservice@wilsontumerkosmo.com Attorneys for Defendant AMERICAN HONDA MOTOR CO., INC (erroneously sued herein as a California Corporation) 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN BERNARDINO 13 14 RHONDA MCDOWELL, an individual, Case N0. CIVSB221 1661 15 Plaintiffs, SEPARATE STATEMENT IN SUPPORT OF DEFENDANT 16 V. AMERICAN HONDA MOTOR CO., INC.’S MOTION TO COMPEL 17 AMERICAN HONDA MOTOR CO., INC, a FURTHER RESPONSES TO California Corporation, and DOES through 10, 1 FURTHER RESPONSES TO 18 inclusive, REQUEST FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS 19 Defendants. Complaint Filed: June 9, 2022 20 Date: January 29, 2024 21 Time: 8:30 am. Dept: S30 22 Judge: Hon. Brian S McCarville Trial Date: Not set 23 24 Pursuant t0 California Rule 0f Court 3.1345(c), Defendant AMERICAN HONDA MOTOR 25 CO., INC. (“AHM”) hereby submits its separate statement in support 0f AHM’S Motion t0 Compel 26 to Plaintiff RHONDA MCDOWELL Responses t0 Request for Production 0f Documents, Set One: 27 28 1 SEPARATE STATEMENT IN SUPPORT OF DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S MOTION TO COMPEL FURTHER RESPONSES TO FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS REQUEST FOR PRODUCTION NO. 1: Any and all DOCUMENTS Which concern, 0r relate t0 in any way, the purchase and ownership of the VEHICLE. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: "Plaintiff objects t0 this Request on the grounds that it is vague, ambiguous, and compound. Plaintiff objects to this Request to the extent that it is overly broad Plaintiff objects to this Request on the grounds that it calls for a legal conclusion. Plaintiff obj ects to this Request to the extent that it seeks information protected from disclosure by any privilege 0r immunity including, Without limitation, the attorney-client privilege, 0r the work product immunity from discovery. Plaintiff 10 objects to this Request on the grounds that it seeks premature disclosure of expert witness opinion in 11 Violation 0f Code of Civil Procedure, section 2034.210. Plaintiff also objects to this Request as it 12 seeks the legal reasoning and theories 0f Plaintiff’s contention. Plaintiffs are not required t0 prepare 13 the defendant's case (Sav-On Drugs, Inc. v. Superior Court, 15 Cal.3d 1, at p. 5 (1975).) Further, a 14 party is not obligated t0 perform legal research for another party. (Id.) Finally, Plaintiff objects 15 because this Request is not full and complete in and 0f itself, contains sub-parts, and/or contains a 16 conjunctive or disjunctive question and therefore does not comply With Code of Civil Procedure, 17 section 2030.060 et seq. 18 However, without waiving the forgoing objections, Plaintiff responds as follows: Plaintiff 19 Will comply With this request t0 the extent responsive, non-priVileged documents are in Plaintiff’s 20 possession, custody and control by producing Plaintiff’s Retail Installment Sale Contract dated July 21 11, 2020, attached hereto as Exhibit “A,” and Plaintiff’s registration card, attached hereto as Exhibit 22 “C” 23 Discovery is still ongoing, and Plaintiff reserves the right to supplement or amend this 24 response should additional information become available. 25 STATEMENT OF INSUFFICIENCY: 26 Plaintiff asserts boilerplate objections which lack specificity and should be disregarded. (See 27 Korea Data, supra, 51 Cal.App.4th 1513 [boilerplate objections lack the required specificity and 28 may be sanctionable]; see also Burlington Northelén & Santa Fe Ry. C0. v. U.S. Dist. Courtfor Dist. SEPARATE STATEMENT IN SUPPORT OF DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S MOTION TO COMPEL FURTHER RESPONSES TO FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS