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SBN 281942
Jordan G. Cohen,
Andrew SBN 342692
J. Dickson, ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
CONSUMER LAW EXPERTS, PC COUNTY OF SAN BERNARDINO
800 Park View Drive North SAN BERNARDINO DISTRICT
E1 Segundo, California 90245
3/1/2024 4:09 PM
Telephone: (3 10) 442-1410
Fax: (877) 566-8828 By: Veronica Gonzalez, DEPUTY
jordan@nolem0n. com
andrew@nolem0n. com
service@nolem0n. com
Attorney for Plaintiff, MICHAEL B. REGENNITTER and EDGAR G. MEJIA LULE
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
11
MICHAEL B. REGENNITTER, an individual, Case No_; CIVSB2303883
12 and EDGAR G. MEJIA LULE, an individual,
Case Filed: February I, 2023
13 Plaintiff,
Trial Date: TBD
14 VS.
Hon. Wilfred J. Schneider
15 AMERICAN HONDA MOTOR COMPANY, Dept. S32
INC.; and DOES through 50, inclusive,
1
16 SEPARATE STATEMENT IN
17
Defendants. SUPPORT OF PLAINTIFF’S MOTION
TO COMPEL FURTHER RESPONSES
18 TO PLAINTIFFS’ REQUEST FOR
PRODUCTION OF DOCUMENTS, SET
19 ONE
20
Date: April 24, 2024
Time: 8:30 am.
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Deptzs32
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Page 1
SEPARATE STATEMENT IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
Pursuant t0 California Rules 0f Court, Rule 3.1345, Plaintiffs MICHAEL B.
REGENNITTER and EDGAR G. MEJIA LULE (“Plaintiffs”) submit the following Separate
Statement in support 0f their Motion t0 Compel AMERICAN HONDA MOTOR CO., INC.
(“AHM”) t0 produce further responses t0 Plaintiffs’ Request for Production 0f Documents, Set
One.
REQUESTED FURTHER RESPONSES
REQUEST FOR PRODUCTION NO. 10:
A11 technical service bulletins issued by YOUI that pertain t0 transmission system
10 malfunctions in vehicles 0f the same year and model as the SUBJECT VEHICLE?
11 RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
12 AHM objects t0 this request as vague, ambiguous, overly broad, unduly burdensome, and
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as asking for information that is not relevant and not reasonably calculated t0 lead t0 the discovery
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0f admissible evidence. Moreover, as phrased, the request fails t0 describe with reasonable
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particularity the documents 0r categories 0f documents being requested in Violation 0f Code 0f
16
Civil Procedure, Section 203 1 .030(c)(1). In addition, the term "transmission system malfunctions"
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18 is not defined, described, 0r otherwise explained in this request and, without definition,
19 description, 0r explanation, is vague, ambiguous, and the information referred t0 cannot be
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determined, without speculation. AHM objects t0 the extent this request is directed t0 concerns for
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which the SUBJECT VEHICLE was presented only one time t0 an authorized Honda repair
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As used in Plaintiffs’ requests, the term “YOU”, “YOUR,” and/or “DEFENDANT”
mean AMERICAN HONDA MOTOR COMPANY, INC., including its directors, officers,
26 agents, representatives, assigns, dealerships and/or businesses that represent themselves t0 be
affiliated with, 0r work for, AMERICAN HONDA MOTOR COMPANY INC.
27 2
As used “SUBJECT VEHICLE” means the 2021 Honda
in Plaintiffs’ requests, the term
28 Pilo, Vehicle Identification Number 5FNYF5H55MBO30973, purchased by PLAINTIFF.
Page 2
SEPARATE STATEMENT IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
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SBN 281942 Jordan G. Cohen, Andrew SBN 342692 J. Dickson, ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA CONSUMER LAW EXPERTS, PC COUNTY OF SAN BERNARDINO 800 Park View Drive North SAN BERNARDINO DISTRICT E1 Segundo, California 90245 3/1/2024 4:09 PM Telephone: (3 10) 442-1410 Fax: (877) 566-8828 By: Veronica Gonzalez, DEPUTY jordan@nolem0n. com andrew@nolem0n. com service@nolem0n. com Attorney for Plaintiff, MICHAEL B. REGENNITTER and EDGAR G. MEJIA LULE SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 MICHAEL B. REGENNITTER, an individual, Case No_; CIVSB2303883 12 and EDGAR G. MEJIA LULE, an individual, Case Filed: February I, 2023 13 Plaintiff, Trial Date: TBD 14 VS. Hon. Wilfred J. Schneider 15 AMERICAN HONDA MOTOR COMPANY, Dept. S32 INC.; and DOES through 50, inclusive, 1 16 SEPARATE STATEMENT IN 17 Defendants. SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES 18 TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET 19 ONE 20 Date: April 24, 2024 Time: 8:30 am. 21 Deptzs32 22 23 24 25 26 27 28 Page 1 SEPARATE STATEMENT IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL Pursuant t0 California Rules 0f Court, Rule 3.1345, Plaintiffs MICHAEL B. REGENNITTER and EDGAR G. MEJIA LULE (“Plaintiffs”) submit the following Separate Statement in support 0f their Motion t0 Compel AMERICAN HONDA MOTOR CO., INC. (“AHM”) t0 produce further responses t0 Plaintiffs’ Request for Production 0f Documents, Set One. REQUESTED FURTHER RESPONSES REQUEST FOR PRODUCTION NO. 10: A11 technical service bulletins issued by YOUI that pertain t0 transmission system 10 malfunctions in vehicles 0f the same year and model as the SUBJECT VEHICLE? 11 RESPONSE TO REQUEST FOR PRODUCTION NO. 10: 12 AHM objects t0 this request as vague, ambiguous, overly broad, unduly burdensome, and 13 as asking for information that is not relevant and not reasonably calculated t0 lead t0 the discovery 14 0f admissible evidence. Moreover, as phrased, the request fails t0 describe with reasonable 15 particularity the documents 0r categories 0f documents being requested in Violation 0f Code 0f 16 Civil Procedure, Section 203 1 .030(c)(1). In addition, the term "transmission system malfunctions" 17 18 is not defined, described, 0r otherwise explained in this request and, without definition, 19 description, 0r explanation, is vague, ambiguous, and the information referred t0 cannot be 20 determined, without speculation. AHM objects t0 the extent this request is directed t0 concerns for 21 which the SUBJECT VEHICLE was presented only one time t0 an authorized Honda repair 22 23 24 25 1 As used in Plaintiffs’ requests, the term “YOU”, “YOUR,” and/or “DEFENDANT” mean AMERICAN HONDA MOTOR COMPANY, INC., including its directors, officers, 26 agents, representatives, assigns, dealerships and/or businesses that represent themselves t0 be affiliated with, 0r work for, AMERICAN HONDA MOTOR COMPANY INC. 27 2 As used “SUBJECT VEHICLE” means the 2021 Honda in Plaintiffs’ requests, the term 28 Pilo, Vehicle Identification Number 5FNYF5H55MBO30973, purchased by PLAINTIFF. Page 2 SEPARATE STATEMENT IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL