Douglas and Georgia Spelts (Plaintiffs) purchased a new 2014 Jeep Cherokee (Jeep) from Cole Chrysler in San Luis Obispo. Plaintiffs bring this lemon law action against FCA US LLC (Defendant) on the grounds the Jeep was defective. The complaint includes one cause of action for violation of the Song-Beverly Consumer Warranty Act.

Plaintiffs now bring a motion to compel the deposition of Defendant’s person most knowledgeable (PMK) on topics related to the lemon law claim. Plaintiffs contend that for the past six months they have tried to gain Defendant’s cooperation in scheduling the deposition. Plaintiffs represent that the Defendant has failed to respond to multiple inquires and is unreasonably objecting to producing its PMK for deposition.

In response, Defendant assert it has never been opposed to the deposition, but explains that this case is one of more than 400 lemon law cases that Plaintiffs’ counsel is prosecuting against Defendant. Defendant states that its PMK, Michael McDow