Plaintiff Erik Negroe’s motion to compel Defendant FCA US LLC’s person most knowledgeable to appear and testify at deposition is GRANTED.

Plaintiff Erik Negroe moves to compel Defendant FCA US LLC’s (“Defendant”) person most knowledgeable (“PMK”) to appear and testify at deposition pursuant to Code of Civil Procedure section 2025.450:

If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed with it, or to produce for inspection any document or tangible thing described in the deposition notice, the party giving the notice may move for an order compelling the deponent's attendance and testimony, and the production for inspection of any document or tangible thing described in the deposition noti........