Plaintiff Larry Neuberg’s Motion to Compel Further Responses to Requests for Production from Defendant FCA US, LLC is GRANTED as to Request No. 76, and DENIED as to all other requests. No sanctions are awarded.

Plaintiff to give notice.

OBJECTIONS

Neuberg’s objections to the Tsai declaration are OVERRULED, as he authenticates the documents presented as either being produced by Neuberg in this litigation or part of the correspondence of the parties in this case.

MOTION TO COMPEL FURTHER – PRODUCTION OF DOCUMENTS

“A party may demand that any other party produce . . . a document that is in the possession, custody, or control of the party on whom the demand is made.” (Code Civ. Proc., § 2031.010(b).) The demanding party may move for an order compelling further response to the demand if the demanding party deems that (1) a statement of compliance with the demand is incomplete, (2) a representation of inability to comply is inadequate, incomplete, or evasive, or (3) an objection in the