Defendant Nissan to provide Plaintiff documents below in Defendant’s Possession, Custody and/or Control:

1. Warranty Policy and Procedure Manual published by Defendant and provided to authorized repair facilities, within the State of California, for the period of June 2018 to present.

2. Any internal analysis or investigation regarding defects alleged in plaintiff’s complaint in vehicles for the Same Year, Make, and Model (SYMM) as Subject Vehicle (this particular 2018 Murano leased by Plaintiff). Including Recall Notices and Technical Service Bulletins (need not search emails).

3. Customer complaints relating to same or similar defects alleged in complaint (transmission, electrical or engine) or identified in Subject Vehicle’s repair invoices, of vehicles purchased in California re SYMM.

4. All documents evidencing policies and procedures used to evaluate customer requests for repurchase pursuant to the Song-Beverly Consumer Warranty Act, for the period of 2018 to present.

5. All