GRAVES VS. GENERAL MOTORS, LLC
Case Number: 24CV-0203994
Tentative Ruling on Motion to Compel Deposition of General Motors, LLC’s Person(s) Most Qualified
with Production of Documents: Plaintiff Jessica Graves (“Plaintiff”) moves to compel Defendant General
Motors, LLC (“Defendant” or “GM”) to produce a Person Most Qualified (“PMQ”) in various categories along
with document production at a deposition.
Meet and Confer. A motion brought under this section must include a declaration describing efforts to meet and
confer in good faith. Plaintiff has provided evidence that Plaintiff attempted multiple times to meet and confer to
resolve the issues. GM was largely nonresponsive. The Court finds that Plaintiff has made sufficient efforts to
meet and confer.
Plaintiff’s Evidentiary Objections. Plaintiff makes four objections to the Declaration of Cameron Major filed in
support of GM’s Opposition. Each of these objections is overruled.
Merits. The scope of discovery is broad. Any matter that is