The Motions by Plaintiff John Baker to Compel Further Responses to (1) Form Interrogatories, (2) Special Interrogatories and (3) Request for Production are GRANTED.
Within twenty (20) days, Defendant General Motors, LLC shall respond without objection to Form Interrogatories: Nos. 1.1, 12.1, 15.1 & 17.1, Special Interrogatories: Nos. 1, 14, 46 & 52-57 and Request for Production: Nos. 1, 3, 9, 37-48, 51, 54 & 55.
No. 1.1: Identify preparer of responses: Granted. Defendant failed to respond. The response was evasive and incomplete. Code Civ. Proc., § 2030.220 (a) provides that “Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.” No. 12.1: Witnesses: Granted. Defendant contended that the term “incident” was vague and ambiguous. The term “incident” is defined. Defendant is required to identify percipient witnesses. Code Civ. Proc., § 2030.220.
No. 15.1: Support for Contentions: Grant