TENTATIVE RULING
Plaintiff Nicholas Perez's motion to compel the deposition and attendance of person(s) most knowledgeable and custodian of records for General Motors LLC ("GM") is granted, in part. GM has already agreed, and remains willing, and thus is ordered to produce a PMK on a number of the Categories for Examination 1-8, 12, and 13. Plaintiff may examine whether all documents have been produced. The deposition shall take place within 45 days, with the production of documents within 30 days.
Although GM should have filed a motion for a protective order, the parties generally enter into protective orders. Plaintiff shall enter the Los Angeles Model Stipulation and Protective Order to protect defendant's trade secrets.
GM shall produce a PMK on Categories 9-11, 14, 15, 16, 17, 18, 18 [sic], and 20. GM does not need to produce the PMK for Categories 19, 21-27.
The documents produced shall be commiserate with the Categories. However, production shall be limited to documents up
Hearing Date
January 07, 2021
Category
Civil - Unlimited
Type
Breach of Contract/Warranty
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TENTATIVE RULING
Plaintiff Nicholas Perez's motion to compel the deposition and attendance of person(s) most knowledgeable and custodian of records for General Motors LLC ("GM") is granted, in part. GM has already agreed, and remains willing, and thus is ordered to produce a PMK on a number of the Categories for Examination 1-8, 12, and 13. Plaintiff may examine whether all documents have been produced. The deposition shall take place within 45 days, with the production of documents within 30 days.
Although GM should have filed a motion for a protective order, the parties generally enter into protective orders. Plaintiff shall enter the Los Angeles Model Stipulation and Protective Order to protect defendant's trade secrets.
GM shall produce a PMK on Categories 9-11, 14, 15, 16, 17, 18, 18 [sic], and 20. GM does not need to produce the PMK for Categories 19, 21-27.
The documents produced shall be commiserate with the Categories. However, production shall be limited to documents up