Plaintiff Andrew Alamillo moves to compel production of documents sought pursuant to a subpoena for business records.

This is an action for strict products liability and negligence. The product at issue is a “Ford 903 series, Model 22-63 post hole digger.”

The subject subpoena was served upon CNH Industrial America, the custodian of records for Defendant Ford Motor Company, on December 15, 2015. Timely objections were served on January 20, 2016.

This motion concerns the objections to Requests 2, 3, 9, 15, 50, 22, and 24. Generally, these requests concern documents pertaining to the Ford Series 905 post hold digger. Among other objections, Defendant contends that the 905 is a different series and therefore irrelevant to this case.

Plaintiff is correct that subsequent remedial measures are often admissible in products liability cases. (Ault v. Int’l Harvester Co. (1974) 13 Cal. 3d 113, 118) Plaintiff argues that the 903 series only had a drive shaft shield on three sides and the