Denied. A motion to compel further responses “shall set forth specific facts showing good cause justifying the discovery sought by the demand.” (CCP § 2031.310(b)(1); Kirkland v. Superior Court (Guess? Inc.) (2002) 95 Cal.App.4th 92, 98.) To establish “good cause,” the burden is on the moving party to show both relevance to the subject matter and specific facts justifying discovery. (Glenfed Develop. Corp. v. Sup. Ct. (National Union Fire Ins. Co. of Pittsburgh, Penn.) (1997) 53 Cal.App.4th 1113, 1117.) RFP nos. 37-45 seek documents relating to complaints by owners of the same year, make, model as the subject vehicle regarding issues with “harsh shifting,” the “radio,” and the “vehicle failing to start.” Plaintiff argues that information relating to complaints by other consumers involving the same types of vehicle as Plaintiffs’ vehicle containing the same defect or nonconformity is relevant to whether Defendant has committed a willful violation of the Song-Beverly Act, i.e., that ther