OppositionOppositionCal. Super. - 4th Dist.July 13, 2018SS OO 0 9 O Y Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Barry R. Schirm (SBN 94553) Ryan K. Marden (SBN 217709) Nina Moreno (SBN 312748) HAWKINS PARNELL & YOUNG LLP 445 South Figueroa Street, Suite 3200 Los Angeles, California 90071 Telephone: (213) 486-8000 Facsimile: (213) 486-8080 Email: pmontoya@hpylaw.com Ca fe S pen irC o By Ck D ep t Cl ELE CTR ONI CAL LY FLED par r Cout o Cal f, Cour y o f Or ing W S s Attorneys for Defendants FCA US LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE-CENTRAL JUSTICE CENTER RENEE GASTELUM, an individual Case No.: 30-2018-01005280-CU-BC-CJC Plaintiff, DEFENDANT FCA US LLC’S Vs. MEMORANDUM OF POINTS AND FCA US LLC, a Delaware Limited Liability AUTHORITIES IN OPPOSITION TO Company; and DOES 1 through 20, inclusive PLAINTIFF’S MOTION TO COMPEL ’ ’ ’ FURTHER RESPONSE TO SPECIAL Defendants. INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 Hearing Date: March 15, 2019 Hearing Time: 10:00 a.m. Department: C21 Reservation ID: 72978097 111 I 111 111 [1] I DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 10 11 12 13 14 13 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant, FCA US LLC (“FCA US”), opposes Plaintiff’s Motion to Compel Further Response to Special Interrogatories; Request for Monetary Sanctions of $2,672.50 as follows: L INTRODUCTION and FACTS CONCERNING DISCOVERY and THE MEET- AND-CONFER PROCESS Plaintiff is demanding a Song-Beverly buy-back of her 2017 Jeep Grand Cherokee ( VIN# 1CARIJEAG9HC674946) because of alleged check engine light, powertrain control mo dule, radio, back-up camera, noise and transmission “defects”. (Plaintiff's Complaint, Paragraph 10-11). The present motion was filed on February 1, 2019 after Plaintiffs counsel cut-short the meet- and- confer process where only one letter had been sent by each party. (See Plaintiff’s Dec. Exh. 6, Plaintiff's letter dated November 8, 2018; and Exh. 7, Defendant’s letter dated November 16, 2018). In FCA US’s meet and confer letter, Defendant offered substantial compromises concerning its principled positions on written discovery that were unreasonably disco unted by Plaintiff's counsel when he abandoned the compromise process. This contradicts the sp irit of the meet-and-confer requirement. Plaintiff also spurned the specific offer by Defendant to f urther discuss discovery issues that still existed: In an effort to avoid judicial intervention, FCA US will provide further responses and a supplemental production for those Requests it has agreed to amend above. As always, I am available to discuss any concerns you may have via email or telephone, and otherwise look forward to your anticipated response. To the extent you require any extension, FCA US is willing to discuss same. (Emphasis added). Unfortunately, instead of a receiving a letter to continue the meet-and-confer process, defendant was met with four motions to compel seeking several thousand dollars in sanct ions. Faced with this challenge, and the fact that the proposed protective order has not yet been entered, defendant held-off on officially supplementing its responses, but remained willing to sta nd by the compromises it proposed in its letter of November 16, 2018. Plaintiff has also failed to respond to a repurchase offer that was made to him on or about January 14, 2019. Based on this, Defendant is convinced that a main purpose of these motions is not to DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 BN N O Dn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 facilitate or foster more perfect discovery for the plaintiff but to increase the costs and fees to all. At issue in this motion are only 15 of the 57 Special Interrogatory responses of de fendant, specifically, numbers 1, 14, 31-36, 40, 42, 43, 45, 46, 56 and 57. In essenc e, in these questions, plaintiff asked defendant the following: 1. Identify the person(s) who provided answers these Special Interrogatories; 14. Identify the person(s) who performed warranty repairs; 31. Do YOU contend that Defendants have complied with their warranty obligations set forth in the Song-Beverly Warranty Act?; 39. Do YOU contend that Defendants were able to repair all the NONCONFORMITY in the SUBJECT VEHICLE to conform to the applicable express warranties? 33. If the answer to Interrogatory No. 32 is yes, IDENTIFY all DOCUMENTS that support YOUR contention; 34. Do YOU contend that Defendants were not given a reasonable number of attempts to repair the NONCONFORMITY in the SUBJECT VEHICLE; 35. If the answer to Interrogatory No. 34 is yes, state all the facts that support your contention; 36. If the answer to Interrogatory No. 34 is yes, identify all documents that support your contention; 40. Identify the individual(s) whose responsibility it is to supervise to ensure that YOU are properly determining whether a vehicle should be repurchased or replaced pursuant to The Song-Beverly Warranty Act; 42. Explain with particularity all aspects of YOUR investigation into whether the SUBJECT VEHICLE qualified or was eligible for repurchase or replacement pursuant to The Song-Beverly Warranty Ac;. 43. Identify all person(s) involved in YOUR investigation, including any individuals with whom YOU conpmunicated regarding the SUBJECT DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 NN w No \O co | aN Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VEHICLE; 45. Identify all individuals responsible for YOUR decision to not repurchase or replace the SUBJECT VEHICLE; 46. How many repair attempts do you believe you had to fix the vehicle under the warranty?; 56. Please explain in detail the process by which a Technical Service Bulletin is recalled or superseded; and, 57. State the total number of days the vehicle was out of service for warranty repairs. Defendant responded to these inquiries and also objected. Plaintiff’s counsel requested further responses to each of them in his meet and confer letter of November 8, 2018 and Defendant replied substantively concerning each one. In many cases, Defendant agreed to supplement its responses but it always expressed its basis for its original response. Defendant will address each of these fifteen “at-issue” Special Interrogatories in its Separate Statement, but FCA US’s responses in its meet and confer letter, in pertinent part, are quoted below: Special Interrogatory No. 1 FCA US stands by its response and objections to this interrogatory. However, in the spirit of cooperation, FCA US further refers Plaintiff to the verification associated with its responses. Special Interrogatory Nos. 2-14, 17, 20 FCA US understands these interrogatories as primarily seeking a summary of documents previously produced to Plaintiff. As such, it is proper to refer Plaintiff to the produced documents responsive to the propounded interrogatory pursuant to Code of Civil Procedure section 2030.230. Contrary to Plaintiff's assertions, FCA US referred to the proper code section and identified the documents from which the answer may be ascertained. ook ok kook =H DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 Special Interrogatory Nos. 31-36, 48-50 The above interrogatories require the presumption or affirmation that the subject vehicle experienced a “nonconformity.” It is FCA US’s position that it did not, and as such, its responses and objections do not require supplementation. kk ok kk Special Interrogatory Nos. 40-42, 43-43 Plaintiffs meet and confer letter fails to explain how FCA US’s responses to the above interrogatories are “deficient.” However, in a showing of oood faith, FCA US will agree to produce, subject to a reasonable protective order. a copy of the policies and procedures of its call center regarding customers’ requests for refund or replacement of their vehicle, organizational charts. as well as the portion of the dealer policy manual that relates to state lemon laws. Special Interrogatory No. 46 FCA US fails to see how its responses to the above requests are deficient. FCA US’s definitions of what it believes is a reasonable amount of repair attempts is irrelevant to this matter. At issue is whether Plaintiff’s vehicle suffered a non-conformity and whether it had a reasonable opportunity to make the repairs under the Song-Beverly Act, which is a determination for the jury. Special Interrogatory Nos. 51-56 FCA US has already produced an index of all TSBs and recalls that may be applicable to the subject vehicle and asked Plaintiff to identify those TSBs and recalls you reasonably believe may be at issue. Your letter still does not identify any additional TSBs or recalls that you believe are applicable and merely seeks to have FCA US conduct your investigation for you. FCA US again invites Plaintiff to identify those TSBs and Recalls you reasonably believe are at issue at FCA US will resppnd and produce accordingly. DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF*S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 OO 0 3 DN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Special Interrogatory No. S57 Upon further review, FCA US will amend its response to refer Plaintiff to the previously produced vehicle repair records, pursuant to Code Section 2030.230. Plaintiff sent no follow-up meet-and-confer letter after the receipt of Defendant’s response letter of November 16, 2018, despite being invited to respond. Plaintiff should not seek court relief without reasonably following the meet-and-confer rules. In discovery, Defendant has been professional, fair and reasonable. Plaintiff is the party who abandoned the production meet-and- confer process and has ignored a reasonable offer to settle the case. The Court should also be reminded that forcing a party to provide “perfect answers” to these 15 Special Interrogatories is not critical in the least. Huge numbers of questions have been answered to the satisfaction of plaintiff. And many documents have been produced as well. For example, FCA US has already produced in its original responses to Request for Production: (1) a copy of the warranty claim records for the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGIHC674946; (2) a copy of any dealer repair records, for the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGIHC674946 obtained from any authorized repair facility; (3) a booklet containing written limited warranties accompanied the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGIHC674946; (4) a copy of available Customer Assistance Inquiry Records (CAIRs) containing communications with Plaintiff relating to the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGIHC674946 (5) an index of Technical Service Bulletins (TSB), recalls, and Customer Satisfaction Notifications that may be applicable to thg 2017 Jeep Grand Cherokee, VIN DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 HH OC 0 ~~ O N Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1C4ARJEAGIHC674946; (6) a copy of any communications with any authorized dealership concerning service to the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGIHC674946; and (7) a copy of the Vehicle Information Detail Report for the 2017 Jeep Grand Cherokee, VIN 1C4RJEAGOHC674946. (See original Response to Plaintiff's Request For Production, set One, Responses to Requests 1-9 and others). Together with the 57 Special Interrogatories, Defendant has also answered 22 total Form Interrogatories, 44 Requests for Admission and 54 Requests for Production. The above is hardly evidence of defendant “abusing the discovery process” as plaintiff rashly and simplistically states. Defendant contends that Plaintiff prematurely abandoned the amicable back-and-forth of the meet-and-confer process, not defendant. Thus, under the actual circumstances and status of discovery in this case, Plaintiff’s Motion is perplexingly aggressive. The remaining points of law and fact are therefore included because plaintiff has impetuously filed this motion. In the instant matter, Defendant timely responded to Plaintiff's voluminous discovery requests and later FCA US timely responded to Plaintiff’s meet and confer letter. The information or evidence that is truly material in a Song-Beverly Warranty case is (1) what problem (non-conformity) plaintiff experienced with the subject vehicle itself, (2) how often, (3) whether it was effectively repaired, (4) the length of time out of service during the repair process and (5) whether the alleged non-conformity substantially impaired the safety and/or value of the vehicle. In addition, Defendant stresses that the burden and expense of the proposed discovery outweigh the likely benefit considering the actual needs of the case and the importance of the issues at stake. (Id.) Further, the parties appear to have been making strides towards an amicable buy-back, so the entire process of discovery could have been deferred. FCA US has already produced Warranty Repair Records, Dealer Repair Records, Vehicle Information Detail Report, the Index of Technical Service Bulletins and communications between it and the consumer and it and the authorized sergicer. Plaintiff has ample FCA US and DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 ND ~N O n A W 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 dealership information to determine likely witnesses and if its case is viable. Therefore, the entirety of this motion is arguably excessive and premature. IL. LAW & ARGUMENT A. Plaintiffs Prematurely Filed this Motion when the Meet and Confer Process had been Working. Code of Civil Procedure § 2030.300 requires that prior to filing a motion to compel the moving party must follow the meet and confer requirements of § 2016.040. “The Discovery Act requires that, prior to the initiation of a motion to compel, the moving party declare that he or she has made a serious attempt to obtain an informal resolution of each issue.” Townsend v. Superior Court (1998) 61 Cal. App. 4th 1431 at 1435, 72 Cal.Rptr.2d 333. This means that the parties must attempt to talk the matter over, compare their views, consult, and deliberate. Clement v. Alegre (2009) 177 Cal. App. 4™ 1277, 1294. The purpose of the meet and confer requirement is to bridge the gap between the parties — to force lawyers to reexamine their positions, and to narrow their discovery disputes to the irreducible minimum, before calling upon the court to resolve the matter. Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal. App. 4" 1006, 1016. Although Defendant legitimately answered and objected to the discovery in question, it has agreed to amend its answers and has also agreed to produce many specifically relevant documents. Defendant also offered to continue the meet-and-confer process. FCA US has actively worked to informally resolve these alleged disputes and avoid burdening this court with yet another unnecessary and premature motion. Plaintiff cut short those efforts. Thus, based upon the facts recited above and the additional arguments below and in the Separate Statement, FCA US requests that this Court deny Plaintiff's Motion to Compel in its entirety. B. The Motion Fails to Show Good Cause. A motion to compel further responses must “set forth specific facts showing good cause justifying the discovery...” (Code of Civil Procedure section 2031.310(b)(1); Kirkland v Superior Court (2002) 95 Cal. App. 4M 92, 98) This requires showing specific facts to justify the discovery, or, why such information is required for trial preparation. (Glenfed Development Corporation v. Superior Court (1997) 53 Cal. App. 4M 1113, 1117; Kirkland, page 98) In order to DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 meet the burden, the moving party must show: (1) relevance to the subject matter (e.g., how the information would tend to prove or disprove some issue in the case); and (2) specific facts justifying the discovery (e.g., why such information is necessary for trial preparation). Civ. Proc . Before Trial, 9 8:1495.6 (The Rutter Group 2014); Kirkland v. Superior Court (2002) 95 Cal. App.4th 92, 98; Glenfed Develop. Corp. v. Sup. Ct. (1997) 53 Cal.App.4th 1113, 1117. Plaintiff's motion does neither. Plaintiff's Motion makes no mention of good cause or the relevant statutory provision. Declarations are generally used to show the requisite “good cause” for an order to compel inspection. The declarations must contain “specific facts” rather than mere conclusions. Civ. Pro . Before Trial 9 8:1495.7. The reason for the greater showing is that demands for inspection of documents involve a greater intrusion on privacy than merely answering questions. Id. § 8:1495 . Additionally, once the moving party meets the burden of showing good cause, the burden shi fts to the opposing party to justify any objections. Kirkland v Superior Court, 95 Cal. App. 4th 92, 9 8 (2002). The failure to set forth good cause requires that the motion be denied. The Court also has the power to limit discovery if it determines that the discovery sought is unduly burdensome or expensive, taking into account the needs of the case and the amount in controversy. (See Code Civ. Proc., § 2017.010, 2017.020, 2019.030, 2031.060; see also Pr att v. Union Pacific R. Co. (2008) 168 Cal. App.4th 165, 181 [85 Cal.Rptr.3d 321], as modified (Nov . 19, 2008).) LC. Plaintiff's Special Interrogatories. A party is required to use the discovery tools permitted to him by statute in order to facilitate its claims or defenses, rather than bludgeon its opponent into submission through onerous discovery requests. See Calcor Space Facility, Inc. v. Superior Court, 53 Cal. App. 4t h 216, 221 (1997) (“Courts must insist discovery devices be used as tools to facilitate litigatio n rather than as weapons to wage litigation. These tools should be well calibrated; the lancet is to b e preferred over the sledge hammer.”) As is with the discovery served by Plaintiff generally, Plaintiff chose the sledgehammer. /11 _8- DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 5 Ov 0 NN O y Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff also overlooks that Defendant cooperated in the meet-and-confer process and agreed to supplement its responses to Special Interrogatories, as well as the Requests for Production and Requests for Admission, once the proposed protective order has been agreed-to and entered. To the extent the interrogatories, though flawed, seek any relevant information, that information is contained within the documents FCA US has for the most part already produced, or has a willingness to produce, subject to a protective order. D. Plaintiff’s Request for Sanctions is Not Warranted. The California Code of Civil Procedure provides that the Court has discretion not to impose sanctions where it finds “substantial justification or that other circumstances make the imposition of the sanction unjust.” Code Civ. Proc., § 2025.420,(h). The phrase “substantial justification” has been understood to mean reasonable grounds to believe that the objection was valid when made and that opposition to the discovery therefore was justified. See Foothill Properties v. Lyon/Copley Corona Associates (1996) 46 Cal. App.4th 1542, 1557-1558 [54 Cal.Rptr.2d 488]; Doe v. U.S. Swimming, Inc. (2011) 200 Cal. App.4th 1424, 1434 [133 Cal .Rptr.3d 465]. Certainly sanctions are not warranted in this case as FCA US has been seeking to settle this matter and still provided timely provided code compliant responses to Plaintiffs discovery, and timely responded to Plaintiff's meet-and-confer letter and compromised on many individual items. As explained in Sinaiko Healthcare Consulting, Inc. v. Pac. Healthcare Consultants, 148 Cal. App. 4th 390, 408, 55 Cal. Rptr. 3d 751, 763 (2007): [Where a | party does serve a timely response—even if that response is deficient in some respect—then the responding party has the procedural protections afforded by section 2030.300. Under that section, the burden is on the propounding party to demonstrate that the response is inadequate or improper, and that the propounding party made a good faith attempt to “meet and confer.” In addition, the propounding party has only 45 days to seek relief. -9. DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 $a ~N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Here, Plaintiff failed to make good faith attempts to continue to meet and confer and has not demonstrated that FCA US’s initial answers or amended responses are inadequate or improper. For these reasons, there is no simply no justification for sanctions in this case. III. CONCLUSION FCA US’s original answers were compliant under Code of Civil Procedure § 2031.210 et seq. Beyond that, Plaintiff abandoned the meet and confer process too soon and while it was working. Plaintiff prematurely filed this motion and then ignored defendant’s supplemental responses to both types of Interrogatories. Discovery has not been hidden from this plaintiff. Therefore, Plaintiff's motion to compel should be denied in its entirety. Dated: March 4, 2019 HAWKINS PARNELL & YOUNG LLP 4 By: ’ Barry R. Schirm Ryan K. Marden Nina Moreno Attorneys for Defendant FCAUSLLC -10 - DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 c o NN O N n b \O 10 11 12 13 14 15 16 17 18 19 20 21 29 23 24 25 26 27 28 [] Renee Gastelumv. FCA US LLC, et al. Orange County Superior Court Case No.: 30-2018-01005280-CU-BC-CJC PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I declare that I am employed by Hawkins Parnell & Young LLP. I am over the age of eighteen years and not a party to the within cause; my business address is 445 South Figueroa Street, Suite 3200, Los Angeles, California 90071-1651. On the date set forth below, I served the foregoing document(s) described as: DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 On the parties in said cause: David N. Barry, Esq. Phone: (310) 684-5859 THE BARRY LAW FIRM Fax: (310) 862-4539 11845 W. Olympic Blvd, Suite 1270 [Los Angeles, CA 90064 Attorneys for Plaintiff Renee Gastelum, an individual BY MAIL: by enclosing a true copy thereof in a sealed envelope and, following ordinary business practices, said envelope, with postage pre-paid, was placed for mailing and collection (in the offices of Hawkins Parnell & Young LLP) in the appropriate place for mail collected for deposit with the United States Postal Service. I am readily familiar with the Firm’s practice for collection and processing of correspondence/documents for mailing with the United States Postal Service and that said correspondence/documents are deposited with the United States Postal Service in the ordinary course of business on the same day. VIA OVERNIGHT MAIL: by enclosing a true and correct copy thereof in a sealed envelope(s), addressed as above, and causing each envelope(s) to be delivered on the next day by courier service following ordinary business practices. BY PERSONAL SERVICE: by enclosing a true and correct copy thereof in a sealed envelope(s), addressed as above, and causing each envelope(s) to be hand-served on this day by courier service following ordinary business practices. BY FACSIMILE: by facsimile to the facsimile number(s) of the offices of the addressee(s) as indicated on the attached list. -11 - DEFENDANT FCA US LLC'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50 co NN O N wn ba Oo 10 11 12 13 14 15 16 17 18 19 20 21 95 23 24 25 26 27 28 I declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on March 4, 2019, at Los Angeles, CA. [ | $1 ee ure Yvonne be Print Name -12- DEFENDANT FCA US LLC’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFE’S MOTION TO COMPEL FURTHER RESPONSE TO SPECIAL INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS OF $2,672.50
