2017-00215812-CU-BC

Jayson Miranda vs. General Motors, LLC

Nature of Proceeding: Motion to Compel Production of Documements

Filed By: Oliva, Vanessa J.

On motion of the court, this matter is continued to 2/16/18 at 09:00AM in this department. If the new date is inconvenient, then counsel shall meet and confer and inform the Department 54 Clerk of their request for a subsequent date.

Having reviewed the moving and opposing papers, and the numerous discovery requests at issue, it is apparent to the court that counsel must resume the meet-and-confer process in good faith before drawing upon the court’s limited resources. Counsel for the parties are thus ordered to resume the meet-and-confer process in order to resolve or substantially narrow their discovery dispute.

In resuming the meet-and-confer process, counsel should discuss crafting a stipulated protective order to alleviate concerns about disclosure of proprietary information. Counsel should also discuss: (1) whether a discovery referee should be appointed; (2)

whether there is a factual basis to request documents related to a vehicle class other than the 2500 class of the 2013 GMC Sierra and, if so, whether it would truly burden Defendant to produce such documents; (3) whether some of Defendant’s objections should be withdrawn (e.g., objections that requests are vague and ambiguous, assume facts not in evidence or are self-serving); (4) whether Defendant should produce a privilege log if it stands by its objections based on any privilege; (5) whether specially defined terms in the requests should be modified or clarified; and (6) whether Defendant’s search for responsive documents should be limited to sources available in California.

Counsel shall meet and confer in person or by telephone no later than 2/02/18. After thoroughly meeting and conferring in an attempt to resolve each and every issue that the motion currently encompasses, and no later than 2/12/18, counsel shall file a joint statement indicating which discovery issues have been resolved, and which issues (if any) remain outstanding. For each outstanding issue, counsel shall set forth in the joint statement their respective positions, citing the relevant facts and authorities. Boilerplate or cut-and-paste arguments are strongly discouraged.

Counsel are reminded that this court does not have the resources to tend to and resolve every discovery issue that could have and should have been resolved informally. (See Young v. Rosenthal (1989) 212 Cal.App.3d 96, 117 [“The very purpose of an order to meet and confer is to obtain a negotiated resolution of a discovery dispute without having to expend judicial time to sort out which party is correct and what relief should be granted. What the court seeks is an agreement by the parties which resolves the dispute”].)