KOPICK, INC. VS. EPLEX, INC.

# Case Name Tentative

1. KOPICK, INC. VS. EPLEX, INC. 2025-01491949 MOTION TO BE RELIEVED AS COUNSEL OF RECORD

The motion of attorneys Samuel Yu and Daniel Yu and law firm Kahana & Feld LLP to be relieved as counsel for defendant Eplex, Inc. is GRANTED. (Code Civ. Proc., § 284; Cal. Rules of Court, rule 3.1362.) Attorneys will be relieved as counsel of record for client effective upon filing of proof of service of the signed order on client.

Moving attorney is to give notice of ruling which includes notice to Defendant that corporations must be represented by counsel.

2. FLORES VS. FCA US, LLC 2023-01366471 MOTION TO COMPEL PRODUCTION

Plaintiff Francisco Javier Flores’ motion to compel Defendant, FCA US, LLC (“FCA”) to provide responses, without objections, to Plaintiff’s Request for Production of Documents, Set One, is MOOT.

On May 22, 2024, Plaintiff served Requests for Production of Documents, Set One (“RFPs”) on FCA. (Rucker Decl., ¶ 4, Ex. 1.) Plaintiff sent a meet and confer letter to FCA on December 31, 2025. (Rucker Decl., ¶ 7, Ex. 2.)

On January 13, 2026, FCA served verified responses to Requests for Production of Documents, Set One. (Gruzman Decl., ¶ 4, Ex. 2.) Defendant has shown the responses are not untimely based on an agreement between FCA and Plaintiff’s counsel’s firm Strategic Legal Practices (“SLP”). Specifically, FCA and SLP entered into an informal arrangement for all cases between FCA and Strategic Legal Practices. (Hugret Decl., ¶ 4.) The informal arrangement was negotiated directly with SLP’s Founding Partner Payam Shahian in December 2024. (Hugret Decl., ¶ 4.)

The arrangement allowed Plaintiff’s counsel to serve discovery requests, while FCA received an open-ended extension to respond to Plaintiff’s discovery. (Hugret Decl., ¶ 5.) The basis of this agreement was that FCA would not be required to respond to discovery served by SLP during the pendency of this arrangement unless such responses were specifically requested by SLP, at which time, FCA would promptly provide responses. (Hugret Decl., ¶ 5.) As part of this agreement. FCA also agreed to informally produce certain case documents, such as the warranty claims and call logs. (Hugret Decl., ¶ 5.)

FCA complied with its portion of the agreement and provided informal document productions for 185 cases by January 27, 2025. (Hugret Decl., ¶ 5.) FCA further complied with the agreement by serving verified responses to the RFPs on January 13, 2026, and producing documents, Bates Number 00001-001527. Therefore, the Motion is MOOT.

Plaintiff’s request for sanctions is DENIED.