MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
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6/25/26 - Law and Motion Calendar Judge Mark A. McCannon – Department 2 Page 8 of 25
2:00 PM LINE: 4 25-CIV-03474 LAYA WASHINGTON VS. PORSCHE CARS NORTH AMERICA, INC., ET AL
LAYA WASHINGTON ROY ENAV PORSCHE CARS NORTH AMERICA, INC. MICHAEL AYZEN
PLAINTIFF LAYA WASHINGTON’S MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
TENTATIVE RULING:
For the reasons stated below, Plaintiff Laya Washington’s unopposed Motion to Compel Further Responses to Plaintiff’s Requests for Production of Documents, Set One, filed December 17, 2025, is GRANTED IN PART and DENIED IN PART.
As to RFP No. 30, the motion is GRANTED IN PART, subject to the limitations set forth below. RFP No. 30 seeks:
All DOCUMENTS, in the form of a list or compilation, of other Customer Complaints in YOUR ESI of database(s) that are SUBSTANTIALLY SIMILAR to complaints made by Plaintiff with respect to the SUBJECT VEHICLE in other 2022 Porsche Panamera vehicles.
Defendant Porsche Cars N.A., Inc. (“PCNA”) responded:
PCNA objects to this request as vague, ambiguous, overly broad, and as asking for information that is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence including but not limited to that it does not take into consideration the statutory construct of the Song-Beverly Consumer Warranty Act. Whether Plaintiff is entitled to relief under the Song-Beverly Consumer Warranty Act is entirely unrelated to complaints in other 2022 Porsche Panamera vehicles.
This case concerns whether Plaintiff is entitled to a remedy under the facts of this case. See Calcor Space Facility, Inc. v. Superior Court (1997) 53 Cal.App.4th 216. Moreover, the request fails to describe with reasonable particularity the documents or categories of documents being requested, in violation of CCP 2031.030(c)(1). In addition, the term "complaints made by Plaintiff" is not defined, described, or otherwise explained in this request and, without definition, description, or explanation is vague, ambiguous and the information referred to or sought cannot be reasonably determined, without speculation.
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PCNA objects to the extent this request asks for information that is protected by the right to privacy. PCNA objects to this request to the extent it may call for information that is confidential, commercially sensitive, and/or proprietary. PCNA further objects to the extent this request asks PCNA to respond on behalf of any other entity.
PCNA’s objections are OVERRULED except as to overbreadth, which is sustained to the extent reflected in this ruling. RFP No. 30 seeks discoverable documents, but the request is overbroad as drafted. The Court limits RFP
6/25/26 - Law and Motion Calendar Judge Mark A. McCannon – Department 2 Page 9 of 25
No. 30 to customer complaints in California, not nationwide, that pertain to 2022 Porsche Panamera vehicles, not other years, makes, or models, and that are substantially similar to the complaints made by Plaintiff regarding the subject vehicle.
Within 10 days of notice of entry of this order, PCNA shall serve a further verified response agreeing to produce all nonprivileged, responsive documents as limited by this order. To the extent PCNA withholds any responsive documents based on privilege, PCNA shall serve a code-compliant privilege log.
As to RFP No. 31, the motion is DENIED. RFP No. 31 seeks:
All DOCUMENTS that refer to, reflect, or relate to any Field Service Action issued, or in the process of being issued, in response to complaints experienced by Plaintiff as described in Defendant’s warranty history/summary and within the line items of the repair orders created at Defendant’s authorized repair facility.
PCNA responded by asserting several objections, followed by the statement:
Subject to and without waiving these objections, PCNA is unable to comply with this request. PCNA has made a diligent search and reasonable inquiry and has no "Field Service Actions," and no responsive documents have ever existed.
PCNA’s response is code-compliant and sufficient. It substantially complies with the statement-of-inability-tocomply requirements of Code of Civil Procedure section 2031.230. Plaintiff’s belief that PCNA must have responsive documents does not constitute grounds to compel PCNA to provide a further response.
If the tentative ruling is uncontested, it shall become the order of the Court. Thereafter, counsel for the Plaintiff shall prepare a written order consistent with this ruling for the Court’s signature, pursuant to California Rules of Court, rule 3.1312, and provide notice of the ruling to all appearing parties as required by law. The Court further directs the parties’ attention to revised Local Rule 3.403(b)(iv) (eff. Jan. 1, 2024) regarding the form of proposed orders.