Palomino vs. FCA US, LLC

Defendants have failed to specify exactly what they want stricken from the complaint, as required under subdivision (a) of CRC 3.1322. That subdivision states:

A notice of motion to strike a portion of a pleading must quote in full the portions sought to be stricken except where the motion is to strike an entire paragraph, cause of action, count, or defense. Specifications in a notice must be numbered consecutively. The Court cannot grant the relief requested because it does not know specifically what defendants want it to strike.

Furthermore, plaintiffs filed a first amended complaint on October 2, 2025, which means that it is the operative pleading in the action and that the (initial) complaint has been superseded. Thus, to the extent that defendants are seeking to strike portions of the complaint – as opposed to the first amended complaint – as stated in the notice of motion, the motion is moot. 11 25-01460537 Motion to Compel Production

Palomino vs. FCA US, Plaintiff Eduardo Palomino’s Motion to Compel Further Compliance LLC with Code of Civil Procedure section 871.26 is CONTINUED to _.

Defendant produced numerous documents in response to its initial disclosure obligations. Plaintiff seeks additional documents he claims are responsive but were not produced. Plaintiff has failed to show any attempts to meet and confer prior to filing its Motion.

The parties are ordered to engage in additional meet and confer efforts, including an in-person, telephonic, or videoconference meeting of counsel, no later than 30 calendar days prior to the continued hearing date. If Defendant agrees to serve supplemental responses, Defendant shall serve supplemental verified responses and produce additional documents no later than 20 calendar days prior to the continued hearing date. Plaintiffs’ counsel shall file and serve a supplemental declaration, no later than 9 court days before the continued hearing date and not to exceed five pages, including: (1) a description of the parties’ additional attempts to meet and confer; (2) attaching a copy of Defendant’s supplemental responses, if any; and (3) a concise description of any remaining dispute including identification of the specific requests which remain in dispute.

Defendant’s counsel may file a responsive supplemental declaration, not to exceed three pages, no later than 5 calendar days before the continued hearing date.