ROBLES VS GENERAL MOTORS LLC

On April 30, 2024, Plaintiff filed a Complaint against GM, asserting causes of action for (1) violation of Civ. Code § 1793.2(d); (2) violation of Civ. Code § 1793.2(b); (3) violation of Civ. Code

§ 1793.2(a)(3); (4) breach of express written warranty; and (5) breach of implied warranty of merchantability.

On September 5, 2025, the parties reached a settlement via GM’s Offer to Compromise pursuant to CCP § 998 (“998 Offer”), whereby GM agreed to pay Plaintiff $225,000.00, which includes repurchase of the Subject Vehicle, payment of civil penalty, as well as attorney fees, costs, and expenses pursuant to a noticed motion. (Demery Decl. ¶ 10, Ex. 2.) The parties agreed that Plaintiff’s attorney fees, costs, and expenses would be decided by motion, and that Plaintiff was the prevailing party for purposes of this motion. (Id.)

On December 12, 2025, Plaintiff filed a Memorandum of Costs, seeking $3,394.47 in litigation costs. On December 22, 2025, GM filed a Motion to Tax Costs, which was heard on April 1, 2026, and denied in its entirety.

Plaintiff now moves for attorneys’ fees, costs, and expenses in the total amount of $79,363.22, which consists of (1) $47,772.50 in lodestar attorneys’ fees for Consumer Law Experts, P.C. (“CLE”), representing 116.3 hours billed by multiple attorneys and paralegals; (2) a 1.5 multiplier enhancement (or $23,886.25); (3) $4,310.00 in additional fees, comprised of (a) $1,318.00 related to GM’s Motion to Tax Costs and (b) $2,992.00 related to the instant fee motion; and (4) $3,394.47 in litigation costs and expenses. Plaintiff argues that, as the prevailing party, she is entitled to attorney fees and costs under Civ. Code § 1794(d), and that her lodestar fees are reasonable given the nearly two years of vigorous litigation, including extensive motion practice necessitated by GM’s obstruct-and-delay tactics.

In opposition, GM argues that Plaintiff’s fee request is excessive and unreasonable for a case that is indistinguishable from hundreds of other templated Song-Beverly cases that Plaintiff’s counsel litigates against GM. Specifically, GM contends: (1) Plaintiff’s billing records are templated and not a reliable reflection of actual time expended; (2) the hourly rates sought are excessive given that the relevant community is Riverside County and Plaintiff’s submitted fee orders are primarily from other jurisdictions; (3) multiple billing entries are excessive, duplicative, or reflect clerical tasks billed at attorney rates; and (4) no multiplier is warranted because the case did not present novel or complex issues. GM contends fees should be reduced to no more than $8,526.20, and that costs should be $0 as previously paid.

In reply, Plaintiff argues that GM’s opposition is a “templated opposition” containing facts from an entirely different case, including reference to a different plaintiff, a different vehicle, a different filing date, a different settlement amount, and the wrong county. Plaintiff contends that GM’s litigation strategy—forcing extensive litigation and then falsely claiming overbilling—is responsible for the fees incurred. Plaintiff further argues that GM failed to satisfy its evidentiary burden because its objections are conclusory and unsupported by any comparative timesheets, expert opinion, or legal authority establishing what time would be reasonable.

Song Beverly Attorney’s Fees

Under Civ. Code § 1794(d), if the buyer prevails in an action under the Song-Beverly Act, the buyer shall be allowed to recover “a sum equal to the aggregate amount of costs and expenses, including attorney’s fees based on actual time expended, determined by the court to have been reasonably incurred by the buyer in connection with the commencement and prosecution of such action.”

Here, there is no dispute that Plaintiff is the prevailing party and is entitled to reasonable attorney fees. The only question is the amount of the award.

Attorney fee awards should be fully compensatory. (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1133.) However, a fee request that appears unreasonably inflated is a special circumstance permitting the trial court to reduce the award or deny one altogether. (Serrano v. Unruh (1982) 32 Cal.3d 621, 635.) The reasonableness of attorney fees is within the sound discretion of the trial court. (Donahue v. Donahue (2010) 182 Cal.App.4th 259, 271.) In determining the reasonable amount of attorney fees, the court first determines a lodestar figure (i.e., the time reasonably spent multiplied by a reasonable hourly rate) and may then adjust based on various factors. (Serrano v. Priest (1977) 20 Cal.3d 25, 48.)

Plaintiff moves for attorneys’ fees, costs, and expenses in the total amount of $79,363.22. GM opposes, arguing that the fee motion is inflated and warrants reduction to no more than $8,526.20 in fees and $0 in litigation costs.

Hourly Rates

Plaintiff’s counsel seeks the following hourly rates: $560/hour for Carey Wood; $540/hour for Vanessa Oliva; $450/hour for Laura Schwartz; $440/hour for Bobby C. Walker and Destinae Demery; $415/hour for Ahmed Yousef; and $215/hour for paralegals. (Demery Decl. ¶¶ 12–19.) Plaintiff supports these rates by submitting eight prior fee orders from California courts approving the same or comparable CLE rates in Song-Beverly matters, including two orders expressly from Riverside County. (Id. at ¶¶ 20–27, Exs. 3–10.)

GM objects that (1) the relevant community is Riverside County and Plaintiff provides insufficient evidence of local market rates; (2) “none of [Plaintiff’s fee] orders are from Fresno County”; and (3) the work performed required no specialized trial-level skill. (Def.’s Opp. 11:25–12:18.) GM requests that the Court reduce rates to “prevailing Fresno County rates for comparable work.” (Id. at 12:16–18.)

A “reasonable” hourly rate is the prevailing rate charged by attorneys of similar skill and experience in the relevant community. (PLCM Grp., Inc. v. Drexler (2000) 22 Cal.4th 1084, 1095– 96.) Evidence of rates awarded to the same firm in other litigations “are ‘obviously relevant’ to the attorney fees determination.” (Margolin v. Regional Planning Com. (1982) 134 Cal.App.3d 999, 1005–06.) In the absence of contrary evidence, a showing of prior approved rates compels a finding that the requested rates are within the reasonable range. (Graciano v. Robinson Ford Sales, Inc. (2006) 144 Cal.App.4th 140, 156.) The Court may also rely on its own knowledge and experience. (PLCM Grp., supra, 22 Cal.4th at 1095.)

Here, the Court finds the requested rates reasonable, albeit on the higher end of reasonable, and awards them as requested. GM’s objections are factually erroneous and legally inapplicable. First, contrary to GM’s assertion that Plaintiff provided no evidence of Riverside County approvals, Plaintiff submitted two Riverside County court orders directly on point. (See Demery Decl. ¶¶ 20– 21, Exs. 3–4 [approving hourly rates up to $575 for attorneys and up to $215 for paralegals].) Second, GM’s reliance on “prevailing Fresno County rates” is entirely misplaced. This action was filed in Riverside County. This appears to be an error, as GM provides no basis for applying rates from a county that has no relationship to this litigation.

Hours Billed

“A trial court assessing attorney fees begins with a touchstone or lodestar figure, based on the ‘careful compilation of the time spent and reasonable hourly compensation of each attorney . . . involved in the presentation of the case.’” (Christian Research Institute v. Alnor (2008) 165

Cal.App.4th 1315, 1321.) The lodestar “approach ‘anchors the trial court’s analysis to an objective determination of the value of the attorney’s services, ensuring the amount awarded is not arbitrary.’” (Graciano v. Robinson Ford Sales, Inc. (2006) 144 Cal.App.4th 140, 154.) The court may also consider whether the amount requested is based upon unnecessary or duplicative work, and “[p]adding in the form of inefficient or duplicative efforts is not subject to compensation.” (Christian Research Institute, supra, 165 Cal.App.4th at 1321 [internal quotation marks & quotation omitted].)

Here, Plaintiff’s fee bill is supported by itemized time records and declarations from counsel attesting to their accuracy. Such verified fee bills are entitled to a presumption of reasonableness; the burden therefore falls on GM to rebut that presumption with specific evidence. (Hadley v. Krepel (1985) 167 Cal.App.3d 677, 682–83.) GM must “establish with legal authority or otherwise what hours and rates would be considered reasonable.” (Etcheson v. FCA US LLC (2018) 30 Cal.App.5th 831, 838.) While GM submits side-by-side exhibit comparisons to show template similarity across cases, GM’s counsel submits no countervailing timesheets, no comparable billing records from defense counsel, and no expert or evidentiary benchmark for how long any task should reasonably take, rendering GM’s specific time estimates of limited evidentiary weight.

(a) Templated Complaint: 1.2 hours ($443.00)

Plaintiff’s counsel billed 1.2 hours to draft the Complaint. GM requests a reduction of 1.0 hour ($377.50)—0.5 attorney hours ($270.00) and 0.5 paralegal hours ($107.50)—on the ground that drafting a complaint Plaintiff’s counsel has filed hundreds of times should require no more than 10 minutes. GM supports this argument with a side-by-side comparison of complaints across cases. (Gruszecki Decl. ¶ 3, Exs. A–B.)

Plaintiff responds that templates enable efficiency and reduce costs, and that use of templates does not mean the legal work was not performed.

The Court finds this objection well taken. Some reduction is appropriate given the conceded templated nature of the Complaint and the use of three timekeepers. However, GM’s proposed limit of 10 minutes is unsupported by evidence. Thus, the Court will reduce these entries by 0.50 hours ($188.75)—one-half of GM’s requested reduction of 1.0 hour ($377.50).

(b) Templated Discovery Requests: 5.6 hours ($2,426.00)

GM requests a reduction of 5.1 hours ($2,295.00), leaving only 0.5 hours (30 minutes) for drafting initial written discovery requests, deposition notices, and an ESI letter. GM contends the documents are fill-in-the-blank templates requiring only minimal customization.

Plaintiff responds that templates allow efficiency but still require careful analysis of the specific facts, issues, and evidence in each case to determine what is ultimately necessary. Plaintiff notes that the deposition of GM’s PMQ witness was ultimately taken on April 22, 2025, confirming the discovery work was productive.

The Court finds this reduction partially warranted. While GM’s side-by-side exhibit comparisons provide some support for a reduction, reducing 5.6 hours to 30 minutes for a full suite of written discovery, a deposition notice, and an ESI letter is extreme and unsupported by evidence. Thus, the Court will reduce these entries by 2.55 hours ($1,147.50)—one-half of GM's requested reduction of 5.1 hours ($2,295.00).

(c) Meet and Confer Letter and Emails: 5.9 hours ($2,430.00)

GM requests a reduction of 4.9 hours ($1,950.00)—covering 3.7 hours ($1,440.00) to review GM’s discovery responses and draft a meet and confer letter, and 2.2 additional hours ($990.00) for meet and confer emails—leaving only 1.0 hour at $450/hour. GM characterizes the meet and confer letter as a recycled template and the emails as padding.

Plaintiff responds that GM’s own discovery failures necessitated the correspondence. Plaintiff argues that GM failed to timely provide responses to written discovery requests, failed to meet and confer in good faith, and failed to produce its PMQ witness absent a court order, all of which necessitated motion practice. The motion to compel further responses to RFPs and the motion to compel PMQ deposition were subsequently granted on January 31, 2025 and March 27, 2025, respectively.

The Court finds this objection without merit. A granted motion to compel is strong evidence that the preceding meet and confer efforts were warranted.

(d) Motion to Compel Further Responses to RFPs: 15.1 hours ($6,536.50)

GM requests a reduction of 13.1 hours ($6,536.50), leaving 2.0 hours total for the full motion package (motion, separate statement, points and authorities, supporting declaration, proposed order, meet and confer correspondence, and reply). GM contends the papers are substantially templated from prior Song-Beverly motions against GM.

Plaintiff responds that this motion was heard and granted by the Court on January 31, 2025. Plaintiff further argues that precise and intensive briefing was required on the specific discovery disputes in this case, and that templates enabling efficiency do not reduce the legitimacy of the time spent.

The Court again finds this objection without merit. A court-granted motion is compelling evidence that the work was warranted. Moreover, even accepting that 15.1 hours is excessive for a templated motion package, GM’s own calculation is internally inconsistent. GM claims Plaintiff billed 15.1 hours at $6,536.50, yet requests a reduction of 13.1 hours at the same figure of $6,536.50. The Court is not obligated to speculate or fill gaps in the opposing party’s calculation.

(e) Motion to Compel PMQ Deposition: Multiple Entries (approximately $2,132.50 requested reduction)

GM requests a reduction of 5.0 hours ($2,132.50) across multiple entries spanning November 2024 through September 2025, covering the motion, supporting papers, reply, hearing preparation, and a subsequent motion to compel compliance. GM characterizes these motions as “unnecessary” requiring no more than one hour to draft them.

Plaintiff responds that the motion to compel PMQ deposition was heard and granted on March 27, 2025. Plaintiff argues that GM’s PMQ was deposed on April 22, 2025, and the motion to compel compliance with the Court’s Order was subsequently heard and granted on September 11, 2025.

The Court again finds this objection without merit. Two separate court-granted motions, plus a successful deposition, establish that this litigation activity was necessary and warranted. Thus, GM’s characterization of these motions as “unnecessary” is directly contradicted by the register of actions. No reduction is appropriate.

(f) Memorandum of Costs: 1.6 hours ($585.00)

GM requests a reduction of 1.1 hours ($402.60), characterizing the Memorandum of Costs as a fill-in-the-blank form.

Plaintiff responds that GM’s Motion to Tax Costs was heard and denied on April 1, 2026, and the Court ordered GM to pay $3,394.47 in costs, nearly four times the amount GM claimed it had “already paid,” when GM has yet to pay those costs.

The Court also finds this objection without merit. The denial of GM’s Motion to Tax Costs validates the cost memorandum. GM’s misrepresentations about having already paid costs further undercut the credibility of its objections in this category. No reduction is appropriate.

(g) Anticipated Fee Motion Time: ($2,150.00 requested)

GM requests that the Court deny $2,150.00 in “anticipated” fees to review the opposition, draft the reply, and attend the hearing, arguing Plaintiff’s existing 2.7 hours ($1,180.00) on the fee motion is sufficient.

Plaintiff responds that it has now actually incurred 4.6 hours ($2,112.00) reviewing GM’s opposition and drafting the reply, work necessitated in part by GM’s opposition, plus an additional 2.0 hours ($880.00) anticipated for the hearing.

The Court finds this objection without merit. As Plaintiff points out, fee motion time, including reply fees, are fully recoverable. (Serrano, supra, 32 Cal.3d at 639.) The 4.6 hours Plaintiff has documented as actually incurred are reasonable and should be awarded in full. The Court further finds that the additional 2.0 hours ($880.00) anticipated for attending the hearing are reasonable and recoverable.

(h) Pre-Representation Work: 6.1 hours ($1,376.50)

GM requests a full strike of 6.1 hours ($1,376.50) billed between October 24, 2023 and March 21, 2024, before the case was accepted for litigation. GM characterizes this time as overhead, citing Dominguez v. American Suzuki Motor Corp. (2008) 160 Cal.App.4th 53, 58, for the proposition that Song-Beverly does not require a manufacturer to reimburse pre-litigation attorney time. Plaintiff did not address this argument in the reply.

The Court finds this objection without merit. GM’s reliance on Dominguez is misplaced. The crux of Dominguez was that a potential plaintiff in a lemon lawsuit is not entitled to fees where the defendant settles the case prior to the commencement of litigation, a holding rooted in the purpose of the Song-Beverly Act to encourage manufacturers, when faced with a meritorious claim, to repurchase or replace the vehicle without resort to litigation. That is not the situation here. This case was litigated for nearly two years, resulting in a settlement.

Moreover, Civ. Code § 1794 provides for the recovery of aggregate fees reasonably incurred by the buyer in connection with the “commencement” and “prosecution” of the action. Pre-representation work undertaken to evaluate and prepare a case that was ultimately filed and litigated falls within the scope of recoverable fees. No reduction is appropriate.

(i) Clerical Tasks: 2.9 hours ($726.50 plus)

GM requests a full strike of at least 2.9 hours ($726.50 plus) for tasks such as calendaring deadlines, receiving documents, and filing/serving papers, arguing these are non-compensable

ministerial tasks. GM also notes that many of these entries are block-billed alongside substantive work, making it impossible to segregate them.

Plaintiff responds that tasks such as calculating statutory deadlines (which requires legal knowledge), drafting proofs of service, and compiling motion packages necessarily support attorney work and are recoverable.

While GM is correct that purely clerical tasks such as calendaring and receipt logging are not compensable at attorney or paralegal rates, many of these entries combine clerical and substantive work in a single block-billed entry, making it impossible to isolate and strike only the non-compensable portion without eliminating legitimate work alongside it. The burden of establishing an unreasonable fee request rests with the party opposing fees. (See Premier Med. Mgmt. Systems, Inc. v. Cal. Ins. Guarantee Assn. (2008) 163 Cal.App.4th 550, 564.) Thus, no reduction will be applied.

(j) Excessive Internal Review Entries: 5.4 hours ($2,727.00)

GM requests a 50 percent reduction of approximately 2.7 hours ($1,363.50) across numerous 0.1 and 0.2 hour internal review and strategy entries billed by multiple attorneys throughout the case.

Plaintiff responds that CLE is a mid-size firm that works as a team and that communications between supervising partners and associates on strategy—particularly regarding the multiple discovery motions this case required—are proper and recoverable. GM provides no evidence for what a reasonable amount of internal review should be.

The Court finds this objection without merit. Given the discovery disputes which required three contested motions, conferences among counsel were demonstrably necessary. No reduction will be applied.

(k) Excessive Time Preparing for PMQ Deposition: 12.2 hours ($5,443.00)

GM requests a reduction of 10.0 hours ($4,500.00), leaving only 2.2 hours for deposition preparation, on the ground that Plaintiff’s counsel was already familiar with GM’s production.

Plaintiff responds that until the case settled—three months before the scheduled trial date of December 12, 2025—Plaintiff had to conduct discovery and prepare to prove liability on all claims.

The Court finds this objection partially warranted. 12.2 hours solely for deposition preparation (exclusive of the deposition itself) is excessive for a case of this nature. Thus, the Court will reduce these entries by 5.00 hours ($2,250.00)—one-half of GM’s requested reduction of 10.0 hours ($4,500.00).

(l) Settlement and Vehicle Surrender: 1.5 hours ($780.00)

GM requests a reduction of 1.1 hours ($630.00), arguing that vehicle surrender coordination should have been handled by a paralegal at $300/hour, and that the task should take no more than 30 minutes. Plaintiff did not address this argument in the reply.

The Court finds this objection without merit. GM’s central premise—that vehicle surrender coordination was improperly billed at attorney rates when it could have been performed by a paralegal—is contradicted by the billing records themselves. (Demery Decl. ¶ 30, Ex. 11.) Notably, GM’s opposition characterizes this work as having been billed at $600/hour, a rate that does not correspond to any timekeeper in this case. More importantly, the record reflects that nearly all of

the time entries associated with settlement coordination and vehicle surrender were in fact billed at the paralegal rate of $215/hour. (Id.) GM’s argument is thus without merit. No reduction is appropriate.

Based on the foregoing, the Court finds that GM’s requested reductions are partially warranted. Applying the reductions of 8.05 hours ($3,586.25) to Plaintiff’s base lodestar of $47,772.50, the adjusted base lodestar is $44,186.25, plus $4,310.00, for a total of $48,496.25.

Multiplier

Plaintiff requests a 1.5 multiplier based on (1) the results obtained, (2) contingency risk, and (3) the complexity and skill displayed in litigating this matter. GM opposes, arguing the case presented no novel issues, counsel operates hundreds of similar Song-Beverly matters simultaneously, the contingency risk was minimal given the fee-shifting mandate, and the requested enhancement would result in an effective rate of “$1,686.88 per hour” for a noncomplex lemon law case that never went to trial. (Def.’s Opp. 11:16–22.)

While the lodestar reflects the basic fee for comparable legal services in the community, it may be adjusted based on various factors, including “(1) the novelty and difficulty of the questions involved, and the skill displayed in presenting them; (2) the extent to which the nature of the litigation precluded other employment by the attorneys; (3) the contingent nature of the fee award” and (4) the success achieved. (Serrano, supra, 20 Cal.3d at 49.) However, courts must avoid enhancing the lodestar for factors already subsumed within it, such as counsel’s skill or the contingent nature of the representation, unless the representation was truly exceptional. (Ketchum, supra, 24 Cal.4th at 1138–39.)

As the California Supreme Court cautioned in Ketchum, “a trial court should award a multiplier for exceptional representation only when the quality of representation far exceeds the quality of representation that would have been provided by an attorney of comparable skill and experience billing at the hourly rate used in the lodestar calculation. Otherwise, the fee award will result in unfair double counting and be unreasonable.” (Id. at 1139.) A multiplier is not warranted here.

This matter did not present novel legal questions. Song-Beverly breach of warranty cases involve similar issues from case to case, and CLE simultaneously handles dozens, if not hundreds, of active Song-Beverly cases against GM and other manufacturers—defeating any claim that this litigation precluded other employment. (Gruszecki Decl. ¶ 14.) The case involved a complaint, written discovery, motions to compel, a PMQ deposition, and a settlement, and did not involve a complexity that “far exceeds” what a comparably skilled Song-Beverly attorney billing at the approved lodestar rates would have provided. (Ketchum, supra, 24 Cal.4th at 1139.) The Court therefore denies Plaintiff’s request for a multiplier.

Litigation Costs and Expenses

Plaintiff filed a Memorandum of Costs on December 12, 2025, seeking $3,394.47 in litigation costs and expenses. GM moved to strike or tax $2,839.14 of those costs. That motion was heard on April 1, 2026, and was denied in its entirety by this Court. (Demery Suppl. Decl. ¶ 4, Ex. 12.)

A verified memorandum of costs is prima facie evidence of the costs’ validity, and the burden falls on the party seeking to tax costs to show they were not reasonable or necessary. (Ladas v. Cal. State Auto. Assn. (1993) 19 Cal.App.4th 761, 774.) Under Civ. Code § 1794(d), a prevailing buyer is entitled to recover costs and expenses reasonably incurred in connection with the commencement and prosecution of the action.

GM’s opposition claims it “already paid” Plaintiff $817.75 in costs on “January 5, 2026.” (Def.’s Opp. 12:20–21.) This assertion is contradicted by the record. As of May 11, 2026, GM has not paid Plaintiff’s costs and expenses in the amount of $3,394.47, as reflected in Plaintiff’s Memorandum of Costs. (Demery Suppl. Decl. ¶ 4, Ex. 12.) Thus, the Court awards costs in the full amount of $3,394.47.

3. CASE # CASE NAME HEARING NAME MOTION TO COMPEL LE PAON RESTAURANT TO PROVIDE RESPONSES TO REQUESTS FOR ORNELAS VS LE PAON CVPS2500121 PRODUCTION-SET TWO, WITHOUT RESTAURANT LLC OBJECTIONS, AND FOR SANCTIONS IN THE AMOUNT OF $510 BY ROSA ORNELAS Tentative Ruling: Granted in part.

Granted as to sanctions in the amount of $510.00 payable by Defendant to Plaintiff within 30 days of this order becoming final. The motion is otherwise moot.

Moving party to provide notice pursuant to CCP 1019.5.

Plaintiff Rosa Ornelas brings this FEHA, and wage and hour action against her former employer, Defendant Le Paon Restaurant and its owners, Defendants Antoine Babia and Eddie Babai. Plaintiff alleges that Defendant Eddie Babai would make sexual and inappropriate comments about her appearance, proposing dates and promising to support her. When Plaintiff rejected his advances, he grew hostile and began demeaning her, criticizing her for speaking Spanish, and made disparaging comments regarding her Mexican heritage.

Defendant Eddie Babai also physically assaulted and battered her on several occasions. Plaintiff complained to Defendant Antoine Babai who took no action. Instead, Defendant Antoin Babai also engaged in sexual harassing conduct towards Plaintiff. As a result, Plaintiff resigned in March 2023. The complaint, filed 1/2/25, asserts: (1) wrongful termination in violation of public policy; (2) hostile work environment; (3) quid pro quo sexual harassment; (4) failure to prevent discrimination, harassment and retaliation; (5) discrimination; (6) retaliation; (7) retaliation for exercise of protected rights; (8) Bane Civil Rights Act violation; (9) failure to provide meal and rest periods; (10) failure to pay wages; (11) failure to provide itemized wage statements; (12) unfair competition; and (13) waiting time penalties.

Plaintiff moves to compel Defendant to provide responses to requests for production. Plaintiff served discovery on 1/5/26 and has yet to receive responses. Plaintiff also requests sanctions of $510 against Defendant and its counsel.

In opposition, Defendant contends it has now served responses without objections. Counsel asserts that due to scheduling/calendaring errors, Defendant did not timely respond.

In reply, Plaintiff contends the responses are not code-compliant as they do not state whether production is allowed in whole or in part, or when Defendant states it is unable to comply, it does not state why. Defendant also apparently filed social security numbers of third parties.

Motion to Compel Further Response(s)