Alvaro Pedroza v. Ford Motor Company et al.

This is a Song-Beverly Consumer Warranty Act case. Plaintiff Alvaro Pedroza moves to compel further responses to certain requests for production of documents (Nos. 16 through 24, 30, 50, and 51) from defendant Ford Motor Company (Ford). The parties separate discussion of the requests into two groups.

Request for Production Nos. 16 through 24: These requests relate to Ford’s policies and procedures related to warranty claims and handling customer complaints related to possible Song-Beverly Act claims. Ford initially withheld records pending entry of a stipulated protective order. Plaintiff confirms that after the stipulated protective order was entered, Ford produced documents related to a class action case “encompass[ing] policies and procedures for the years 2016 through 2024.” (Reply ISO MTC, at 2:9-16.) Plaintiff argues the response should be supplemented with records for 2025. The court finds Ford’s response code-compliant. The motion is DENIED as to these requests.

Request for Production Nos. 30, 50, 51: These requests seek information about complaints from owners of 2023 Ford F-150 trucks, which is the same make and model as plaintiff’s truck. In a meet and confer letter, Ford agreed to “meet and confer with [plaintiff] to establish appropriate search parameters to identify additional documents from Ford’s internal databases” to respond to these requests. Ford indicated it would supplement its responses to include: “Complaints or concerns made by California customers of vehicles that are of the same year, make, and model as Plaintiff’s vehicle, which is a 2023 Ford F-150 Crew Cab, with 4-wheel L/H pat time drive, equipped with a 3.5L V6 engine, and a Mod Hybrid Transaxle- A10R80 MHT-X, and involving the agreed symptoms from Plaintiff’s repair records allegedly exhibited in Plaintiff’s vehicle.” (Exh.

E. to Lopez dec. ISO MTC, filed 9/3/25.) The court agrees with plaintiff that no further meet and confer is necessary or appropriate. The motion to compel is GRANTED as to request Nos. 30, 50, and 51 as follows: Ford must produce responsive documents that meet the parameters it previously identified.

Plaintiff requests sanctions in the amount of $2,734. The court finds no substantial justification for Ford’s failure to supplement its responses to request for production Nos. 30, 50, and 51. (Code Civ. Proc., § 2023.030, subd. (a) [the court “shall impose” discovery sanctions “unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust”].) The court finds sanctions appropriate in the amount of $1,200 (four hours at $300/hour).