Hyundai Motor America v. O'NEILL

This mandamus proceeding presents important issues concerning the steps necessary to preserve a claim of privilege during discovery. I write separately to address these issues.

NECESSITY OF AN APPROPRIATE REQUEST

This discovery dispute centers on the interpretation of Request No. 17 to Plaintiff’s First Request for Production. As originally written, Corina McDonald asked Hyundai to produce:

Each document containing any compilation, report, summary, analysis, index or digest of warranty claims, problems, or complaints pertaining, directly or indirectly, to the seat belt system on the model of…