*1 This matter is before the Court on Plaintiffs’ Fourth Motion to Compel Discovery [Doc. No. 245]. For the reasons that follow, Plaintiffs’ motion is granted in part and denied in part.

This putative class action lawsuit involves the transmissions on Defendant Ford Motor Company's Model Year 2017-2020 Ford F-150 vehicles. Plaintiffs bring the action individually and on behalf of all similarly situated persons who purchased or leased the subject vehicles. Plaintiffs allege that the subject vehicles have “defects contained in the Vehicles’ 10R80, a 10-speed automatic transmission that can shift harshly and erratically, causing the vehicle to jerk, lunge, and hesitate between gears.” (Am. Compl. ¶ 3.) Plaintiffs assert that, despite Ford's knowledge of the transmission defects, the company “has refused to recall or replace the defective Transmissions.” (Id. at ¶ 5.) According to Plaintiffs, had they “known about the Transmission Defect at the time of sale or lease,” they “would not have purchased” the subject vehicles “or would have paid less for them.” (Id. at ¶ 10.) Several discovery disputes have arisen between the parties and they were not able to resolve their disputes through the required Local Rule 37.2 procedure. Plaintiffs now move for an order compelling Ford to produce documents and present a corporate representative to provide further testimony. The disputed discovery issues will be addressed below in turn.

Federal Rule of Civil Procedure 26 provides that “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1); see also Fed. R. Civ. P. 34; Fed. R. Civ. P. 37(a)(3)(B). “The party requesting discovery bears the initial burden of establishing its relevancy.” Eternity Mart, Inc. v. Nature's Sources, LLC, No. 19-cv-02436, 2019 U.S. Dist. LEXIS 198880, at *4 (N.D. Ill. Nov. 15, 2019) (citations omitted); see also Art Akiane LLC v. Art & SoulWorks, LLC, No. 19 C 2952, 2020 WL 6509228, at *3 (N.D. Ill. Nov. 5, 2020) (collecting cases). If the requesting party meets its burden, “the party opposing discovery has the burden of proving that the requested discovery should be disallowed.” Sols. Team v. Oak St. Health, MSO, LLC, No. 17 CV 1879, 2021 U.S. Dist. LEXIS 132847, at *7 (N.D. Ill. July 16, 2021) (citation omitted).

I. DEPOSITION TOPIC NO. 4 AND eSOURCEBOOKS

Plaintiffs move for an order requiring Ford to present a corporate representative to provide testimony regarding Ford's “eSourceBooks.” Generally, it appears from the record that eSourceBooks are documents prepared to assist Ford's salespeople when selling vehicles to customers. The parties’ dispute presents the question of whether eSourceBooks and testimony related thereto fall within Plaintiffs’ Rule 30(b)(6) Deposition Topic No. 4. In that deposition topic, Plaintiffs seek corporate representative testimony regarding:

[Doc. No. 245-9 at 2.] This Court previously ordered Ford to “present a corporate representative knowledgeable about [Deposition Topic No. 4] as drafted.” [Doc. No. 215.]

Ford contends that eSourceBooks are outside the scope of Deposition Topic No. 4 because “the topic is limited to only Ford's advertising” and “eSourceBooks are not a form of advertising” but rather “educational materials designed to provide dealership employees with basic information on a particular vehicle model.” (Def.’s Resp. at 1-2, 7.) On the other hand, Plaintiffs argue that the eSourceBooks fall under Deposition Topic No. 4 because they embody representations made by Ford directed at potential Ford consumers concerning the class vehicles. As characterized by Plaintiffs, “the sole purpose of eSourceBooks is to aid salespeople in selling vehicles to potential customers” as “eSourceBooks describe key vehicle messages, key vehicle features, and ‘bragging rights’ – information that is only relevant if passed on to potential customers and used to sell vehicles.” (Pls.’ Mot. at 7.)

Plaintiffs’ assertion that eSourceBooks constitute representations directed at potential Ford customers is borne out by the deposition testimony of Ford employee Brian Bell, the corporate representative designated by Ford to provide testimony regarding Deposition Topic No. 4. Mr. Bell testified that the purpose of eSourceBooks is “for [Ford] salespeople to learn about the vehicles so they can talk to their customers intelligently.” [Doc. No. 245-8 at 127:2-9 (emphasis added).] Further, Mr. Bell agreed that eSourceBooks “explain[ ] to [Ford salespeople] the features of, and highlights, so they can pass that information on to customers.” [Id. at 107:23-108:1 (emphasis added).]

In light of Mr. Bell's testimony in that regard, the Court concludes that eSourceBooks fall within Deposition Topic No. 4 as they embody representations made by Ford through a medium of communication directed at potential Ford consumers. Furthermore, the information contained in the eSourceBooks is plainly relevant in this litigation. Accordingly, the Court compels Ford to prepare and present a corporate witness to testify with respect to statements made in eSourceBooks regarding class vehicles. Ford shall present such a witness within 28 days of this order.

II. IMMERSION EVENTS DOCUMENTS

The parties’ second discovery dispute concerns so-called “immersion events” and documents related thereto. At his deposition, Mr. Bell described “immersion events” as events where Ford's “suppliers come in and learn about the ... vehicle from engineering or from the different groups.” [Doc. No. 245-8 at 22:4-19.] Mr. Bell further testified that at immersion events:

*3 [Id. at 177:9-16.] Plaintiffs now seek an order requiring Ford to produce documents related to the immersion events.

In arguing that Plaintiffs are not entitled to documents concerning immersion events at this juncture, Ford's contentions boil down to its assertion that “Plaintiffs’ request for the production of documents related to immersion events should be denied as untimely because Plaintiffs first raised the issue after the close of fact discovery.” (Def.’s Resp. at 12.) However, Plaintiffs maintain that they first learned that Ford had withheld immersion events documents during Ford's 30(b)(6) deposition (after fact discovery had closed) and “[p]rior to Mr. Bell's deposition, Ford had not produced or disclosed the existence of any documents concerning immersion events.” (Pls.’ Mot. at 9; Pls.’ Reply at 1.) In response, Ford asserts that it previously “produced documents concerning ‘immersion events and marketing meetings’ ... as well as documents demonstrating it was working with third-parties on F-150 marketing [and] [t]hese are precisely the type of documents that Plaintiffs now belatedly seek.” (Def.’s Resp. at 13-14.) However, Plaintiffs point out that “the documents highlighted by Ford are not the presentations referenced by Ford's 30(b)(6) representative” and “the immersion event document from the 2018 event discussed by Ford's representative was not produced during the regular course of discovery.” (Pls.’ Reply at 13 n.7.)

The Court finds that documents related to immersion events are relevant and responsive to multiple of Plaintiffs’ discovery requests. As such, documents concerning immersion events should have been produced by Ford during the regular course of discovery (and it is unclear to the Court why they were not). It appears from the record that Ford did not previously disclose that it was withholding immersion event documents, and Plaintiffs had no reason to believe such documents were being withheld until they learned that fact at Ford's 30(b)(6) deposition. Plaintiffs promptly sought production of the documents upon learning that documents had been withheld. Under the circumstances, the Court concludes that Plaintiffs are entitled to documents concerning immersion events despite fact discovery otherwise being closed. Accordingly, the Court compels Ford to produce documents prepared for and disseminated during immersion events where Ford presented information related to 10R80 transmissions. Ford shall produce such documents within 28 days of this order.

III. FORD'S SEARCH FOR DOCUMENTS REGARDING DRAFT TSB

The parties’ final discovery dispute concerns one of Ford's Technical Service Bulletins (“TSBs”), specifically, a draft TSB that addresses rough shifting in class vehicles. Ford has agreed to supplement its production regarding the draft TSB and to “conduct a targeted search for communications regarding Ford's consideration of the issuance of a potential new TSB.” [Doc. No. 245-5 at 1.] Ford is in the process of producing such documents. However, Plaintiffs complain that Ford has improperly “refus[ed] to provide more clarity about its proposed ‘targeted search.’ ” (Pls.’ Mot. at 11.) Along those lines, Plaintiffs request that Ford be “compelled to describe its specific process for locating responsive documents related to the draft TSB.” (Id. at 13.) However, the joint discovery plan in this case states that “the Producing Party is best situated to decide how to search for and produce ESI responsive to the Receiving Party's discovery requests.” [Doc. No. 136 at ¶ 7.] Furthermore, and in any event, the Court accepts Ford's representation that it is conducting a good faith search and finds that Ford is not obligated to detail its search efforts for Plaintiffs. Accordingly, Plaintiffs’ motion to compel is denied with respect to Ford's search for and production of documents concerning the draft TSB.

*4 For the foregoing reasons, Plaintiffs’ Fourth Motion to Compel Discovery [Doc. No. 245] is granted in part and denied in part as specified herein.

SO ORDERED.