THIS CAUSE came before the Undersigned on Plaintiff's Motion to Compel, and this Court, having read the pleadings, motions, depositions, and submissions of the Parties, and having heard the arguments of Counsel, and having concluded that Plaintiff's Motion should be granted, hereby issues the following Order pursuant to Rule 37(a) of the North Carolina Rules of Civil Procedure:

1. The Toyota and Subaru Defendants' responses to Plaintiff's First Interrogatories and First Requests for Production of Documents, and their responses to the document requests contained in the Rule 30(b)(6) deposition notices to said Defendants did not comply with the North Carolina Rules of Civil Procedure.

2. The Toyota and Subaru Defendants did not comply with their responsibilities under Rule 30(b)(6) to provide witnesses prepared to testify as to the matters known or reasonably available to the Toyota and Subaru Defendants regarding the topics listed in Plaintiffs Notices of Deposition to said Defendants.

3. The Toyota and Subaru Defendants shall supplement their responses to Interrogatories 17-21 and 23-25 with full, complete, and substantive responses without further objection, within thirty (30) days of the entry of this order.

4. The Toyota and Subaru Defendants shall supplement their responses to Requests for Production 4, 5, 13, 18, 22, 25, 29, 30, 32, 36-38, 44, 45, 53-58, and 67 with full, complete, and substantive responses, and with production of all responsive documents, files, and materials within thirty (30) days of the entry of this order, and without further objection. Defendant shall produce all responsive documents, files, and other materials in English, and in their native, electronic format.

5. The Toyota and Subaru Defendants shall supplement their responses to the document requests contained in the respective Notices of Deposition with full, complete, and substantive responses, and with production of all responsive documents, files, and materials, within thirty (30) days of the entry of this order, and without further objection. Defendant shall produce all responsive documents, files, and other materials in English, and in their native, electronic format.

6. To the extent that Defendants claim that a document or set of documents is not within their possession or control, Defendants shall specifically identify the document(s), the custodian of the document(s), the efforts made to obtain the document(s), and, to the extent that any document was destroyed, the date of destruction and the identity of the individual(s) who authorized the destruction of any such document(s).

7. To the extent that Defendants claim that a document or documents are protected from disclosure pursuant to the attorney-client or work product privileges Defendants shall provide privilege logs that set forth with particularity the document or documents, the author of the document(s), the recipient of the document(s), and a description of the document(s) being withheld sufficient for the Plaintiff to evaluate the claim of privilege.

8. To the extent that the Parties cannot agree on whether a document is subject to the attorney-client or work-product privileges, the Defendant asserting the privilege shall submit the materials to the Undersigned for in camera review.

9. Following the supplementation and production pursuant to this Order, Defendant shall designate the specific individuals who are prepared to testify as to all matters known or reasonably available to the respective Defendant for the topics listed in the respective Rule 30(b)(6) depositions, without further objection.

10. The Court finds and concludes that the consent protective order entered in this Action provides adequate protection for any materials subject to any alleged trade secret, confidential, or proprietary privileges.

11. The Court finds and concludes that the interests of justice, including but not limited to the need for resolution by the undersigned of any controversies concerning the scope of the notice or the testimony, require that the reconvened 30(b)(6) depositions take place in Robeson County, North Carolina.

12. The depositions shall take place within 150 days of the date of this Order.

13. Pursuant to Rule 37(a)(4), the Court hereby orders that the Toyota Defendants shall pay the reasonable expenses incurred in the taking of the June 1, 2023 Rule 30(b)(6) deposition in Plano, Texas, including reasonable attorney's fee. Counsel for Plaintiff shall submit an affidavit regarding the expenses and time incurred in the taking of the deposition within seven (7) days of the entry of this Order. 

14. Pursuant to Rule 37(a)(4), the Court hereby orders that the Subaru Defendants shall pay the reasonable expenses incurred in the taking of the June 21, 2023 Rule 30(b)(6) deposition in Torrance, California, including a reasonable attorney's fee. Counsel for Plaintiff shall submit an affidavit regarding the expenses and time incurred in the taking of the deposition within seven (7) days of the entry of this Order. 

15. The Undersigned hereby retains jurisdiction over this Action. Within seven (7) days of the entry of this Order, the parties shall confirm whether they consent or oppose thé waiver of venue for hearing of matters other than trial. 

IT IS SO ORDERED.'