Judge: Armen Tamzarian, Case: 22STCV26384, Date: 2023-12-18 Tentative Ruling

Case Number: 22STCV26384    Hearing Date: December 18, 2023    Dept: 52

Plaintiff Lajos “Lali” Hugyetz’s Motion to Compel Further Responses to Special Interrogatories

Plaintiff Lajos “Lali” Hugyetz moves to compel defendant Equinox Holdings, Inc. to provide a further response to special interrogatory, set two, No. 41.  A party propounding interrogatories may move to compel further responses when an answer “is evasive or incomplete,” “[a]n exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate,” or “[a]n objection to an interrogatory is without merit or too general.”  (CCP § 2030.300(a).) 

Defendant made meritless objections to special interrogatory No. 41.  The interrogatory requests the “full name, address, telephone number, and date of hire, for the first three Personal Trainers that were hired at” the gym where plaintiff worked.  Defendant responded, “Defendant objects on the grounds that this Interrogatory is overbroad in time, and therefore, seeks information irrelevant to the subject matter of this case, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence.  Defendant further objects to this interrogatory to the extent that it violates the privacy rights of third parties.”

This interrogatory is not overbroad in time.  It asks defendant to identify only the first three personal trainers it hired after February 23, 2022.  The question can only apply to the time from that date to the present.  That is a reasonable and narrow scope.

Defendant’s privacy objection does not warrant denying this discovery.  Defendant’s reliance on Life Technologies Corp. v. Superior Court (2011) 197 Cal.App.4th 640 is misplaced.  There, the Court of Appeal applied a standard, which has since been rejected, that discovery of “confidential information in third party personnel files” should be denied “unless the litigant can show a compelling need for the particular documents and that the information cannot reasonably be obtained through depositions or from nonconfidential sources.”  (Id. at p. 652.)  The California Supreme Court expressly disapproved Life Technologies “to the extent [it] assume[d], without conducting the” necessary analysis, “that a compelling interest or compelling need automatically is required.”  (Williams v. Superior Court (2017) 3 Cal.5th 531, 557, fn. 8 (Williams).)

Williams set forth the following test for adjudicating privacy objections: “The party asserting a privacy right must establish a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious.”  (Williams, supra, 3 Cal.5th at p. 552.)  If the objecting party shows all three elements, then the court must balance the need for disclosure against the right to privacy.  (Ibid.)

Defendant shows a legally protected privacy interest and an objectively reasonable expectation of privacy but does not show a serious threatened intrusion.  Plaintiff asks for three personal trainers’ names, addresses, phone numbers, and dates of hire.  “[T]he requested information, while personal, is not particularly sensitive, as it is merely contact information, not medical or financial details, political affiliations, sexual relationships, or personnel information.”  (Puerto v. Superior Court (2008) 158 Cal.App.4th 1242, 1253.)  Disclosing individuals’ contact information “involves no revelation of personal or business secrets, intimate activities, or similar private information, and threatens no undue intrusion into one’s personal life, such as mass-marketing efforts or unsolicited sales pitches.”  (Pioneer Electronics (USA), Inc. v. Superior Court (2007) 40 Cal.4th 360, 373.)  Though defendant did not itself identify these personal trainers as witnesses, plaintiff establishes a reasonable basis that they may have admissible evidence.   

Evidence regarding the employees hired after plaintiff’s termination may support an inference that discriminatory intent was a substantial motivating factor in the decision to terminate plaintiff.  “Evidence that an employer replaced a plaintiff with a less qualified person outside the protected class can be evidence of pretext.”  (Mayes v. WinCo Holdings, Inc. (9th Cir. 2017) 846 F.3d 1274, 1282; accord Raad v. Fairbanks North Star Borough School Dist. (9th Cir. 2003) 323 F.3d 1185, 1197 [“the fact that an employer hired a far less qualified person than the plaintiff naturally gives rise to an inference that the non-discriminatory explanation offered by the employer is pretextual”].)  “Evidence that an employer treated ‘ “similarly situated” ’ employees outside the plaintiff’s protected class ‘ “more favorably” ’ is probative of the employer’s discriminatory or retaliatory intent.”  (Gupta v. Trustees of California State University (2019) 40 Cal.App.5th 510, 519.)  This interrogatory is reasonably calculated to lead to the discovery of admissible evidence to prove discriminatory intent or pretext.

Defendant’s objections to special interrogatory No. 41 are overruled.

Disposition   

Plaintiff Lajos “Lali” Hugyetz’s motion to compel further responses to special interrogatories is granted.  Defendant Equinox Holdings, Inc. is ordered to provide a further verified response without objections to special interrogatory, set two, No. 41, within 20 days.