Judge: Cherol J. Nellon, Case: 22STCV27684, Date: 2023-05-09 Tentative Ruling
Case Number: 22STCV27684 Hearing Date: May 9, 2023 Dept: 28
Motions to Compel Production of Documents from Non-Party
American Specialty Health Plans of California, Inc.
Having considered the moving papers, the Court rules as
follows. No opposing papers have been
filed.
BACKGROUND
On July 28, 2021, Plaintiff Lilian O’Connor (“Plaintiff”)
filed this action against Defendants Matthew Ross Delgado (“Delgado”), Malcolm
R. Mazer (“Mazer”), Twentieth Century Fox Television (“TCFT”), Twentieth
Century Fox Film Corporation (“TCFFC”), The Walt Disney Company (“Disney”) and
Antonio J. Garcia (“Garcia”) for negligence.
Trial is set for June 1, 2023.
PARTY’S REQUESTS
On March 13, 2023, Defendants TCFFC, Delgado, and Mazer (“Moving
Defendants”) filed a Motion to Compel Non-Party American Specialty Health Plans
of California, Inc. (“American Specialty”) to produce documents requested in a deposition
subpoena for production of business records served on November 23, 2022. Moving
Defendants also request sanctions in the amount of $4,684.20 pursuant to Code
of Civil Procedure section 2025.480(j).
No opposition has been filed.
LEGAL STANDARD
A party seeking discovery from a
person who is not a party to the action may obtain discovery by oral
deposition, written deposition, or deposition subpoena for production of
business records. (CCP § 2020.010.) A deposition subpoena may command the
attendance and testimony of the deponent, as well as the production of business
records, other documents, electronically stored information, and tangible
things. (CCP § 2020.020.) If a deponent disobeys a deposition subpoena, the
subpoenaing party may seek a court order compelling the nonparty to comply with
the subpoena. (CCP §§ 1987.1, 2025.480(b).)
A nonparty deponent may be subject
to contempt or monetary sanctions for disobeying a court order. (CCP §
2025.480(k).) Monetary sanctions are also available against nonparties who
“flout the discovery process.” (Temple Community Hospital v. Superior Court (1999)
20 Cal.4th 464, 476-477.)
A “written notice and all moving
papers supporting a motion to compel an answer to a deposition question or to
compel production of a document or tangible thing from a nonparty deponent must
be personally served on the nonparty deponent unless the nonparty deponent
agrees to accept service by mail¿or electronic service¿at an address¿or
electronic service address¿specified on the deposition record.” (Cal.
Rules of Court, Rule 3.1346.)
DISCUSSION
Deponent American Specialty was
identified as one of the medical facilities from which Plaintiff alleges to
have received medical treatment for injuries resulting from the accident.
(Hawkinson Decl., ¶ 3.) On November 23, 2022, the Deposition Subpoena was personally
served on American Specialty, requesting that American Specialty produce any
and all documents and records pertaining to Lilian O’Connor from January 2016
to present, including medical reports and billing records. (Hawkinson Decl., ¶
5; Beam Decl., Ex. A.) American Specialty was to respond by December 20, 2022.
Defendants state that they
contacted American Specialty’s office on no less than fourteen (14) separate
occasions between December 28, 2022 and March 8, 2023 requesting responses to
the subpoena. (Hawkinson Decl., ¶¶ 6-11; Ex. C, D; Beam Decl., ¶¶ 4, 6, Ex. B.)
As of the filing of this Motion, American Specialty has not responded to the
Deposition Subpoena, produced any responsive records, or responded to the
numerous attempts to make contact. (Hawkinson Decl., ¶ 11; Beam Decl., ¶ 6.)
Defendants argue that there
is good cause for the deposition subpoena because Plaintiff identified American
Specialty as a medical provider in her verified discovery responses and because
the subpoena requests medical records and bills, which are relevant to
Plaintiff’s damages.
The Court finds there is
good cause for the subpoena document requests. Further, Notice of this Motion
and Motion were properly served by personal service on American Specialty.
Further, the deposition subpoena was properly accompanied by proof of service
of a notice to the consumer. No objection to the deposition subpoena was
served.
Thus, the Court grants the
motion to compel production of documents
from non-party American Specialty Health Plans of California, Inc.
Defendants request recovery
of their costs and attorney fees spent on the filing of the motion, in addition
to $500 in sanctions set forth in the terms of the subpoena. (Hawkinson Decl.,
¶ 13.) Although a nonparty may be subject to contempt or monetary sanctions for
disobeying a court order or for “flouting” the discovery process, at this time,
American Specialty has not violated a court order and, even though they have
not responded to attempts to contact, there is no evidence they are “flouting”
the discovery process. Thus, the request for sanctions is denied.
CONCLUSION
The
motion to compel production of
documents from non-party American Specialty Health Plans of California, Inc.
is GRANTED.
American
Specialty Health Plans of California, Inc. is ordered to serve verified responses to the Deposition
Subpoena within twenty days of this ruling.
The
request for sanctions is DENIED.
Defendants
are ordered to give notice of this ruling.
Defendants are ordered to file
the proof of service of this ruling with the Court within five days.
The parties
are directed to the header of this tentative ruling for further instructions.