Judge: Erick L. Larsh, Case: 2022-01245628, Date: 2023-05-18 Tentative Ruling

Plaintiff’s motions to compel Defendant Elizabeth Grant’s further responses to form interrogatories, general, set one, and Defendant Children’s Hospital of Orange County’s (CHOC) further responses to form interrogatories, general, set one, form interrogatories, employment, set one, and special interrogatories, set one, are GRANTED as to Grant and CHOC’s responses to form interrogatories, general, nos. 12.2, and CHOC’s responses to form interrogatories, employment, nos. 215.1 and 215.2, and otherwise DENIED.

Defendants have not waived the attorney-client privilege or work product protection as to counsel’s interviews, investigations, reports, and related information that took place after litigation commenced. (Nacht & Lewis Architects, Inc. v. Superior Court (1996) 47 Cal.App.4th 214, 217).

However, both Grant and CHOC’s supplemental responses to form interrogatory, general, no. 12.2, and CHOC’s supplemental responses to form interrogatories, employment, nos. 215.1 and 215.2, fail to answer whether any such responsive interviews or recorded statements (including non-privileged interviews and statements) exist. Defendants are to provide supplemental responses to these interrogatories within 30 days. All other requested relief is DENIED.

Both parties’ requests for sanctions are DENIED. (See Mattco Valley Forge v. Arthur Young & Co. (1990) 223 Cal.App.3d 1429, 1437 [court’s discretion to deny sanctions upon mixed results].)

Plaintiff shall give notice.