Judge: Gregory Keosian, Case: 21STCV34207, Date: 2023-02-21 Tentative Ruling

Case Number: 21STCV34207    Hearing Date: February 21, 2023    Dept: 61

Plaintiff Newage Garden Grove, LLC’s Motion to Compel Further Responses to Special Interrogatories, Set One, from Defendant Titanium Group (III), LLC, is GRANTED. Code compliant responses to be served within 30 days. Sanctions are DENIED.

 

I.                   MOTION TO COMPEL FURTHER – INTERROGATORIES

 

“Any party may obtain discovery . . . by propounding to any other party to the action written interrogatories to be answered under oath.”  (Code Civ. Proc., § 2030.010(a).) If a propounding party is not satisfied with the response served by a responding party, the former may move the court to compel further interrogatory responses.  (Code Civ. Proc., § 2030.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 403.)  The propounding party must demonstrate that the responses were incomplete, inadequate or evasive, or that the responding party asserted objections that are either without merit or too general.  (Code Civ. Proc., § 2030.300(a)(1)–(3); Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 403.)

This motion arises from the court’s prior order of June 13, 2022, granting Defendant Titanium Group (III) LLC’s (Defendant) motions to compel further production of documents against Plaintiff Newage Garden Grove, LLC (Plaintiff). Pursuant to this order, only July 11, 2022, an inspection of documents was held on Plaintiff’s property, conducted by Defendant’s agents and overseen by Plaintiff’s agents. (Miller Decl. ¶¶ 9–10.) Following this inspection, Plaintiff promulgated the special interrogatories at issue here, asking Defendant in various ways to identify the documents it scanned, photographed, or otherwise reproduced during its July 11 2022 inspection. (Separate Statement.) Defendant objected to these interrogatories, reasoning that the documents it copied are protected by the work-product doctrine. (Ibid.)

 

An attorney’s selection of what documents to copy from a given collection may fall within the ambit of the work-product doctrine’s protections. The statute defining the work-product doctrine gives absolute protection to writings that reflect “an attorney’s impressions, conclusions, opinions, or legal research or theories,” and gives qualified protection to other attorney “work product.” (Code Civ. Proc. § 2018.030.) In certain circumstances,  disclosing a list of witnesses from whom an attorney has taken recorded statements may, in some instances, reveal the attorney's impressions of the case.” (Coito v. Superior Court (2012) 54 Cal.4th 480, 501.) Disclosure of documents reproduced from a given collection may similarly reveal attorney impressions or theories, if the circumstances of the case are such as to make the particular selection suggestive of a given attorney opinion. Although Plaintiff argues that Defendant’s counsel did not personally select the documents — they were instead selected by Defendant’s own employees — the work-product doctrine preserves from disclosure not simply the work-product of the attorney themselves, but also the attorney’s agents or investigators. (Coito v. Superior Court (2012) 54 Cal.4th 480, 495.)

However, the circumstances of document selection in this case were peculiar, in that they were not conducted in confidence, as most work product is, but rather in full view of Plaintiff’s agents. Defendant’s interrogatory response stated, in its objections, that Plaintiff “had multiple people in the room” during the inspection, “watching [Defendant] and every movement then taken, i.e. watched every folder that was taken out of a box, every folder that was opened, every page that was handled, and every page that was selected for copying or not.” (Separate Statement at p. 4.) Defendant’s counsel confirms in opposition that Plaintiff had someone in the inspection room at all times, “watching every movement of our consultants always.” (Miller Decl. ¶ 10.) It is doubtful that the work product doctrine would preserve an attorney’s selection of documents in such a situation, as the doctrine is a rule against discoverability and disclosure, which may be waived by an intentional disclosure inconsistent with the privilege, particularly to one who “has no interest in maintaining the confidentiality ... of a significant part of the work product.” (Laguna Beach County Water Dist. v. Superior Court (2004) 124 Cal.App.4th 1453, 1459.) When the information to be protected by the privilege was itself obtained in full view of the adverse party, that privilege would have been waived if it ever applied at all.

 

Such is the appropriate determination here. Defendant’s selection of documents, though arguably subject to work-product protection if conducted in confidence, was here conducted in full view of Plaintiff’s agents. As such, the doctrine does not apply.

 

The motion to compel further responses is therefore GRANTED.

 

II.                SANCTIONS

Statute provides that the court shall impose sanctions upon a party who unsuccessfully makes or opposes a motion to compel further response to interrogatories or requests for production of documents, absent substantial justification otherwise. (Code Civ. Proc. §§ 2030.300, subd. (d).)

 

Plaintiff seeks sanctions in the amount of $2,951.65, representing 6.8 hours of attorney work at $425 per hour, plus a $61.65 filing fee. Sanctions are DENIED, as the motion was brought with substantial justification