Judge: Joseph Lipner, Case: 20STCV40677, Date: 2025-02-18 Tentative Ruling



Case Number: 20STCV40677    Hearing Date: February 18, 2025    Dept: 72

 

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

SALVAROR BARRIOS, et al.,

 

                                  Plaintiffs,

 

         v.

 

 

HEALTHY START-EAST LA, INC., et al.,

 

                                  Defendants.

 

 Case No:  20STCV40677

 

 

 

 

 

 Hearing Date:  February 18, 2025

 Calendar Number:  2

 

 

 

Defendant City of Commerce (the “City”) separately moves to compel Plaintiff Salvador Barrios (“Salvador”) to serve further responses to the City’s Form Interrogatories, Set Two, No. 17.1 and the City’s Request for Admissions (“RFA”), Set One, Nos. 1-6, 8-11, 14, 17, 18, 21-26, 31, 46-57, and 70-113.

 

The City moves to compel Plaintiff Elena Barrios (“Elena”) to serve further responses to the City’s Form Interrogatories, Set Two, No. 17.1 and the City’s Request for Admissions, Set One, Nos. 1-6. (The Court uses the parties’ first names for the purpose of clarity only, and means no disrespect.

 

The Court DENIES the motions as they relate to RFA Nos. 56, 57, 73, and 75 served on Salvador.

 

The Court DENIES the motions as they relate to RFA Nos. 4 and 6 served on Elena.

 

The Court GRANTS the motions as they relate to the remaining discovery items at issue.  Plaintiffs shall provide full and complete responses in twenty days.

 

Background

 

This is a personal injury case resulting from an automobile collision. Plaintiffs bring this action against Defendants City of Commerce (the “City”); County of Los Angeles (the “County”); Karapet Dzheragyan (“Dzheragyan”); and Healthy Start-East LA (“Healthy Start”). The following facts are taken from the parties’ separate statements relating to the motion for summary judgment heard on February 27, 2024.

 

On February 25, 2020, Salvador was driving southbound on LaVerne Avenue and attempted to execute a left turn onto eastbound Telegraph Road. (Commerce City Undisputed Material Fact (“CC UMF”) 2.) Defendant Daniel Tercero Neri was driving westbound on Telegraph Road, and his vehicle struck Salvador’s. (CC UMF 2.)

 

The border between the City of Commerce and the County of Los Angeles runs along Telegraph Road. Specifically, the border sits a total of 45 feet north of the center line of Telegraph Road, including 10 feet from the north curb of Telegraph to the sidewalk. (CC UMF 7-10.) Thus, the entirety of Telegraph Road itself lies within the City’s jurisdiction.

 

The only traffic control at the intersection of LaVerne and Telegraph is a stop sign maintained by the County on the southbound side of LaVerne. (Plaintiffs’ Additional Material Fact in Opposition to the County’s Motion (“PLA AMF”) 80.)

 

There were no parking prohibitions on Telegraph Road at the intersection with LaVerne at the time of the collision. (Plaintiff’s Additional Material Fact in Opposition to the City’s Motion (“PC AMF”) 27.) In other words, the City permitted any vehicle to park on Telegraph Road up to the intersection with LaVerne, with no “red curb” section at or next to the corner of the two streets. Only the curb return itself (the portion of the curb that curves as it turns from Telegraph to LaVerne) was painted red. (PC AMF 14-17, 27.) At the time of the collision, a black SUV was legally parked along the northern curb of Telegraph Road, just east of where the red curb on the curb return ended. (PC AMF 16.) The SUV was parked approximately 27 feet east of the eastern curb line of LaVerne and 3 feet, 5 inches south of the north curb line of Telegraph. (PC AMF 16.)

 

Between 2010 and 2020, there were five vehicular collisions at the intersection, three of which involved a vehicle turning left from La Verne and a westbound vehicle on Telegraph Road. (PLA AMF 109.)

 

Plaintiffs provide evidence that, for a number of the intersections on Telegraph, the County proactively provided traffic signal maintenance for the entire intersection and billed the City for a portion of the costs. (PLA AMF 91-97.) The County only provided this maintenance for intersections that were signalized. The intersection of La Verne and Telegraph lies between two such intersections for which the County provided proactive maintenance. However, Plaintiffs do not provide evidence that the County provided proactive maintenance subject intersection itself. Additionally, from 2010 through 2020, the county had a contractual agreement with the City to provide public works services within the City, including traffic advising services, infrastructure design and construction, traffic law enforcement, street maintenance, and painting red curbs. (PLA AMF 83-90.) Plaintiffs do not provide evidence as to whether the County did any work relating to the City’s portion of the subject intersection as a result of this contract.

 

 Plaintiffs filed this action on October 22, 2020. The operative complaint is now the First Amended Complaint (“FAC”), which raises claims for (1) negligence; (2) negligent entrustment; (3) dangerous condition of public property under Government Code sections 830, 835, and 835.2; (4) negligent/reckless acts of public employees, agents, or contractors under Government Code sections 815.2, 815.4, and 820, et seq.; (5) general negligence; and (6) loss of consortium. Only the third, fourth, and sixth causes of action are alleged against Moving Defendants.

 

On August 26, 2024, the City served the discovery at issue in these motions.

 

On October 23, 2024, Plaintiffs served their responses to the discovery.

 

            The City filed each of these four motions on January 3, 2025. Salvador filed an opposition to each of the motions relating to him. Elena filed an opposition to each of the motions relating to her. The City filed two replies: a consolidated reply in support of the Salvador motions and a consolidated reply in support of the Elena motions.

 

Legal Standard

 

Interrogatories

 

Code of Civil Procedure section 2030.220, subdivision (a) requires that “[e]ach answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.” Pursuant to Code of Civil Procedure section 2030.300, a party may move to compel further responses to a form interrogatory if the other party’s answer is “evasive or incomplete.” The responding party has the burden of justifying the objections to the form and special interrogatories. (Coy v. Super. Ct. (1962) 58 Cal.2d 210, 220-221.) 

 

“The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. If a party then fails to obey an order compelling answers, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010).” (Code Civ. Proc. § 2030.290.

 

Requests for Admission

 

“(a) On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply:

(1) An answer to a particular request is evasive or incomplete.

(2) An objection to a particular request is without merit or too             general.”

 

(Code Civ. Proc. § 2033.290.)

 

“The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.” (Code Civ. Proc., § 2033.290(d).) 

 

Discussion

 

The Court has reviewed the parties’ papers and rules as follows on the requests at issue.

 

The Court makes special note of Plaintiffs’ objection that the City’s discovery seeks information on documents prepared for the purpose of a mediation that occurred between the parties and disclosed in the mediation.

 

“One of the fundamental ways the Legislature has sought to encourage mediation is by enacting several ‘mediation confidentiality provisions.’ ” (Rojas v. Superior Court (2004) 33 Cal.4th 407, 415.)

 

“(a) No evidence of anything said or any admission made for the purpose of, in the course of, or pursuant to, a mediation or a mediation consultation is admissible or subject to discovery, and disclosure of the evidence shall not be compelled, in any arbitration, administrative adjudication, civil action, or other noncriminal proceeding in which, pursuant to law, testimony can be compelled to be given.

 

(b) No writing, as defined in Section 250, that is prepared for

the purpose of, in the course of, or pursuant to, a mediation or a mediation consultation, is admissible or subject to discovery, and disclosure of the writing shall not be compelled, in any arbitration, administrative adjudication, civil action, or other noncriminal proceeding in which, pursuant to law, testimony can be compelled to be given.

 

(c) All communications, negotiations, or settlement discussions by and between participants in the course of a mediation or a mediation consultation shall remain confidential.”

 

(Evid. Code, § 1119.)

 

            “Evidence otherwise admissible or subject to discovery outside of a mediation or a mediation consultation shall not be or become inadmissible or protected from disclosure solely by reason of its introduction or use in a mediation or a mediation consultation.” (Ev. Code, § 1120, subd. (a).) “Likewise, otherwise admissible facts cannot be shielded from disclosure simply because they have been placed in confidential mediation documents.” (Lappe v. Superior Court (2014) 232 Cal.App.4th 774, 783.)

 

Plaintiffs contend that “[d]ocuments and information revealed in the voluntary mediation were and are confidential, inadmissible, and not subject to discovery in this or any civil action.” (See, e.g., Opposition to Salvador RFA Motion at p. 3:3-5.)

 

Plaintiffs object that Defendants seek information related to Plaintiff’s life care plan (“LCP”), which was prepared for the purpose of the mediation and revealed in the course of the mediation.

 

The Court agrees that the LCP document itself is protected. However, relevant facts relating Salvador’s medical needs after the collision remain admissible – and critical to Defendants’ ability to litigate issues of damages. The Court therefore finds that the mediation privilege is not a bar where the City seeks information that is contained in the LCP but not the LCP itself.

 

Requests for Admission – Salvador Barrios

 

The Court notes that the City’s separate statement is confusingly numbered. The Court uses the numberings in Plaintiffs’ separate statement.

 

RFA No. 1: Granted.

 

RFA No. 2: Granted.

 

RFA No. 3: Granted.

 

RFA No. 4: Granted.

 

RFA No. 5: Granted.

 

RFA No. 6: Granted.

 

RFA No. 8: Granted.

 

RFA No. 10: Granted.

 

RFA No. 11: Granted.

 

RFA No. 14: Granted.

 

RFA No. 17: Granted.

 

RFA No. 18: Granted.

 

RFA No. 21: Granted.

 

RFA No. 22: Granted.

 

RFA No. 23: Granted.

 

RFA No. 24: Granted.

 

RFA No. 25: Granted.

 

RFA No. 26: Granted.

 

RFA No. 31: Granted.

 

RFA No. 46: Granted.

 

RFA No. 47: Granted.

 

RFA No. 48: Granted.

 

RFA No. 49: Granted.

 

RFA No. 50: Granted.

 

RFA No. 51: Granted.

 

RFA No. 52: Granted.

 

RFA No. 53: Granted.

 

RFA No. 54: Granted.

 

RFA No. 55: Granted.

 

RFA No. 56: Denied.

 

RFA No. 57: Denied.

 

RFA No. 70: Granted.

 

RFA No. 71: Granted.

 

RFA No. 72: Granted.

 

RFA No. 73: Denied.

 

RFA No. 74: Granted.

 

RFA No. 75: Denied.

 

RFA No. 76: Granted.

 

RFA No. 77: Granted.

 

RFA No. 78: Granted.

 

RFA No. 79: Granted.

 

RFA No. 80: Granted.

 

RFA No. 81: Granted.

 

RFA No. 82: Granted.

 

RFA No. 83: Granted.

 

RFA No. 84: Granted.

 

RFA No. 85: Granted.

 

RFA No. 86: Granted.

 

RFA No. 87: Granted.

 

RFA No. 88: Granted.

 

RFA No. 89: Granted.

 

RFA No. 90: Granted.

 

RFA No. 91: Granted.

 

RFA No. 92: Granted.

 

RFA No. 93: Granted.

 

RFA No. 94: Granted.

 

RFA No. 95: Granted.

 

RFA No. 96: Granted.

 

RFA No. 97: Granted.

 

RFA No. 98: Granted.

 

RFA No. 99: Granted.

 

RFA No. 100: Granted.

 

RFA No. 101: Granted.

 

RFA No. 102: Granted.

 

RFA No. 103: Granted.

 

RFA No. 104: Granted.

 

RFA No. 105: Granted.

 

RFA No. 106: Granted.

 

RFA No. 107: Granted.

 

RFA No. 108: Granted.

 

RFA No. 109: Granted.

 

RFA No. 110: Granted.

 

RFA No. 111: Granted.

 

RFA No. 112: Granted.

 

RFA No. 113: Granted.

 

 

Interrogatories – Salvador Barrios

 

            Form Interrogatory No. 17.1: Granted.

 

 

Requests for Admission – Elena Barrios

 

RFA No. 1: Granted.

 

RFA No. 2: Granted.

 

RFA No. 3: Granted.

 

RFA No. 4: Denied.

 

RFA No. 5: Granted.

 

RFA No. 6: Denied.

 

 

 

Interrogatories – Elena Barrios

 

            Form Interrogatory No. 17.1: Granted.