Judge: Lee S. Arian, Case: 22STCV38367, Date: 2023-11-09 Tentative Ruling
Case Number: 22STCV38367 Hearing Date: November 9, 2023 Dept: 27
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL
DISTRICT
On December 9,
2022, Plaintiff Nasir Amaya, a minor, by and through his guardian ad litem, Gabby
Torres, filed this action against Defendant Los Angeles Unified School
District. The operative complaint is the
Second Amended Complaint alleging a single claim for Dangerous Condition on
Public Property (Gov. C. §§830, 835).
On September
16, 2022, Plaintiff Nasir was injured during recess at Union Elementary School
of Defendant Los Angeles Unified School District. Plaintiff Nasir’s teeth became entangled in a
volleyball net that was missing the outer protective nylon lining. As a result, Nasir’s teeth were pulled out of
his mouth when he fell. Defendant LAUSD
failed to retrieve Nasir’s teeth after the accident.
On April 10,
2023, Plaintiff served Defendant LAUSD with Form Interrogatories (Set One). On June 5, 2023, Defendant LAUSD served
responses.
On August 15,
2023, Plaintiff filed the instant motion to compel further responses to Form
Interrogatories 12.1, 12.2 and 12.3 on August 15, 2023.
On September
12, 2023, parties participated in an informal discovery conference with the
Court. The Court noted that LAUSD
required a court order to release the minor student witnesses’ contact
information. The Court indicated that Plaintiff could proceed with a motion to
compel.
Defendant
LAUSD filed an opposition on October 13, 2023.
Plaintiff filed a reply on October 16, 2023.
LEGAL
STANDARD — Compel Further Responses
CCP §2030.300
(a) On receipt of a response to interrogatories, the propounding
party may move for an order compelling a further response if the propounding
party deems that any of the following apply:
(1) An answer
to a particular interrogatory is evasive or incomplete.
(2) An
exercise of the option to produce documents under Section 2030.230 is
unwarranted or the required specification of those documents is inadequate.
(3) An
objection to an interrogatory is without merit or too general.
(b)(1) A motion under subdivision (a) shall be accompanied
by a meet and confer declaration under Section 2016.040.
(2) In lieu of a separate statement required under the
California Rules of Court, the court may allow the moving party to submit a
concise outline of the discovery request and each response in dispute.
(c) Unless notice of this motion is given within 45 days of
the service of the verified response, or any supplemental verified response, or
on or before any specific later date to which the propounding party and the
responding party have agreed in writing, the propounding party waives any right
to compel a further response to the interrogatories.
(d) 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 further 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.
(e) If a party then fails to obey an order compelling
further response to interrogatories, 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).
If a timely
motion to compel has been filed, the burden is on the responding party to
justify any objection or failure to fully answer the interrogatories and RFAs.
(Coy v. Sup.Ct. (Wolcher) (1962) 58 Cal.2d 210, 220–221; Fairmont
Ins. Co. v. Sup.Ct. (Stendell) (2000) 22 Cal.4th 245, 255.)
ANALYSIS
Plaintiff
seeks to compel further responses to Form Interrogatories 12.1, 12.2 and 12.3,
which seek information related to witnesses who saw the incident, have
knowledge of the incident, were interviewed about the incident and gave a
statement about the incident. Defendant
LAUSD objected to providing the
information sought because the witnesses are minor students protected under the
Family Educational Rights and Privacy Act (20 USC §1232g), HIPAA, the
California Education Code, LAUSD Policy Bulletin 1077.1 and other Federal and
State statutes. Defendant LAUSD concedes
that a court order would allow it to provide the witness information with the
exception of phone numbers.
Pursuant to 20
USC §1232g(b)(2)(B), Defendant LAUSD may release educational records and
identifying information of the student witnesses in compliance with a judicial
order, “upon condition that parents and the students are notified of such
orders…in advance of the compliance therewith by the education institution or
agency…” (20 USC §1232g(b)(2)(B).) Similarly,
pursuant to Education Code §49077(a), Defendant LAUSD “shall” furnish
information concerning a pupil “in compliance with a court order….” LAUSD must “make a reasonable effort to
notify the pupil’s parent or legal guardian and the pupil in advance of
compliance…in the case of compliance with a court order, if lawfully possible
within the requirements of the order.”
(Educ. C. §49077(a).) In
addition, LAUSD “shall make a reasonable effort to enter into an agreement with
the entity that obtained the court order…requiring that the pupil contact
information be maintained in a confidential manner.” (Educ. C. §49077(b).)
Defendant’s
objection based on Family Educational Rights and Privacy Act (20 USC §1232g),
HIPAA, the California Education Code, LAUSD Policy Bulletin 1077.1 and other
Federal and State statutes is overruled.
The Court orders that Defendant provide further response to Form
Interrogatories 12.1-12.3 and provide the witness information requested
thereunder within 20 days. Defendant
should comply with the conditions for disclosure set forth under 20 USC
§1232b(g)(2)(B) and Education Code §49077.
Plaintiff
withdrew the request for sanctions on reply.
No sanctions are therefore at issue.
CONCLUSION
Plaintiff’s
Motion to Compel Further Responses to Form Interrogatories 12.1-12.3 is
GRANTED. Defendant LAUSD to provide
further responses within 20 days subject to the requirements under 20 USC
§1232b(g)(2)(B) and Education Code §49077.