Judge: Lee W. Tsao, Case: 23NWCV00003, Date: 2024-05-14 Tentative Ruling

Case Number: 23NWCV00003    Hearing Date: May 14, 2024    Dept: C

Gertrud Jacoby, By and Through Her Successor in Interest, Brian Jacoby, et al. vs La Mirada Post Acute LLC, et al.

Case No.: 23NWCV00003

Hearing Date: May 14, 2024 @ 9:30 AM

 

#3

Tentative Ruling

Plaintiff’s Motion to Compel Further Responses to Special Interrogatories (Set One) is GRANTED in part, subject to the limitations set forth below.  No sanctions are imposed. 

Plaintiff to give notice.

 

Background

This is a wrongful death action. Plaintiff Gertrud Jacoby (“Plaintiff”) was a resident at Defendant La Mirada Post Acute LLC’s (“Defendant”) skilled nursing facility.  On January 3, 2023, Plaintiff and Successor in Interest Brain Jacoby brought this action against Defendant alleging the following causes of action: (1) Elder Abuse and Neglect and (2) Violation of Residents’ Rights, (3) Negligence, and (4) Wrongful Death.  The Complaint alleges that Defendant’s “consistent failure to turn and reposition PLAINTIFF, keep her clean and dry, and ensure she received adequate hydration and nutrition … led to the development of her significant skin injuries and ultimately her death.” (Complaint, ¶ 41.) 

On April 17, 2023, Plaintiff propounded Special Interrogatories, Set One, upon Defendant. (Voas Decl., ¶ 2.) On June 16, 2023, after Plaintiff granted extensions of time to respond, Defendant served unverified responses to Plaintiff’s Special Interrogatories, Set One. (Voas Decl., ¶ 3.) Over the following few months, the parties met and conferred on outstanding discovery matters. (Voas Decl., ¶ 5.) On January 2, 2024, Defendant served a verification for Special Interrogatories, Set One. (Ibid.) On January 25, 2024, the parties again met and conferred on Special Interrogatories 13, 14, and 15, and confirmed that Defendant intended to stand by its objections to the interrogatories. (Voas Decl., ¶ 6, Ex. 2.)

 

Plaintiff’s Special Interrogatories, Set One, Nos. 13, 14, and 15 request the identities of Plaintiff’s roommates and the identities of “Responsible Parties” and “Resident Representatives” for all residents at Defendant’s facility during Plaintiff’s approximate five-week residency.

·        Special Interrogatory No. 13: Please IDENTIFY all roommates of PLAINTIFF at the FACILITY during the RELEVANT TIME PERIOD.

·        Special Interrogatory No. 14:  Please IDENTIFY the RESPONSIBLE PARTY for all residents of the FACILITY during the RELEVANT TIME PERIOD.

·        Special Interrogatory No. 15: Please IDENTIFY the RESIDENT REPRESENTATIVE for all residents of the FACILITY during the RELEVANT TIME PERIOD.

Defendant objects to the special interrogatories as overbroad, burdensome, harassing, and irrelevant.  Defendant also objects on the grounds that the requests violate the privacy rights of third parties under the Federal Health Insurance Portability and Accountability Act (“HIPAA”) and California’s Confidentiality of Medical Information Act (“CMIA”). 

Plaintiff argues that there is no bar to disclosure because the interrogatories only seek the identity of certain individuals, not their medical or health information within the meaning of the HIPPA or CMIA. 

 

Legal Standard

 

“The party asserting a privacy right must establish a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious.” (Williams v. Superior Court (2017) 3 Cal.5th 531, 552 (citing Hill v. National Collegiate Athletic Assn. (1994) 7 Cal.4th 1, 35).) “The party seeking information may raise in response whatever legitimate and important countervailing interests disclosure serves, while the party seeking protection may identify feasible alternatives that serve the same interests or protective measures that would diminish the loss of privacy. A court must then balance these competing considerations. (Ibid.)

 

Discussion

 

Plaintiff’s Special Interrogatories, Set One, Nos. 13, 14, and 15, request the identities of Plaintiff’s roommates and the identities of “Responsible Parties” and “Resident Representatives” of all residents at Defendant’s facility during Plaintiff’s approximate five-week residency. 

 

HIPAA provides the following definition of “health information”:   

 

Health information means “any information, whether oral or recorded in any form or medium, that:  

 

1.    Is created or received by a health care provider, health plan, public health authority, employer, life insurer, school or university, or health care clearinghouse; and  

2.    Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual.”  

 

45 C.F.R. §160.103 (italics added). 

 

With respect to Special Interrogatory No. 13, the Court finds that patients at Defendant’s facility have a legally protected privacy interest and a reasonable expectation of privacy in their identities because such information was received by a health care provider and relates to the provision of health care to an individual. 

 

A party asserting a privacy right must also demonstrate a serious invasion of privacy. (Williams, supra, at 552.) With respect to Special Interrogatory No. 13, Plaintiff only seeks the identity of Plaintiff’s roommates; Plaintiff does not seek their medical information.  The Court determines that disclosure of the identity of Plaintiff’s roommates is necessary to discover potential witnesses to Plaintiff’s treatment at Defendant’s facility in the time period leading up to Plaintiff’s death.  As long as the roommates receive notice of the lawsuit, assurance they are under no obligation to talk to Plaintiff’s Counsel, and an opportunity to opt out of disclosure, revealing their identities entails no serious invasion of privacy. (Id., at 555.) The Court orders Defendant to make diligent efforts to obtain updated contact information for Plaintiff’s roommates and to provide them with actual notice, consistent with the language in Williams cited above, permitting them to opt out of disclosure of their information.  The opt-in procedure proposed by Defendant is disfavored. (Ibid.)

 

Accordingly, Plaintiff’s motion to compel further response to Special Interrogatory No. 13 is GRANTED, subject to the notice procedures set forth above. 

 

With respect to Special Interrogatories Nos. 14 and 15, Plaintiff requests the identities of “Responsible Parties” and “Resident Representatives” for all residents at Defendant’s facility during the relevant time period.  Plaintiff argues that these individuals are likely to have factual information which could support Plaintiff’s allegations that the facility had a pattern of understaffing, undertraining staff, and underfunding.  Defendant argues that responding to the requests would be unduly burdensome because Defendant’s facility has 142 beds.  Plaintiff’s motion to compel further responses to Special Interrogatories Nos. 14 and 15 is GRANTED in part.  Defendant is ordered to disclose the identities of responsible parties/resident representatives for Plaintiff’s roommates during the relevant time period.  Disclosure is subject to the notice procedures set forth above.  Defendant is not ordered to disclose the identities of responsible parties/resident representatives for residents in other patient rooms.  The Court determines that the probative value of such information is speculative, and production would be unduly burdensome. 

 

Accordingly, Plaintiff’s Motion to Compel Further Responses to Special Interrogatories (Set One) is GRANTED in part, subject to the limitations set forth above.  Defendant shall provide further responses within 60 days unless the parties agree to a longer period of time. 

 

Sanctions

 

Plaintiff requests sanctions in the amount of $1,400.00.

 

The court shall impose a monetary sanction against the party who unsuccessfully makes or opposes a motion to compel further responses to interrogatories or demand for production of documents unless the party subject to the sanction acted with substantial justification or the sanction would otherwise be unjust. (Code of Civ. Proc., §§ 2030.300, subd. (d), 2031.310, subd. (h), 2033.290, subd. (d).)

 

Given the limitations imposed upon the Plaintiff’s discovery requests, the Court finds that Defendant acted with substantial justification in opposing the motion. 

 

Accordingly, the request for sanctions is DENIED.