Judge: Melvin D. Sandvig, Case: 24CHCV01868, Date: 2024-09-18 Tentative Ruling

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Case Number: 24CHCV01868    Hearing Date: September 18, 2024    Dept: F47

Dept. F47

Date: 9/18/24

Case 24CHCV01868

 

MOTION TO QUASH SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS

 

Motion filed on 7/12/24.

 

MOVING PARTY: Plaintiff Melina Angulo

RESPONDING PARTY: Defendants Aerospace Dynamics International, Inc. and Precision Castparts Corp.

NOTICE: ok

 

RELIEF REQUESTED: An order quashing Defendants Aerospace Dynamics International, Inc.’s and Precision Castparts Corp.’s (collectively, Defendants) Subpoena for Production of Records to Pentair Water Pool and Spa, Inc.  Alternatively, Plaintiff requests a protective order to where production is limited to records pertaining to Plaintiff’s applications for employment, reasons for leaving, and pay/benefits records.

 

Additionally, Plaintiff requests sanctions against Defendants and their counsel, Ethan W. Smith of Bryan Cave Leighton Paisner LLP, jointly and severally, in the amount of $4,125.00.

 

RULING: The request to quash the entire Subpoena for Production of Records is denied as is the alternative request for a protective order.  Alternatively, the Court modifies the subpoena as set forth below.  Both Plaintiff’s and Defendants’ requests for sanctions are denied.    

 

SUMMARY OF FACTS & PROCEDURAL HISTORY

 

This action arises out of the termination of Plaintiff Melina Angulo’s (Plaintiff) employment with Defendant Aerospace Dynamics International, Inc. (ADI).  In August 2023, Plaintiff applied to work for ADI and was hired as a Supply Chain Manager with a starting date of 10/2/23.  (See Trujillo Decl. ¶¶2-3).  Soon after beginning work, ADI placed Plaintiff on a Performance Improvement Plan (PIP).  (Id. ¶3).  ADI terminated Plaintiff’s employment on 11/2/23.  Id.

 

On 5/15/24, Plaintiff filed this action against ADI and Defendant Precision Castparts Corp. (PCC) alleging causes of action for: (1) Marital Status Discrimination; (2) Sex Discrimination; (3) Marital Status and/or Sex Discrimination; (4) Marital Status Harassment, Hostile Work Environment; (5) Sex Harassment, Hostile Work Environment; (6) Marital Status and/or Sex Harassment, Hostile Work Environment; (7) Retaliation; (8) Failure to Prevent Discrimination, Harassment and Retaliation; and (9) Wrongful Termination in Violation of Public Policy.  Plaintiff seeks damages based on past and future lost income and benefits.  (Complaint, Prayer ¶3). 

 

On 7/1/24, ADI and PCC (collectively, Defendants) filed their answer to the complaint and a cross-complaint against Plaintiff for: (1) Breach of Employment Contract, (2) Breach of Implied Covenant of Good Faith and Fair Dealing and (3) Unjust Enrichment.  Defendants’ affirmative defenses include Plaintiff’s failure to mitigate damages, failure to exercise due diligence in her efforts to mitigate damages, unclean hands, waiver and offset.  (Answer ¶¶18, 32, 35, 37).

 

On 6/7/24, Defendants served Plaintiff with notice that they would serving a Subpoena for Production of Business Records (Subpoena) on Plaintiff’s former employer, Pentair Water Pool and Spa, Inc. (Pentair).  (See Bell Decl., ¶2, Ex.A).  The Subpoena seeks the following documents: (1) Plaintiff’s application for employment at Pentair; (2) Any resume for Plaintiff that is in Pentair’s possession; (3) The job description for the position(s) that Plaintiff held while employed by Pentair; (4) All documents regarding, referencing, relating to, and/or pertaining to any discipline that Plaintiff received while employed at Pentair; (5) All documents regarding, referencing, relating to, and/or pertaining to the reason that Plaintiff no longer works for Pentair; (6) All documents stating the dates during which Plaintiff was employed at Pentair; (7) All itemized wage statements issued to Plaintiff during her employment with Pentair; and (8) Documents sufficient to show the amount of wages paid to Plaintiff during each pay period that she worked for Pentair.

 

After meet and confer efforts failed to resolve the issues Plaintiff had with the Subpoena, on 7/12/24, Plaintiff filed and served the instant motion seeking an order quashing Defendants’ Subpoena to Pentair.  Alternatively, Plaintiff requests a protective order to where production is limited to records pertaining to Plaintiff’s applications for employment, reasons for leaving, and pay/benefits records.  Additionally, Plaintiff requests sanctions against Defendants and their counsel, Ethan W. Smith of Bryan Cave Leighton Paisner LLP, jointly and severally, in the amount of $4,125.00.

 

On 8/21/24, the Court signed a Protective Order pursuant to the stipulation of the parties whereby Plaintiff has the right to designate as confidential any documents that she believes in good faith contain non-public information that is entitled to confidential treatment. 

 

Defendants have opposed the motion and Plaintiff has filed a reply to the opposition.

 

ANALYSIS

 

A party may make a motion to quash, modify or direct compliance with a subpoena for the production of records.  See CCP 1987.1; CCP 2025.420(b); Monarch Healthcare (2000) 78 CA4th 1282, 1287.  The Court has discretion to make any other appropriate order to protect the parties (or the witnesses) from unreasonable or oppressive demands, including unreasonable violations of an individual’s right of privacy.  CCP 1987.1.

 

The right to discovery is broad allowing a party to “obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.”  CCP 2017.010; See also Williams (2017) 3 C5th 531, 541-542.

 

Employees have a right to privacy in their personnel records.  Board of Trustees (1981) 119 CA3d 516; Harding Lawson Associates (1992) 10 CA4th 7.  However, an individual’s right to privacy is not absolute.  See Lantz (1994) 28 CA4th 1839, 1854.  For example, where a person files a lawsuit, his/her right to privacy is waived with regard to matters directly relevant to the issues in the action and essential to the fair resolution of the lawsuit  See Lantz, supra; Loder (1997) 14 C4th 846; Davis (1992) 7 CA4th 1008, 1014.

 

The disclosure of employment records is not unusual in cases such as this.  See Ragge (C.D. Cal. 1995) 165 F.R.D. 601, 604.  Plaintiff’s job description and dates of employment at Pentair are directly relevant to Plaintiff’s alleged damages and Defendants’ defenses in this action.  The job description for the position Plaintiff held at Pentair is not private because such information was  prepared by Pentair to describe the duties of the position that Plaintiff held.  Plaintiff also has no privacy interest in the dates of her employment because she voluntarily disclosed the dates to  ADI in applying for the position which is the subject of this action.  (Trujillo Decl. ¶2, Ex. A.); See Leibert (1995) 32 CA4th 1693, 1701-1702.

 

Additionally, to the extent Plaintiff seeks damages related to lost income, evidence concerning her employers, dates of employment, and job duties prior to her employment with ADI is directly relevant.  This information is also directly relevant to Plaintiff’s duty and efforts to mitigate her damages.  The documents Defendants seek in the Subpoena do not relate to Plaintiff’s sexual, health, or financial matters; therefore, they are unlikely to be confidential in nature.  See Ragge, supra at 604. 

 

Even if any sensitive personal information is included in job description or Plaintiff’s dates of employment, as noted above, a protective order has already been entered in this case “to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights… .”  (Smith Decl., Ex.D); See Ragge, supra at 605.

 

Documents regarding Plaintiff’s job description and dates of employment at Pentair are also relevant to Plaintiff’s credibility to the extent that the information may contradict information provided by Plaintiff through written discovery and deposition testimony.  See Ragge, supra at 604. 

 

However, the Court finds that the wording of Category 6, “All DOCUMENTS stating the dates during which [Plaintiff] was employed by PENTAIR,” is overbroad as it could be construed to include all documents in Plaintiff’s personnel file if they are dated during Plaintiff’s employment.  Therefore, the Court modifies Category 6 to: “All DOCUMENTS which list the dates of ANGULO was employed by PENTAIR.  This category does not require the production of all documents which are dated during Plaintiff’s employment with Pentair.”   

 

The Court finds that Plaintiff waived any privacy right in her application and resume provided to Pentair.  The information contained in these documents bears on Plaintiff’s claimed damages and Plaintiff’s efforts to mitigate same.  Again, to the extent any of the information contradicts information provided by Plaintiff in discovery it is relevant to Plaintiff’s credibility.   Also, as noted above, to the extent any sensitive personal information is included in these documents, the protective order already in place is sufficient to protect Plaintiff’s privacy rights. 

 

Documents regarding Plaintiff’s disciplinary records, reasons for termination and wage records are directly relevant to Plaintiff’s qualifications and performance for her position at ADI.  Additionally, such documents are also relevant to Defendants’ defenses and assessment of damages.  These records may also be relevant to Plaintiff’s credibility as she claims that there are no disciplinary records to discover.  (Smith Decl., Ex.G, p.22:6-15).  If Plaintiff’s statement is true, no disciplinary records will be produced rendering the privacy issue moot as to such records.  As such, the production of such documents is necessary for the fair resolution of this lawsuit.  See Starr 2017 WL 1400114 at *3; Davis 2017 WL 11633478, at *7. 

 

Documents from past employers regarding Plaintiff’s work history and job skills are also necessary for Defendants’ experts’ evaluation of Plaintiff’s mitigation efforts and loss of earnings claim.  See Crawford 2023 WL 6130416; Peterson 2023 WL 9116980.

 

As noted above, the documents sought via the subject subpoena may confirm or contradict Plaintiff’s discovery responses.  Similarly, the information may also confirm or contradict Plaintiff’s anticipated trial testimony.  Defendants are entitled to obtain independent verification of Plaintiff’s testimony where possible to assist the jury in determining Plaintiff’s credibility.  See Evidence Code 780.

 

Both Plaintiff’s and Defendants’ requests for sanctions are denied.  CCP 1987.1(a) provides:

 

“Except as specified in subdivision (c), in making an order pursuant to motion made under subdivision (c) of Section 1987 or under Section 1987.1, the court may in its discretion award the amount of the reasonable expenses incurred in making or opposing the motion, including reasonable attorney's fees, if the court finds the motion was made or opposed in bad faith or without substantial justification or that one or more of the requirements of the subpoena was oppressive.”

 

The Court does not find that either Plaintiff or Defendants acted in bad faith.  While the Court is not quashing the subpoena in its entirety as requested, as noted above, the Court is modifying  Category 6 of the documents sought.  As such, the Court finds that Plaintiff made the motion with substantial justification.

 

CONCLUSION 

 

The request to quash the entire Subpoena for Production of Records is denied as is the alternative request for a protective order.  Alternatively, the Court modifies Category 6 of the subpoena to require the production of: “All DOCUMENTS which list the dates of ANGULO was employed by PENTAIR.  This category does not require the production of all documents which are dated during Plaintiff’s employment with Pentair.”  

 

Both Plaintiff’s and Defendants’ requests for sanctions are denied.