Judge: Michael Shultz, Case: 23CMCV01841, Date: 2024-03-21 Tentative Ruling

Case Number: 23CMCV01841    Hearing Date: March 21, 2024    Dept: A

23CMCV01841 Sergio Armando Mayagoitia v. Prime Healthcare Services, et al.

Thursday, March 21, 2024, at 8:30 a.m.

 

[TENTATIVE] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES AND DOCUMENTS FROM DEFENDANT, PRIME HEALTHCARE SERVICES – ST. FRANCIS, LLC; REQUEST FOR SANCTIONS

I.        ARGUMENTS        

      The complaint alleges claims for negligence and elder abuse arising from injuries sustained by Plaintiff while in Defendants’ care. Plaintiff served request for production of documents on Defendant, Prime Healthcare Services – St. Francis, LLC (“Defendant ”).  Defendant served responses on January 26, 2024. The parties resolved some of their differences, but objections to some requests remain, all of which Plaintiff contends are without merit.

      In opposition, Defendant argues that the separate statement is misleading and defective. Defendant will respond to five of the remaining requests rendering the motion moot in part. The remaining responses to Plaintiff’s requests are appropriate.

      In reply, Plaintiff argues that Defendant is acting in bad faith by agreeing to supplement responses that Defendant promised on February 6, 2024. It is improper for Defendant to withhold documents based on attorney-client privilege or other basis without a privilege log.

 

II.      LEGAL STANDARDS

      A motion to compel further responses to a document request is proper where the moving party believes the responding party’s statement of compliance is incomplete, or a representation of inability to comply is inadequate, evasive, and/or an objection in the response is without merit or too general.  (Code Civ. Proc., § 2031.310.)

      The scope of discovery is liberally construed in favor of disclosure “as a matter of right unless statutory or public policy considerations clearly prohibit it.” (Greyhound Corp. v. Superior Court of Merced County (1961) 56 Cal. 2d 355, 377-378.) The broad scope of permissible discovery includes “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.” (Code Civ. Proc., § 2017.010.)

 

III.    DISCUSSION

      Initially at issue in this motion were requests 19, 21, 22, 25-27, 30-33, 37, and 38. Defendant impliedly concedes the propriety of requests 22, 25, 26, 30, and 38, since Defendant “intends” to provide verified responses before Plaintiff’s reply brief is due. (Opp. 2:1-3.) This leaves the following requests:

 

Request 19

      By agreeing to produce documents responsive to these requests, Defendant concedes the discoverability of the documents.  Plaintiff argues that production was not complete because Defendant failed to produce an “Inter-Rater Reliability Report” referenced in the policy and procedure manual. Defendant argues that the report is published yearly, and such a document is not prepared for “each shift” as Plaintiff requested.

      The response is not code compliant. Defendant is required to affirm that a diligent search and reasonable inquiry were made and specify the reason for its inability to comply, among other information.  

 

Request 21

      Plaintiff requests documents showing Defendant’s compliance with statutory requirements for nursing staff development for each wing, unit, or station of the hospital where decedent was a patient. Defendant agreed to comply with the request in full, but now contends the request is overbroad, vague, ambiguous, and irrelevant. Defendant contends that the request should be limited to training for the care of pressure sores.

      The limitation is too narrowly drawn. Plaintiff alleges that Defendant was negligent in developing patient care in general, including assessment, and providing nutrition, hygiene, planning, intervention, and evaluation. (Complaint, ¶ 25.) Defendant is ordered to provide documents responsive to the request.

      Defendant has not established with competent evidence that compliance with the document request will be unreasonably burdensome and oppressive. (West Pico Furniture Co. of Los Angeles v. Superior Court In and For Los Angeles County (1961) 56 Cal.2d 407, 417.)

An objection based upon burden requires evidence showing the quantum of work required. An objection based on oppression requires a showing of either an intent to create an unreasonable burden or that the “ultimate effect of the burden is incommensurate with the result sought.” (Id.)  Defendant relies on the conversations defense counsel had with “representatives” which is not competent to support the objection. (Munoz decl., ¶ 5.) Additionally, Defendant’s remedy is to move for a protective order, not refuse to respond or unilaterally impose limitations on Plaintiff’s discovery. Defendant did not support these objections with any evidence.  

 

Request 27, 31, 32

      Plaintiff requests documents of “organized in-service education program” for all patient care personnel in compliance with California Code of Regulations [“CC&R”] § 70214. Plaintiff also requests documents showing validation of patient care personnel including nurses. These requests are relevant to training practices and whether Defendant complied with regulatory training and competency validation under CC&R 70161.1.

      The requests are not overbroad, vague, or ambiguous, nor has Defendant sustained the objection based on burden and oppression with any evidence. Defendant also contends that Plaintiff is required to give notice to third parties whose records are being sought.  Defendant does not adequately explain whose privacy rights are implicated or why discovery should be denied. Plaintiff offered a stipulated protective order to protect against disclosure of personal information. (SS 23:26-28.)

      Finally, Defendant may not unilaterally determine that the documents are protected from discovery and refuse to comply. This is an issue for the Court to decide.

 

Request 33

      Plaintiff requests documents that Defendant relied on to ensure that hospital patient care personnel provided basic care services to decedent. Plaintiff alleges that staff providing care to decedent was insufficient and not adequately trained. Accordingly, Plaintiff is permitted to discover their identities as witnesses, and to establish whether they were competent and trained to provide care. Defendant’s claim of right to privacy is not supported by any evidence or substantive argument and does not warrant withholding documents. Moreover, Plaintiff agreed to sign a protective order. (SS 23:26-28.)

 

Request 37

      Plaintiff requests documents required by law to be maintained consisting of minutes of meetings of the governing body and medical staff during the time period in question and concerning operations where decedent was housed. As Plaintiff requests that patients’ names be redacted, Defendant’s objection based on privacy (although Defendant does not identify whose privacy rights are at issue) is without merit. Defendant cannot withhold documents based on its own determination of what is relevant to Plaintiff’s claim.

      Plaintiff is entitled to an award of sanctions for fees and costs incurred as Defendant has not shown substantial justification for its objections. (Code Civ. Proc., § 2031.310 subd (h).) The Court finds that counsel’s hourly rate of $1,000 per hour is excessive given the motion’s lack of complexity and lack of support other than what counsel believes his colleagues have been awarded. (Stephen M. Garcia decl., ¶ 13, fn. 2.) The Court also finds that additional time spent by a paralegal is duplicative of counsel’s work.

 

IV.    CONCLUSION

      Based on the foregoing, the Court GRANTS Plaintiff’s motion, and orders Defendant to provide further, verified, supplemental responses without objection and to produce documents responsive to requests 19, 21, 22, 25-27, 30-33, 37 and 38, within 10 days. The order applies to Requests 22, 25, 26, 30, and 38, to which Defendant subsequently agreed to respond since Plaintiff’s reply does not indicate that Defendant provided supplemental responses and production before the reply brief was due as Defendant represented in its opposition.

      The Court imposes monetary sanctions of $1,400 ($350 per hour x 4 hours to prepare motion, reply, and to appear). The Court also awards costs of $750 for court reporter expenses and $60 for a filing fee totaling $2,210 of against Defendant, Prime Healthcare Services – St. Francis, LLC, and its attorneys of record Kelly Trotter & Franzen, jointly and severally. Monetary sanctions are to be paid to Plaintiff’s counsel within 10 days.