Judge: Nick A. Dourbetas, Case: 2020-01149675, Date: 2022-09-02 Tentative Ruling

Motion for Protective Order

Defendant Hilton Management, LLC’s motion for protective order regarding the deposition of its Person Most Qualified [PMQ] is DENIED.  (Code Civ. Proc., § 2025.420 [authorizing protective order].) 

Moving party has not shown good cause for the requested protective order.  Code Civ. Proc., § 2025.230, governing PMQ depositions, requires the deponent to produce the person most “qualified to testify on its behalf as to those matters to the extent of any information known or reasonably available to the deponent.”  Whether any of the challenged topics govern matters known or reasonably available to the deponent, is reasonably calculated to lead to the discovery of admissible evidence (Code Civ. Proc., § 2017.010), particularly as moving party has a pending motion for summary judgment involving some of the challenged topics.  (See Standefer Decl. in support of motion for summary judgment, also submitted as an exhibit to the instant motion.)

Plaintiff shall give notice.