Judge: Serena R. Murillo, Case: 20STCV42084, Date: 2023-03-06 Tentative Ruling

Case Number: 20STCV42084    Hearing Date: March 6, 2023    Dept: 29

TENTATIVE

Plaintiff Sindy Carolina Mejia Climaco’s motion to quash deposition subpoena is GRANTED. Plaintiff’s request for sanctions is GRANTED. Defendant Jaclyn Salvatore De Rose and attorney of record, Derick Hovsepian, are ordered to pay $1,022 in sanctions, jointly and severally, within 30 days of this order.

 

Legal Standard

 

When a subpoena has been issued requiring the attendance of a witness or the production of documents, electronically stored information, or other things before a court or at the taking of a deposition, the court, upon motion “reasonably made” by the party, the witness, or any consumer whose personal records are sought, or upon the court's own motion after giving counsel notice and an opportunity to be heard, may make an order quashing the subpoena entirely, modifying it, or directing compliance with it upon those terms and conditions as the court may specify.  (See Code Civ. Proc. § 1987.1; Southern Pac. Co. v. Superior Court (1940) 15 Cal.2d 206.) 

 

The court can make an order quashing or modifying a subpoena as necessary to protect a person from “unreasonable or oppressive demands, including unreasonable violations of the right of privacy of the person.”  (Code Civ. Proc., § 1987.1, subd. (a).)

 

For discovery purposes, information is relevant if it might reasonably assist a party in evaluating the case, preparing for trial, or facilitating settlement.  (Gonzalez v. Superior Court (1995) 33 Cal.App.4th 1539, 1546.)  Generally, all unprivileged information that is relevant to the subject matter of the action is discoverable if it would itself be admissible evidence at trial or if it appears reasonably calculated to lead to the discovery of admissible evidence.  (Code Civ. Proc. § 2017.010; Schnabel v. Superior Court (1993) 5 Cal.4th 704, 711.)   

 

Discussion

Plaintiff moves to quash Defendant’s deposition subpoena for insurance records on the grounds that records are protected under the right to privacy, and are overbroad, among other things.

Defendant issued a deposition subpoena to Farmers Insurance Exchange, seeking:

Any and all non-privileged insurance records including but not limited to, medical records, correspondence, billing, payments, claims photographs, explanation of benefits (EOBs), and any other non-privileged documents contained within the insurance file, pertaining to [Plaintiff]...”

(Best Decl., Exh. A.)

Plaintiff argues the subpoena is overbroad and invasive of her right to privacy. The right of privacy of individuals is protected by the California Constitution. (Cal. Const., Art. I, § 1.) The framework for evaluating invasions of privacy in discovery have been clarified in Williams v. Superior Court (2017) 3 Cal.5th 531.  There, the California Supreme Court held that, generally, “[t]he 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.  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.”  (Williams, supra, 3 Cal.5th at p. 533, citing Hill v. National Collegiate Athletic Assn. (1994) 7 Cal.4th 1, 35.)  The court rejected the cases which held that the party seeking protected information must always show a compelling need or interest.  (Id. at p. 557.)  Instead, the court held, “[o]nly obvious invasions of interest fundamental to personal autonomy must be supported by a compelling interest.”  (Id.)   

Here, Plaintiff has raised an objectively reasonable expectation of privacy in her insurance records and history under the given circumstances.  (See Williams, supra, 3 Cal.5th at p. 557.)  However, as previously discussed, Plaintiff’s privacy interests must be balanced against Defendant’s right to obtain discovery of the existence and contents of a plaintiff’s liability insurance coverage.  (See Code Civ. Proc., § 2017.210.)  Nevertheless, the Court agrees that Defendant’s request in the subpoena is both overbroad and will contain documents invasive of Plaintiff’s right to privacy.  Defendant does not articulate any legitimate or important countervailing interest such disclosure would serve, as they have not opposed the motion.  Accordingly, the Court agrees with Plaintiff that the subpoena should be quashed.   

 

As the subpoena is quashed, the remaining arguments need not be addressed.

 

              Sanctions

 

“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.” Cal. Code Civ. Proc., § 1987.2, subd. (a).  

The Court finds that the subpoena was oppressive as the subpoena is overbroad, violates Plaintiff’s privacy rights and Defendant is aware of this as this matter has been ruled on in this same case in this department. Thus, monetary sanctions in the amount of $1,022 ($481 an hour, for two hours, plus $60 in filing fees) are imposed against Defendant Jaclyn Salvatore De Rose, and her attorney of record, Derick Hovsepian, jointly and severally, to be paid within 30 days of this order.

Conclusion

Accordingly, Plaintiff’s motion to quash the subpoena is GRANTED. Plaintiff’s request for sanctions is GRANTED. Defendant Jaclyn Salvatore De Rose and attorney of record, Derick Hovsepian, are ordered to pay $1,022 in sanctions, jointly and severally, within 30 days of this order.

 

Moving party is ordered to give notice.