Judge: Steven A. Ellis, Case: 22STCV06786, Date: 2025-01-06 Tentative Ruling

Case Number: 22STCV06786    Hearing Date: January 6, 2025    Dept: 29

Sliwoski v. Extended Stay America, Inc.
22STCV06786

Plaintiff’s Motion to Quash Subpoenas

 

Tentative

 

The motion is granted in part.

 

Background

On February 24, 2022, Plaintiff Molly Jean Sliwoski (“Plaintiff”) filed a complaint against Defendant Extended Stay America, Inc.; ESA P Porfolio Operating Lessee, LLC (“ESAP”); and Does 1 through 100, asserting causes of action for negligence and premises liability.  Plaintiff alleges that on September 29, 2020, while Plaintiff was visiting a guest at Defendant’s premises, she sat on a bench, the bench collapsed, and she sustained injuries as a result.

On March 30, 2022, ESAP filed its answer.

On July 21, 2022, Plaintiff amended the complaint to name ESH Hospitality, Inc., as Doe 1.

On September 19, 2022, Defendant ESA Management, LLC (“ESAM”), erroneously sued as Extended Stay America, Inc. and ESH Hospitality, Inc., filed its answer.

On June 12, 2023, Plaintiff filed a First Amended Complaint (“FAC”).  

On June 16, 2023, ESAP and ESAM (collectively, “Defendants”) filed an answer to the FAC.

As it relates to the matter currently before the Court, Defendants issued a number of subpoenas to Plaintiff’s medical providers, withdrew them, and then on or about November 11, 2024, reissued 22 of the subpoenas.  (Hennessey Decl., ¶¶ 8-13 & Exh. C.)

On November 27, 2024, Plaintiff filed this motion to quash the 22 subpoenas. Plaintiff also seeks sanctions.

On December 20, 2024, Defendants filed their opposition, and on December 27 Plaintiff filed a reply.

 

Legal Standard

 

Code of Civil Procedure section 1987.1, subdivision (a), states:  

 

“If a subpoena requires the attendance of a witness or the production of books, documents, electronically stored information, or other things before a court, or at the trial of an issue therein, or at the taking of a deposition, the court, upon motion reasonably made by any person described in subdivision (b), 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 or conditions as the court shall declare, including protective orders. In addition, the court may make any other order as may be appropriate to protect the person from unreasonable or oppressive demands, including unreasonable violations of the right of privacy of the person.”  

 

(Code Civ. Proc., § 1987.1, subd. (a).)

Section 1987.2, subdivision (a) provides that, subject to certain exceptions not applicable here:

“[T]he 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.” 

(Code Civ. Proc., § 1987.2, subd. (a).)

The California Constitution recognizes that all people have “inalienable rights,” including “pursuing and obtaining safety, happiness, and privacy.”  (Cal. Const., art. 1, § 1.)

For purposes of discovery, 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

Defendants seek to obtain, by 22 subpoenas, medical records of Plaintiff.  The subpoenas request the following records:

“[A]ny and all DOCUMENTS, including but not limited to medical and billing records, admission records, office records, emergency room records, mental and psychiatric records, sign-in sheets, medical tests, inpatient and outpatient charts and records, photographs, patient care reports, doctors' reports, paramedic reports, notes, memoranda, correspondence, videotapes, audio tapes, test results, diagnosis of condition(s), radiology records, films, x-rays, MRI’s, CT scans, radiological reports and test results, billing statements, invoices, charges, records of adjustments and/or write-offs, credits, explanation of benefits, balances due and insurance records, and payments by or on behalf of PLAINTIFF Molly Jean Sliwoski; date of birth 07/23/1974, and any other information pertaining to medical treatment rendered to her, from September 29, 2015 to present.”

(Hennessey Decl., Exh. C.)

Plaintiff seeks to quash or limit the Subpoena, arguing that they are overly broad in scope and violate Plaintiff’s right to privacy.  Defendants argue that the subpoenas are properly focused and seeks highly relevant information, particularly given that Plaintiff is seeking to recover significant damages for physical injuries and pain and suffering.

California’s Constitutional right to privacy protects against the unwarranted, compelled disclosure of various private or sensitive information regarding one’s personal life.¿ (Britt v. Superior Court (1978) 20 Cal.3d 844, 855-856.)¿¿This includes, of course, medical records.¿¿(E.g., John B. v. Super. Ct. (2006) 38 Cal.4th 1177, 1198.) “The public interest in preserving confidential … information generally outweighs a private litigant's interest in obtaining that information.”¿ (Life Technologies Corp. v. Superior Court (2011) 197 Cal.App.4th 640, 652, disapproved on other grounds by Williams v. Superior Court (2017) 3 Cal.5th 531.)

In Williams v. Superior Court (2017) 3 Cal.5th 531, Hill v. Nat'l Collegiate Athletic Assn. (1994) 7 Cal. 4th 1, and other cases, the California Supreme Court has established “a framework for evaluating potential invasions of privacy.” (Williams, supra, 3 Cal.5th at p. 552.) First, a 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.” (Id., citing Hill, supra, 7 Cal.4th at pp. 35-37.) In response, the party seeking the information may raise “whatever legitimate and important countervailing interests disclosure serves,” and “the party seeking protection may identify feasible alternatives that serve the same interests or protective measures that would diminish the loss of privacy.” (Id., citing Hill, supra, 7 Cal.4th at pp. 37-40.) The court must then “balance these competing considerations.” (Ibid.) The party seeking the information need not, however, establish a “compelling interest” unless the disclosure would be “an obvious invasion of an interest fundamental to personal autonomy.” (Id. at p. 556.)

Under the Williams and Hill framework, Plaintiff here must first establish a legally protected privacy interest and a reasonable expectation of privacy. Plaintiff has done so.  The medical records covered by the subpoenas are protected by the right to privacy, and Plaintiff has an objectively reasonable expectation of privacy in these records.  

Next, the subpoenas appear on their face to be a serious intrusion into Plaintiff’s right to privacy. Medical records, including those relating to the diagnosis and treatment of various conditions, are private, personal, and sensitive.

At this point, under Williams and Hill, Defendants must identify the “legitimate and important countervailing interests” that disclosure would serve. For example, the party seeking the discovery may attempt to show that the records sought through a subpoena are “directly relevant” to the claims or defenses in dispute and are “essential to the fair resolution of the lawsuit.” (Lantz v. Super. Ct. (1994) 28 Cal.App.4th 1839, 1854.)

Defendants have made this showing, at least in part.  As Plaintiff’s counsel notes, Plaintiff claims injuries to her right hand and wrist, her left hand and wrist, her lower extremities, skin discoloration, and Complex Regional Pain Syndrome.  (Hennessey Decl., ¶ 3.)  As a result, Plaintiff seeks to recover for a variety of treatments, including the placement of a spinal cord stimulator and lifelong medical care to manage her ongoing symptoms.  (Id., ¶ 4.)  Accordingly, information about injuries or pain throughout Plaintiff’s body is directly relevant to Plaintiff’s claims and essential to a fair resolution of the lawsuit.

Plaintiff seeks to quash the subpoenas in the entirety or, in the alternative, to limit the scope.  This secondary, alternative request for relief is a feasible alternative that would serve the same legitimate and important interests of Defendants while also diminishing Plaintiff’s loss of privacy. 

Finally, under the framework set out in Hill and reaffirmed in Williams, the Court must balance the “competing considerations” of the serious intrusion into Plaintiff’s privacy and Defendants’ legitimate need for the information.  This balancing of competing considerations is necessarily a difficult and delicate task, and it is particularly challenging here as the Court does not know what the subpoenaed records and testimony will reveal. Nonetheless, the Court must and will conduct the balancing based on the information before it in the record.

On balance, and after considering all of the evidence in the record and the arguments of both sides, the Court finds that Defendants’ legitimate interest in obtaining some, but not all, of the records requested in the subpoenas outweighs Plaintiff’s substantial privacy interest.  Accordingly, the Court grants the motion in part as follows:

First, the Court will quash in their entirety the subpoenas directed to Advantage Psychological Services and Jeffrey Wilson, Ph.D.  These are mental health providers, and Plaintiff has withdrawn and waived any claim for compensation for mental or psychological injury other than garden variety pain and suffering.  (Hennessey Decl., ¶¶ 8-10 & Exh. A.)

Second, although the Court recognizes that Plaintiff’s injury claims are broad, they are not unlimited, and Defendants’ legitimate need for discovery of Plaintiff’s private medical records extends no further than the scope of Plaintiff’s injuries.  Accordingly, the Court will modify the remaining subpoenas to be limited to complaints, diagnoses, or treatments relating to Plaintiff’s left hand and wrist, right hand and wrist, upper extremities, lower extremities, Chronic Regional Pain Syndrome, and chronic pain.

Third, for same reason, the Court will modify the remaining subpoenas to strike the reference to “mental and psychiatric records.”

Fourth, for the same reason, the Court will modify the remaining subpoenas to exclude, expressly, complaints, diagnoses, or treatments relating to reproductive health issues.

Plaintiff’s request for sanctions is denied.  Although the motion is granted in part (and denied in part), and although some of the requirements of the subpoenas are overly broad, the Court exercises its discretion to decline to award sanctions and finds that Defendants did not oppose the motion in bad faith, that Defendants did not act without substantial justification, and that the requirements of the subpoena are not oppressive.

Conclusion

 

The Court GRANTS IN PART Plaintiff’s motion to quash.

 

The Court QUASHES the subpoena to Advantage Psychological Services.

 

The Court QUASHES the subpoena to Jeffrey G. Wilson, Ph.D.

 

As to the remaining subpoenas, the Court MODIFIES each subpoena as follows: (1) each subpoena is limited to complaints, diagnosis, or treatments relating to Plaintiff’s left hand and wrist, right hand and wrist, upper extremities, lower extremities, Chronic Regional Pain Syndrome, and chronic pain; (2) the reference to “mental and psychiatric records” in each subpoena is stricken; (3) specifically excluded from each subpoena are any and all records relating to reproductive health issues. 

Moving Party is to give notice.