Judge: Steven A. Ellis, Case: 22STCV16354, Date: 2024-03-27 Tentative Ruling

Case Number: 22STCV16354    Hearing Date: April 2, 2024    Dept: 29

Defendant’s Motion for Leave to Conduct a Second Physical Examination of Plaintiff

 

Tentative

The motion is denied.

Background

On May 17, 2022, Jacqueline Escobar (“Plaintiff”) filed a complaint against Smart & Final LLC, Smart & Final Stores LLC (“Defendant”), and Does 1 to 20, asserting general negligence and premises liability causes of action arising out of slip and fall occurring on June 8, 2020.  Defendant filed its answer on May 8, 2023.

On March 7, 2024, Defendant filed this motion to compel the second physical examination of Plaintiff.  Plaintiff filed her opposition on March 19, 2024. No reply has been filed.

 Legal Standard

“Any party may obtain discovery ... by means of a physical or mental examination of (1) a party to the action, (2) an agent of any party, or (3) a natural person in the custody or under the legal control of a party, in any action in which the mental or physical condition (including the blood group) of that party or other person is in controversy in the action.” (Code Civ. Proc., § 2032.020, subd. (a).)

In a personal injury action, the defendant may demand one physical examination of plaintiff as of right, without advance leave of the court.  (Code Civ. Proc., § 2032.220.) 

If a defendant seeks a further physical examination of plaintiff, the defendant must first file a motion and “obtain leave of court.” (Code Civ. Proc., § 2032.310, subd. (a).)  Such a motion must “specify the time, place, manner, conditions, scope, and nature of the examination, as well as the identity and the specialty, if any, of the person or persons who will perform the examination.” (Id., subd. (b).) The moving party¿must support the motion with a meet and confer declaration.  (Ibid.

 

The court may grant the motion “only for good cause shown.” (Id., § 2032.320, subd. (a).) The purpose of the good cause standard is to protect a plaintiff from “excessive and unwarranted intrusions.” (Sporich v. Super. Ct. (2000) 77 Cal.App.4th 422, 428.)  A showing of good cause generally requires “that the party produce specific facts justifying discovery and that the inquiry be relevant to the subject matter of the action or reasonably calculated to lead to the discovery of admissible evidence.” (Vinson v. Super. Ct. (1987) 43 Cal.3d 833, 840.) 

“An order granting a physical … examination shall specify the person or persons who may perform the examination, as well as the time, place, manner, diagnostic tests and procedures, conditions, scope, and nature of the examination.”  (Code Civ. Proc., § 2032.320, subd. (d).)  ¿¿ 

Discussion

Defendant seeks an order compelling Plaintiff to sit for an independent medical examination performed by Dr. Hillel Sperling on March 19, 2024 at 1:30 p.m.

As a threshold matter, the Court obviously cannot order Plaintiff to attend an examination scheduled for two weeks in the past.

As a second threshold matter, it does not appear to the Court that there has been an adequate meet and confer process between counsel.  The parties agree that Plaintiff has already been examined once, by Defendant’s expert Dr. Nathaneal Heckman.  On page 7 of the motion, Defendant states that Dr. Heckman is an “orthopedic surgeon knee specialist.”  Defendant argues that because Plaintiff claims injuries to more than her knee, it should be now able to require Plaintiff to an additional examination by Dr. Hillel Sperling, who is a spine specialist and will examine Plaintiff’s back and neck.

What is missing, however, is any evidence regarding the scope of Dr. Heckman’s examination of Plaintiff.  Dr. Heckman may well specialize in knees, but if he already examined Plaintiff’s back and neck, there is no reason (or at least no reason in the record) that Defendant should be granted leave to compel Plaintiff to undergo a second examination of her back and neck.   Defendant doesn’t tell the Court what the scope of Dr. Heckman’s examination was (although Defendant presumably has Dr. Heckman’s report in hand by now), and Plaintiff argues in its legal briefing about what is in Dr. Heckman’s report but does not offer any supporting evidence (such as, for example, a copy of the report).

On this record, the motion is denied.  The denial is without prejudice, as it is based on at least three procedural matters, each of which is an independent basis to deny the motion, but all three of which are at least potentially subject to correction: (1) seeking an order requiring Plaintiff to attend an examination on a date in the past; (2) an inadequate meet and confer; and (3) the failure to present evidence to the Court regarding the scope of Dr. Heckman’s examination of Plaintiff.

Conclusion

The Court DENIES, without prejudice, Defendants’ motion for leave to require a second physical examination of Plaintiff by Dr. Sperling.

Moving Party is ORDERED to give notice.