Judge: William A. Crowfoot, Case: 19STCV23465, Date: 2022-12-27 Tentative Ruling

Case Number: 19STCV23465    Hearing Date: December 27, 2022    Dept: 27

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

 

NATOSHA PLOUSHA,

                   Plaintiff(s),

          vs.

 

HYUNDAI MOTOR COMPANY, et al.

 

                   Defendant(s).

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CASE NO.: 19STCV23465

 

[TENTATIVE] ORDER RE: PLAINTIFF’S MOTION TO CONTINUE TRIAL; PLAINTIFF’S MOTION TO REOPEN DISCOVERY

 

Dept. 27

1:30 p.m.

December 27, 2022

 

I.            INTRODUCTION

On July 8, 2019, plaintiff Natosha Plousha (“Plaintiff”) filed this action against defendants Hyundai Motor and Avis Budget Group, Inc. (“Defendant”).  Plaintiff alleges that on July 20, 2017, a tire on her rental car blew out and she lost control of the vehicle.  Trial is currently scheduled for January 31, 2023.  On November 15, 2022, Plaintiff filed these motions.  Plaintiff seeks an order continuing the trial date and reopening discovery.  On December 12, 2022, Defendant filed opposition briefs.  Plaintiff filed reply briefs on December 20, 2022. 

II.          LEGAL STANDARD

Trial dates are firm to ensure prompt disposition of civil cases. (Cal. Rules of Court, rule 3.1332(a).) Continuances are thus generally disfavored. (See id. rule 3.1332(b).) Nevertheless, the trial court has discretion to continue trial dates. (Hernandez v. Superior Court (2004) 115 Cal.App.4th 1242, 1246.) Each request for continuance must be considered on its own merits and is granted upon an affirmative showing of good cause. (Cal. Rules of Court, rule 3.1332(c); Hernandez, supra, 115 Cal.App.4th at 1246.) Circumstances that may indicate good cause include: (1) the unavailability of an essential lay or expert witness due to death, illness, or other excusable circumstances; (2) the unavailability of a party due to death, illness, or other excusable circumstances; (3) the unavailability of trial counsel due to death, illness, or other excusable circumstances; (4) the substitution of trial counsel where there is an affirmative showing that the substitution is required in the interests of justice; (5) the addition of a new party if (A) the new party has not had a reasonable opportunity to conduct discovery and prepare for trial, or (B) the other parties have not had a reasonable opportunity to conduct discovery and prepare for trial in regard to the new party’s involvement in the case; (6) a party’s excused inability to obtain essential testimony, documents, or other material evidence despite diligent efforts; or (7) a significant, unanticipated change in the status of the case as a result of which the case is not ready for trial. (Cal. Rules of Court, rule 3.1332(c).)

The court must also consider such relevant factors as: (1) the proximity of the trial date; (2) whether there was any previous continuance, extension of time, or delay of trial caused by any party; (3) the length of the continuance requested; (4) the availability of alternative means to address the problem that gave rise to the motion or application for a continuance; (5) the prejudice that parties or witnesses will suffer as a result of the continuance; (6) if the case is entitled to a preferential trial setting, the reasons for that status and whether the need for a continuance outweighs the need to avoid delay; (7) the court’s calendar and the impact of granting a continuance on other pending trials; (8) whether trial counsel is engaged in another trial; (9) whether all parties have stipulated to a continuance; (10) whether the interests of justice are best served by a continuance, by the trial of the matter, or by imposing conditions on the continuance; and (11) any other fact or circumstance relevant to the fair determination of the motion or application. (Id., rule 3.1332(d).)

On motion of any party, the court may grant leave to complete discovery proceedings, or to have a motion concerning discovery heard, closer to the initial trial date, or to reopen discovery after a new trial date has been set.  This motion shall be accompanied by a meet and confer declaration demonstrating a good faith effort at informal resolution.  (Code Civ. Proc., § 2024.050, subd. (a).)  

The court shall take into consideration any matter relevant to the leave requested, including, but not limited to: (1) the necessity and the reasons for the discovery, (2) the diligence or lack of diligence of the party seeking the discovery or the hearing of a discovery motion, and the reasons that the discovery was not completed or that the discovery motion was not heard earlier, (3) any likelihood that permitting the discovery or hearing the discovery motion will prevent the case from going to trial on the date set, or otherwise interfere with the trial calendar, or result in prejudice to any other party, and (4) the length of time that has elapsed between any date previously set, and the date presently set, for the trial of the action.”  (Code Civ. Proc., § 2024.050, subd. (b).)

III.        DISCUSSION

Plaintiff requests a continuance of the trial date and the reopening of discovery because she claims that her prior counsel, Armand Tinkerian, failed to adequately prepare the case for trial.  Plaintiff’s current counsel, Mariano Alvarez, states that he believed that he was substituting in because of Mr. Tinkerian’s health and that the case was ready for trial.  Mr. Alvarez states that Plaintiff’s medical expenses, both past and future, were not fully disclosed by Mr. Tinkerian to opposing counsel, and he discovered this when he was preparing the exhibit and witness list.  Plaintiff allegedly discussed the procedures and treatments she underwent, which were not disclosed during discovery, including a shoulder surgery, uterine injuries, a seizure, and a stroke.  Plaintiff contends that she must still obtain her medical records and find experts who are willing to prepare reports and testify in time. 

          In opposition, Defendant argues that there is no need to reopen discovery because the medical records and treatments that Plaintiff identified are not relevant to the injuries she sustained from the underlying incident on July 16, 2017.  Defendant also states that Plaintiff has had the opportunity to identify all her medical providers in written discovery because she signed verifications.  Defendant contends that Plaintiff did not present with any complaints related to this matter regarding her low back, shoulders, or radiating lower extremities, and that these complaints were the result of a motor vehicle accident that occurred on April 3, 2018.  Plaintiff underwent an independent medical examination on September 6, 2022, and had the opportunity to disclose all injuries, but she only complained of headaches, abdominal and pelvic pain, seizures, and depression.  She did not complain of neck pain, shoulder pain, low back pain, or radiating bilateral lower extremity pain.  She also did not allege that her stroke from November 5, 2021 was connected with this accident.  Defendant adds that reopening discovery and continuing trial is unnecessary because Plaintiff may obtain her records by way of an executed release and can provide supplemental discovery responses identifying any additional information if necessary. 

The Court agrees with Defendant that any additional facts that Plaintiff would like to provide does not require re-opening discovery, but recognizes that if Plaintiff would like to designate new experts, then expert discovery would need to be reopened. 

IV.         CONCLUSION

Accordingly, Plaintiff’s motion is GRANTED in part.  Trial is continued from January 31, 2023 to February 28, 2023 at 8:30 a.m. in Department 27.  The final status conference is continued from January 17, 2023 to February 14, 2023 at 10:00 a.m. in Department 27.  Only expert discovery is reopened and the expert discovery cut-off date will be based on the new trial date.  

 

Moving party to give notice.

Parties who intend to submit on this tentative must send an email to the Court at SSCDEPT27@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org.  Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter.  Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue.  If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar.