Jane Doe vs. Dignity Health

34-2021-00292375-CU-PO-GDS: Jane Doe vs. Dignity Health 10/29/2025 Hearing on Motion to Compel Regarding Deposition of def's Person Most Qualified in Department 53

Tentative Ruling

NOTICE: PLEASE TAKE NOTICE that pursuant to “Public Notice – Civil Division – 2025 Law and Motion Calendars” any oral arguments regarding this tentative ruling will be heard in Department 25, located at 720 9th Street, Sacramento, CA, the Hon. Julie G. Yap presiding. Should argument be requested by either party, the requesting party must call the Law and Motion Oral Argument Request Line at (916) 874-2615, by 4:00 p.m. the Court day before the hearing, request the hearing, and notify the opposing party of the location and time of hearing pursuant to Local Rule 1.06.

At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

The Court encourages parties to appear remotely for the hearing on the tentative ruling through the Court’s Zoom Application. But, any party wishing to appear in person may do so, provided that party notifies the Court by 4:00 the Court day before the hearing. The parties may join the Zoom session for hearing on the tentative ruling by audio and/or video through the following link: https://saccourt-ca-gov.zoomgov.com/my/sscdept25 SIP Address: 16113421868@sip.zoomgov.com (833) 568-8864 ID: 16113421868 Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956.

Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.Pdf A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk

34-2021-00292375-CU-PO-GDS: Jane Doe vs. Dignity Health 10/29/2025 Hearing on Motion to Compel Regarding Deposition of def's Person Most Qualified in Department 53

will be forward the form to the Court Reporter’s Office and an official reporter will be provided.

TENTATIVE RULING:

The Motion of Plaintiff Jane Doe to compel the deposition of defendant Dignity Health’s (“DH”) person most qualified (“PMQ”) re: Plaintiff is ruled upon as follows.

This matter was continued to this date to permit the parties to further meet-and-confer on various issues and to submit a Joint Statement identifying those remaining disputes which require judicial resolution. The Court has received the parties’ Joint Statement filed on 10/15/2025 and now rules as follows.

Based on the Joint Statement filed on 10/15/2025, the parties “made significant headway on a plan that included an orderly production of witnesses and documents” but “a few key disputes” remain. (Jt. Stm., p. 2:8-9.) These “disputes” relate to the following:

(1) Complaints, concerns, investigation, reporting, and/or employment action regarding defendant Harms outside the topic of sexual misconduct; and/or (2) Complaints, concerns, investigation, reporting, and/or employment action about narcotics misappropriation/misuse (regarding defendant Harms). (Jt. Stm., p. 2:25-28.)

By way of their joint statement, the parties identify that the same issues to the PMQ notice re: Harms apply to the following Topics and Requests for Documents here: PMQ Topics 1-4, 8, 10- 12; and Document Requests 1, 2, 5-8, 10-11, 13-29, 31-33. (Jt. Stm., pp. 3:1-5:3.)

Because the same “key disputes” remain in this motion that remain in the pending motion to compel the deposition of defendant Dignity Health’s (“DH”) person most qualified (“PMQ”) re: Gregory Harms, the Court incorporates by reference the discussion and analysis set forth in the order relating to that motion.

For the reasons explained in the Court’s ruling on plaintiff’s motion to compel the deposition of defendant Dignity Health’s (“DH”) person most qualified (“PMQ”) re: Gregory Harms, plaintiff’s motion to compel the deposition of defendant DH’s PMQ re: plaintiff is DENIED to the extent plaintiff claims here that she is “entitled to explore through deposition the information which may be contained within [Harms’] personnel file” and/or is entitled to an order compelling production of any portion of Harms’ personnel file.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2021-00292375-CU-PO-GDS: Jane Doe vs. Dignity Health 10/29/2025 Hearing on Motion to Compel Regarding Deposition of def's Person Most Qualified in Department 53

Consistent with their representations in their Joint Statement, the parties are directed to resume their meet-and-confer process relating to this PMQ deposition and to proceed with same in accordance with their agreement.

Plaintiff remains free to file and serve an appropriate noticed motion(s) to the extent she may contend defendant DH has unreasonably refused to do any of the following:

(1) To produce a PMQ on a topic which is otherwise in conformity with the limitations set forth in the 8/13/2024 Order and/or this ruling; (2) To answer a specific deposition question which is otherwise in conformity with the limitations set forth in the 8/13/2024 Order and/or this ruling; and/or (3) To produce documents responsive to a request for production which is otherwise in conformity with the limitations set forth in the 8/13/2024 Order and/or this ruling.

Neither side requested monetary sanctions and thus, no sanctions are awarded here.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC Rule 3.1312.)