JANE LS DOE, AN INDIVIDUAL vs DR. STEPHEN FREDERICK KNOX, et al.

12. Despite the foregoing knowledge, the Plaintiff is informed and believes, and on this basis alleges, that Defendant SUTTER HEALTH and its employees,

24CV013840: JANE LS DOE, AN INDIVIDUAL vs DR. STEPHEN FREDERICK KNOX, et al. 02/26/2026 Hearing on Motion to Compel Further Discovery Responses to Requests for Production of Documents, Set One in Department 54

agents, nurses, physicians, medical assistants, supervisors, and executives never once reported KNOX to law enforcement, the California Department of Consumer Affairs, or to the Medical Board of California, during KNOX’s tenure at Defendant SUTTER HEALTH.

(3AC, ¶¶ 11-12.)

Plaintiff alleges that in August 2023, the Attorney General before the Medical Board of California and Department of Consumer Affairs brought an accusation against Knox for sexually abusing three of his female patients, including Plaintiff. Knox stipulated to surrender his medical license to the Board and effective as of June 27, 2024. (3AC, ¶ 7.)

The 3AC asserts causes of action for: (1) intentional infliction of emotional distress, (2) gender violence, (3) sexual harassment, (4) sexual assault, (5) sexual battery, (6)) negligence, (7) negligent supervision, (8) negligent hiring and retention, and (9) negligent failure to warn, train and educate.

No trial is currently scheduled.

Plaintiff moves to compel SVMF’s further responses to RFP Nos. 2, 4, 16 and 17, and to produce documents responsive to the RFPs, which concern complaints and allegations against Knox for sexual misconduct.

RFP Nos. 2 and 17 request:

 ALL DOCUMENTS and COMMUNICATIONS RELATED TO allegations of KNOX committing SEXUAL MISCONDUCT or having a history of SEXUAL MISCONDUCT, including allegations, complaints, reports, memoranda, e-mails, ESI, letters, directives, notices, warnings, admonishments, discipline, patient records, personnel files, arrests, or convictions. (RFP No. 2.)  To the extent not encompassed by prior requests, ALL DOCUMENTS that EVIDENCE formal OR informal complaints from ANY source, including but not limited to patients AND EMPLOYEES, RELATING TO KNOX. (RFP No. 17.)

SVMF responded to RFPs Nos. 2 and 17 as follows:

Objection. This request is vague, ambiguous, overbroad, burdensome, harassing and compound. The request seeks information not reasonably likely to lead to the discovery of admissible evidence. The request assumes facts and lacks foundation. The request seeks information not subject to discovery pursuant to

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Evidence Code Section 1101 and seeks information protected by Evidence Code 1156 and 1157. The request seeks confidential information which would relate to third-party individuals and would be violative of those individual’s rights to privacy. Subject to and without waiving these objections, Responding Party attaches Exhibit F, Acknowledgement of Member Grievance and refers Propounding Party to the accompanying Privilege Log.

(SVMF’s Supplemental Responses to RFP Nos. 2 and 17.)

RFP Nos. 4 and 16 request:

 ALL DOCUMENTS and COMMUNICATIONS RELATED TO complaints by any patient regarding SEXUAL MISCONDUCT by KNOX. (RFP No. 4.)  ALL DOCUMENTS and COMMUNICATIONS RELATED TO all complaints of KNOX committing SEXUAL MISCONDUCT. (RFP No. 16.)

SVMF responded to RFP Nos. 4 and 16 as follows:

Objection. This request is vague, ambiguous, overbroad, burdensome, harassing and compound. The request seeks information not reasonably likely to lead to the discovery of admissible evidence. The request assumes facts and lacks foundation. The request seeks information not subject to discovery pursuant to Evidence Code Section 1101 and seeks information protected from discovery by Evidence code 1157. It also seeks confidential information which would relate to third-party individuals and would be violative of those individual’s rights to privacy. This request also seeks information protected by HIPAA. Based on and subject to the objections, Responding Party is unable to comply with this request.

(SVMF’s Supplemental Responses to RFP Nos. 2 and 17.)

SVMP also served a privilege log with 16 documents withheld based on Evidence Code sections 1156 and 1157, attorney-client privilege and attorney work-product[2], HIPAA, and right to privacy under article I, section 1 of the California Constitution.

Legal Standard

A party responding to a request for production must respond separately to each request by any of the following:

(1) A statement that the party will comply with the particular

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demand . . . by the date set for the inspection, copying, testing, or sampling pursuant to paragraph (2) of subdivision (c) of Section 2031.030 and any related activities.

(2) A representation that the party lacks the ability to comply with the demand . . . .

(3) An objection to the particular demand . . . .

(Code Civ. Proc., § 2031.210, subd. (a).)

“A statement that the [responding] party . . . will comply with the particular demand shall state that the production . . . will be allowed either in whole or in part, and that all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production.” (Code Civ. Proc., § 2031.220.)

“A representation of inability to comply with the particular demand . . . shall affirm that a diligent search and a reasonable inquiry has been made in an effort to comply with that demand. This statement shall also specify whether the inability to comply is because the particular item or category has never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in the possession, custody, or control of the responding party. The statement shall set forth the name and address of any natural person or organization known or believed by that party to have possession, custody, or control of that item or category of item.” (Code Civ. Proc., § 2031.230.)

“A valid response to an inspection demand is to object to it. (Code Civ. Proc., § 2031.210, subd. (a)(3).” (Cal. Judges Benchbook: Civil Proceedings - Discovery (2024) § 19.28.) “A valid objection defeats the demanding party’s motion to compel a further answer.” (Ibid. [citing Cal. Code Civ. Proc., § 2031.310, subd. (a)(3)].) “If only part of a [demand] is objectionable, the response shall contain a statement of compliance, or a representation of inability to comply with respect to the remainder of that item or category.” (Code Civ. Proc., § 2031.240, subd. (a).) And “[i]f an objection is based on a claim of privilege or a claim that the information sought is protected work product, the response shall provide sufficient factual information for other parties to evaluate the merits of that claim, including, if necessary, a privilege log.” (Id. at subd. (c)(1).)

The requesting party is entitled to obtain an order compelling further responses to its RFPs if the responding party’s statement of compliance to a demand is incomplete, the responding party’s representation of inability to comply is inadequate or evasive, or the responding party has made an objection that is without merit or is too general. Such a motion must set forth “specific facts

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showing good cause justifying the discovery sought by the demand.” (Code Civ. Proc., § 2031.310, subd. (b)(1).) The burden of showing good cause “is met simply by a fact-specific showing of relevance.” (Glenfed Dev. Corp. v. Super. Ct. (1997) 53 Cal.App.4th 1113, 1117.) If “good cause” is shown by the moving party, the burden is on the responding party to justify any objections made to the demands. (Kirkland v. Super. Ct. (2002) 95 Cal.App.4th 92, 98 [citing Coy v. Super. Ct. (1962) 58 Cal.2d 210, 220-221].)

Analysis

As an initial matter, the Court declines SVMF’s request to deny the motion based on Plaintiff’s failure to comply with CRC Rule 3.1345(c) because Plaintiff’s separate statement provided a single statement of factual and legal reasons intended to apply to all disputed requests collectively. Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893, upon which SVMF relies is inapposite because in Miller the moving party did not set forth the responding party’s full response to each of the interrogatories and requests for production.

Rather, the moving party “repeatedly grouped together several discovery requests, and then stated ‘in relevant part’ U.S. Bank’s response to the group as a whole, and it significantly truncated some of the lengthier responses.” (Ibid.) Additionally, the factual and legal reasoning section “was extremely confusing because it did not indicate which of the specific discovery requests the various factual and legal reasons related to.” (Ibid.) Here, Plaintiff’s separate statement includes the entirety of SVMF’s responses and supplemental responses.

The factual and legal reasoning section is not “extremely confusing” given that the requests seek documents concerning the same subject matter, and SVMF’s objections and responses are similar.

Plaintiff insists that further responses are required because the requests are relevant, probative and necessary to show that SVMF had notice and knowledge of Knox’s conduct. Plaintiff notes that the Medical Board accusations alleged in the 3AC show that Knox was accused of similar conduct towards two other patients, as a result, the documents requests are “direct, relevant and extremely probative evidence that not only did SVMF know KNOX was engaging in inappropriate and reprehensible conduct, but that they continued to allow him privileges to their facilities, and access to more patients.” (Plaintiff’s Separate Statement, 7:4-6.)

With respect to Knox’s employment records, Plaintiff contends that any privacy interest in such documents is outweighed by her compelling interest in obtaining them. Plaintiff explains that “[w]ithout learning the qualifications (or lack thereof) of KNOX and the prior history of documented complaints, misconduct, and handling of KNOX, Plaintiff is unable to support her conclusions as to her various claims. Without having access to the requested documents (i.e., internal investigations and peer review summaries), Plaintiff is unable to adequately prosecute her claims.” (Motion, 9:22-25.) Plaintiff adds that SVMF cannot show an objectively reasonable expectation of privacy regarding Knox’s employment records because “both California and

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Federal law make clear that an employer cannot guarantee confidentiality in connection with harassment and/or discrimination complaints.” (Motion, 10:6-10.)[3] Plaintiff further notes that a protective order will remedy Knox’s privacy concerns.

As to the HIPPA objections, Plaintiff suggests that “HIPAA would not be applicable since the documents cited would appear to be our own client’s records. Even if not our client’s own records, the Plaintiff has proposed in their Meet and Confer letter that a Protective Order would cure any fear of misuse of privileged information being disseminated.” (Plaintiff’s Separate Statement, 9:4-7.)

With respect to SVMF’s privilege log, Plaintiff advances that SVMF fails to show that the documents are not discoverable or fall within the protections of Evidence Code sections 1156 and 1157. Plaintiff explains that Evidence Code 1156 applies to committees conducting studies for the purposes of reducing morbidity or mortality, and thus, is inapplicable here. With respect to Evidence Code section 1157, Plaintiff argues that the statute does not apply because “[a]n internal investigation into one particular care provider, here a surgeon, is not what the purpose of a peer review body is summoned for.

On the contrary, a peer review body would gather to discuss a different purpose, such as best practices in preventing future situations of harm to a patient; not to hide what has already been done.” (Plaintiff’s Separate Statement, 8:21-26.) Plaintiff insists that SVMF fails to articulate and detail its asserted privileges, and that providing documents to a lawyer does not transform a document to make it privileged.

SVMF argues in opposition that Plaintiff fails to show good cause for the discovery. It emphasizes that in its verified discovery responses, SVMF has stated that it did not employ Knox at any time, did not maintain a personnel file for him and did not control his compensation or discipline. (Declaration of Taryn A. Perez, Ex. A.) Thus, SVMF insists that “Plaintiff’s continued reliance on an employment relationship that did not exist cannot serve as a basis to expand SVMF’s discovery obligation.” (Opposition, 3:27-28.)

SVMF further explains that it has not concealed the existence or timing of patient complaints/concerns/grievances or internal investigations/reviews since its privilege log “provides the temporal information Plaintiff claims she needs to evaluate any alleged ‘notice’ theory, including the dates associated with patient complaints/concerns/grievances and internal investigation/reviews.” (Opposition, 4:3-5.) As a result, SVMF claims that “[w]hat Plaintiff actually seeks is not notice information, but the substance of the privileged documents, which are protected from disclosure for the reasons asserted on the Privilege Log.” (Opposition, 3:6-8.)

As to SVMF’s privacy objections, SVMF explains that the privacy objections protect non-party patients, not Knox, and that “Plaintiff’s requests are so overbroad that compliance would require disclosure of identifiable information and sensitive personal details of individuals who are not parties to this case and have not placed their medical or personal information at issue.”

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(Opposition, 4:18-21.) SVMG adds that “the identity of a complaining patient and the nature of their complaint are inherently confidential medical-related information protective under the California Constitution and long-standing case law. To the extent that responsive documents existed as to Plaintiff, the same were produced.” (Opposition, 5:5-8.)

SVMF also disagrees with Plaintiff that Evidence Code section 1157 is inapplicable because the purpose of the section is to improve the quality of medical care in the hospital by the use of peer review committees, as such, “a complaint related to a patient’s medical care would go directly to the hospital’s peer review committee to investigate and improve the care provided at the hospital.” (Opposition, 6:16-18.) SVMF suggests that its privilege log is sufficient since it “identifies documents that are subject to peer review. These documents were used for the evaluation and improvement of the quality of care rendered by the facility, and/or internal investigation.” (Opposition, 7:4-6.)

The Court disagrees with SVMF that Plaintiff fails to show good cause for the discovery. While SVMF states that it did not employ Knox, and therefore, does not have a personnel file for Knox, the requests are not limited to Knox’s personnel file. Indeed, based on SVMF’s privilege log, it is clear that SVMF has documents concerning Knox. Plaintiff also alleges that Knox was SVMF’s apparent or ostensible agent, that SVMF referred patients to Knox, and that SVMF held Knox out as a physician who was working for and/or affiliated with SVMF. (3AC, ¶ 5.) Here, whether SVMF received prior complaints or allegations against Knox for sexual misconduct is directly relevant to Plaintiff’s claims. The Court finds that the right to privacy is outweighed by Plaintiff’s compelling need for the discovery.

The vague, ambiguous, overbroad, burdensome, harassing and compound objections are OVERRULED. The objection that the requests seek information not reasonably likely to lead to the discovery of admissible evidence and assumes facts and lacks foundation are also OVERRULED. Since SVMF makes no attempt to justify the objections based on Evidence Code sections 1101 and 1156, the objections are OVERRULED.

With respect to third-party privacy concerns, the Court agrees with SVMF the requests implicate third-party rights to privacy. This recognition, however, does not end the analysis. HIPAA permits disclosures when they are made pursuant to court orders, and such disclosures may be made “without the written authorization of the individual” in question and “without the opportunity for the individual to agree or object.” (See 45 C.F.R. § 164.512(e)(1)(i) (providing in part that “A covered entity may disclose protected health information in the course of any judicial or administrative proceeding: [¶] In response to an order of a court or administrative tribunal, provided that the covered entity discloses only the protected health information expressly authorized by such order.”) The California Confidentiality of Medical Information Act also allows a provider of health care to disclose patient medical information if compelled by “[a]

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court order issued by a court of this state.” (Civ. Code § 56.10(b)(1)(A).) A stipulated protective order will also lessen the privacy concerns. Nonetheless, the only protected health information to be disclosed shall concern Knox’s sexual misconduct against the patient(s). As a result, Plaintiff’s request that the Court compel SVMF to produce document nos. 8, 9, and 14 in the privilege log is GRANTED. The only protected health information to be disclosed shall concern Knox’s sexual misconduct against the patient(s). SVMF shall produce document nos. 8, 9, and 14 by no later than March 16, 2026, unless the parties agree in writing to a different date.

Evidence Code section 1157 provides, in pertinent part, “[n]either the proceedings nor the records of organized committees of medical . . . or of a peer review body, as defined in Section 805 of the Business and Professions Code, having the responsibility of evaluation and improvement of the quality of care rendered in the hospital . . . shall be subject to discovery. Neither party provides legal authority that the statute applies to cases involving allegations of sexual assault. Nonetheless, it was SVMF’s burden to justify the objection.

“Section 1157 specifies that the records of a medical staff committee are immune from discovery when the committee has ‘the responsibility of evaluation and improvement of the quality of care rendered in the hospital . . . .’ In passing upon the claim of immunity, a court must have before it facts which allow it to match the staff committee’s mission and function against the specifications of the statute.” (Matchett v. Super. Ct. (1974) 40 Cal. App. 3d 623, 627 [emphasis added].) “The burden of establishing entitlement to nondisclosure rested with the party resisting discovery . . . .” (Ibid.)

Evidence Code section 1157 does not extend to documents contained in hospital administration files that do not reflect the proceedings of staff committees. (Id., at 628.) Hospital administrators have a concurrent duty to insure the adequacy of medical care and cannot evade that duty by purporting to delegate all responsibility for the quality of care to medical staff committees. (Santa Rosa Mem’l Hosp. v. Superior Court (1985) 174 Cal.App.3d 711, 724.) Thus, Evidence Code section 1157 does not prevent discovery of hospital administration documents that do “not derive from an investigation into the quality of care or the evaluation thereof by a medical staff committee, and which does not disclose the investigative and evaluative activities of such a committee,” even if the documents are subsequently placed in the possession of such a committee. (Ibid.)

In the case at bar, SVMF fails to meet its burden since it provides no declaration to support its claim that peer review(s) occurred, or that the requested documents are peer review documents protected from disclosure pursuant to Evidence Code section 1157. It is also unclear whether SVMF has withheld hospital administration documents that do “not derive from an investigation into the quality of care or the evaluation thereof by a medical staff committee, and which does not disclose the investigative and evaluative activities of such a committee.” The Court, however, will not order SVMF to produce document nos. 1-7, 10-13, 15-16 in the privilege log. As explained in Santa Rosa Mem’l Hosp., “[w]hen application of the statute to disputed

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discovery is not facially apparent, as will often be the case, the burden on the party resisting discovery ordinarily cannot be sustained except upon judicial inquiry into the pertinent facts at an in-camera hearing [citations]. If it is revealed at such a hearing that only portions of a report or other document are derived from the work of a protected committee the court may order such portions excised and compel disclosure of the remainder.” (Santa Rosa Mem’l Hosp., supra, 174 Cal.App.3d at 727-728.)

Accordingly, the Court will conduct an in-camera review of document nos. 1-7, 10-13, 15-16. SVMF shall bring document nos. 1-7, 10-13, 15-16 to Department 54 pursuant to an ex parte appointment to be scheduled on the Court’s ex parte calendar, and the Court will conduct an in-camera review. The Court will issue a ruling at the conclusion of the in-camera review. Five court days prior to the ex parte hearing, SVMF shall file and serve a declaration or declaration(s) providing sufficient facts demonstrating that peer review(s) occurred and that the documents fall within the Evidence Code section 1157.

Two court days prior to the ex parte hearing, Plaintiff may file and serve objections (if any) to the declaration(s) submitted by SVFM.

Subject to the above, Plaintiff’s motion to compel SVMF’s further responses is GRANTED. SVMF shall serve further verified written responses by no later than March 16, 2026, unless the parties agree in writing to a different date.

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

Moving counsel’s notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Moving counsel is directed to contact Defendant’s counsel and advise counsel of Local Rule 1.06 and the Court’s tentative ruling procedure and the manner to request a hearing. If moving counsel is unable to contact Defendant’s counsel prior to hearing, moving counsel is ordered to appear at the hearing.

[1] SVMF was erroneously sued as Sutter Health Medical Foundation. Plaintiff’s 3AC refers to

SVMF as “Sutter Health.” [2] SVMF’s responses to RFPs nos. 2,4, 16 and 17 did not assert the attorney-client privilege or

work-product protection. A responding party may respond to a request for production by objecting. (Code Civ. Proc. § 2031.210, subd. (a)(3).) However, to be effective, an objection must set forth the specific ground for objection, including claims of privilege or work product protection. (Code Civ. Proc., § 2031.240, subd. (b)(2).) Further, if an objection is based on a claim of privilege, “the particular privilege invoked [must] be stated.” (Ibid.) As a result, SVMF waived the attorney-client privilege or work-product protection by failing to assert them in its response. (Code Civ. Proc. §§ 2031.240(b)(2) and 2031.300 (a); see also Stadish v. Superior Court (1999) 71 Cal.App.4th 1130, 1141; Catalina Island Yacht Club v. Superior Court (2015)

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242 Cal.App.4th 1116, 1125 (citing Stadish).) [3] Plaintiff cites to “DFEH Guide, ‘Ex. 8’ to DCP.” Plaintiff, however, fails to define “DCP,”

and has not attached an Exhibit 8 to the Declaration of Rebecca A. Reed filed in support of the motion.

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you 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 and advise opposing counsel. 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.

Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings.

The Department 54 Zoom Link is https://saccourt-ca-gov.zoomgov.com/my/sscdept53.54 and the Zoom Meeting ID is 161 4650 6749. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.

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

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Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/courtreporters/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 will forward the form to the Court Reporter’s Office and an official reporter will be provided.