PLAINTIFF’S MOTION TO QUASH SUBPOENAS FOR MEDICAL RECORDS
LAW AND MOTION TENTATIVE RULINGS DATE: JUNE 25, 2026 TIME: 8:30 A.M.
complaints in two years surrounding decedent’s stay (nos. 97-99) or who had similar injuries (no. 100). Plaintiffs seek this information since they believe family members or representatives of other patients who were in the facility at the time of decedent’s care have information directly relevant to their claims.
Defendant filed an opposition only as to special interrogatory no. 96, arguing that the request is not reasonably calculated to lead to relevant evidence and disclosure of information would violate the privacy rights of third parties.
The right to privacy is not absolute and even private information can be disclosed in some circumstances. The court must carefully balance the right of privacy against the need of discovery. (Britt v. Superior Court (1978) 20 Cal.3d 844, 855-856.) How compelling the discovery need must be will depend on the importance of the privacy interest involved. (Davies v. Superior Court (1984) 1412, 1432.) Personal information can be ordered disclosed only if the information is directly relevant and essential to a fair resolution of the action. (Alch v. Superior Court (2008) 165 Cal.App.4th 1412, 1431-1432.)
Here, the names and contact information of potential witnesses does not contemplate nor require the disclosure of medical information merely because a family member was a patient at an acute care facility. The requests do not seek medical information; instead, they seek the identity of witnesses. (See Eisenhower Medical Center v. Superior Court (2014) 226 Cal.App.4th 430, 434-435 [identifying information implicates medical privacy concerns only when disclosure reveals information concerning a patient’s medical condition or treatment].) To the extent that the patients or their responsible parties witnessed decedent’s treatment or any alleged staffing issues, the evidence is directly relevant. The privacy invasion is slight, particularly as to the responsible parties, and outweighed by the need for discovery. Based on the foregoing, the motion is granted.
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No. 25CV01078
LYNTTON et al. v. MORALES et al.
(UNOPPOSED) PLAINTIFF’S MOTION TO QUASH SUBPOENAS FOR MEDICAL RECORDS
The unopposed motion is granted. The subpoena to Tesla Insurance Services, Inc. is quashed and the Court imposes $1,000.00 in monetary sanctions against defendant Angel Abraham Morales.
LAW AND MOTION TENTATIVE RULINGS DATE: JUNE 25, 2026 TIME: 8:30 A.M.
I. BACKGROUND
Plaintiffs Christian Lyntton and Saide Maydahl sued defendants Angel Abraham Morales and Gerardo Morales for damages related to an auto collision on April 16, 2023.
Plaintiff seeks a court order to quash or modify one subpoena issued by defendant for records relating to plaintiff’s medical care and history directed to Tesla Insurance Services, Inc. Plaintiff takes issue with the subpoena’s overly broad scope, arguing it seeks records protected by plaintiff’s right to privacy and goes beyond the parties’ agreements related to production of medical records.
Despite proper service, no opposition was filed. Defendant’s failure to oppose this motion can be construed as a concession to its merits. (D.I. Chadbourne, Inc. v. Superior Court (1964) 60 Cal.2d 723, 728, fn. 4 [where nonmoving party fails to oppose a ground for a motion “it is assumed that [nonmoving party] concedes” that ground].)
II. DISCUSSION
Pursuant to Code of Civil Procedure section 2017.010 unless otherwise limited by a court order, any party may obtain discovery regarding any matter not privileged that is relevant to the subject matter involved if the matter is admissible or is reasonably calculated to lead to the discovery of admissible evidence. “The ‘relevancy to the subject matter’ and ‘reasonably calculated to lead to discovery of admissible evidence’ standards are applied liberally. Any doubt is generally resolved in favor of permitting discovery, particularly where the precise issues in the care are not yet clearly established. [Citations.]” (Weil & Brown Civil Proc. Before Trial (TRG 2025) § 8:71.)
The right to privacy is not absolute and in each case the court must balance the right to privacy against the need for discovery. Defendant is entitled to records related to plaintiff’s claims for bodily injury and the parties previously agreed in this action to only seek records related to plaintiff Christian Lyntton’s head, back, neck and related symptoms. (Gauthier Declaration, ¶ 2.) This subpoena exceeds that agreement and following meet and confer, defendant refused to abide by the agreement. The Court therefore imposes monetary sanctions against defendant Angel Abraham Morales in the amount of $1,000.00 pursuant to Code of Civil Procedure section 2023.030, payable no later than July 24, 2026.