GHANI vs STANDARD LAKESIDE I, LP, et al.

Defendants contend that the discovery propounded between 4/6/2026 and 4/15/2026 is both duplicative and significantly disproportionate to discovery required by Plaintiff to oppose Defendants’ summary judgment motion. 24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 07/02/2026 Hearing on Motion for Protective Order filed by STANDARD LAKESIDE I, LP (Defendant) + CRS# 806085508739 in Department 23

The Court has broad authority to issue a protective order to “restrict the frequency or extent of use of” depositions and written discovery if it determines either that (1) “[t]he discovery sought is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome, or less expensive”; or (2) “[t]he selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake in the litigation.” (CCP § 2019.030.) Upon a showing of good cause, courts may “make any order that justice requires” to protect a party or deponent “from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense.” (CCP § 2025.420(b).)

The Court notes Plaintiff’s objections to the timing of this motion as insufficiently “prompt.” However, considering the significant number of pending discovery motions and given the limited factual context of this dispute and that the requests, at least superficially, appear to seek duplicative information, the Court finds this motion to be an appropriate and timely method for addressing the volume of discovery at issue in the near future.

The Court further notes that the parties appear to disagree regarding about the applicable discovery cutoff date. The Court’s order re-setting trial to March 2027 does not directly address this issue, but it was the Court’s intention to continue the related pretrial deadlines to the date of the continued trial. Accordingly, the Court does not decide the motion on this basis.

Site inspection: Plaintiff’s demand for inspection of the subject property stated that the inspection would last four hours or until completion, whichever is later; would encompass the “entirety of the Property”; and would be attended by Plaintiff, Plaintiff’s counsel, Plaintiffs’ retained security and premises safety expert, and “[s]uch additional experts, consultants, photographers, videographers, or support personnel as Plaintiff deems necessary and appropriate.” (Mot. Ex. F.)

In opposition to this motion, Plaintiff’s counsel states that he met and conferred with Defendants on 6/11/2026 regarding the 6/15/2026 inspection and indicated that he “really only anticipated a ~10 minute inspection around the parking lot area where Plaintiff was injured, and we would take some picture[s].” (Thuesen Decl. ¶ 2.) The Court appreciates the parties meet and confer efforts, and finds this to be a reasonable limitation in light of the relatively narrow factual scope of this case. Therefore, the Court GRANTS a protective order limiting the site inspection to 30 minutes, to take place in the parking lot area on a date and time that is agreeable to the parties.

Crime statistics: Defendants contend that crime statistics upon which Plaintiff relies are not relevant to this case, and argue further that generalized neighborhood crime does not establish foreseeability in a premise case; thus, any testimony derived from the crime statistics would not be admissible at trial under CCP section 352. Defendants provide excerpts from the 4/23/2026 deposition of Richelle Warr to demonstrate Plaintiff’s use of the crime data at deposition. (See Mot. at pp. 9-10; see also Holley Decl. ¶ 14, Ex. D [Warr Depo. Tr. at pp. 160-163].) Defendants

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 07/02/2026 Hearing on Motion for Protective Order filed by STANDARD LAKESIDE I, LP (Defendant) + CRS# 806085508739 in Department 23 ask the Court to preclude Plaintiff from relying on, referencing, or using in deposition or written discovery crime statistics that are not tied to the subject property or the 2/12/2023 incident at issue in this case, and preclude deposition questioning and related discovery directed to unrelated crimes.

It is unreasonable and unrealistic to expect a lay individual to know generalized neighborhood crime statistics or to know how those statistics may have been generated. The issue is the foreseeability of crime on or at the subject property—i.e., what the witness knew—not whether unrelated crimes occurred at other locations at some prior date.

The motion is GRANTED on this basis. Plaintiff is precluded from relying on generalized crime statistics that do not relate to the subject property or the underlying incident in written discovery questions or deposition questions.

Number and scope of depositions: Defendants contend that the noticed depositions are duplicative and ask the Court to limit the number and scope of depositions to those which Plaintiff can show are non-duplicative, non-cumulative, proportional, and relevant. (See Mot. at p. 14.) The Court is unable to determine which depositions may be duplicative without more specific direction from the Defendants. As the moving party, Defendants have the burden to demonstrate good cause for the relief sought. (See e.g., Emerson Elec. Co. v. Superior Court (1997)16 Cal.4th 1101, 1110.) Accordingly, the request to limit depositions on this basis is DENIED.

Duplicative discovery: Defendants provide an example of duplicative discovery requests. Using Form Interrogatory – General, No. 15.1, Plaintiff previously requested “targeted attack” facts and information, identity and contact information of witnesses, as well as the identity and location of documents from SLI and from AMC. (Holley Decl. ¶ 13.) Notwithstanding that request, between 4/6/2026 and 4/15/2026 propounded further requests seeking information regarding Defendants’ “targeted attack” defense 14 separate times: Request for Production (“RFP”) Set 3 to SLI (#30); RFP Set 4 to AMC (#69); RFP Set 3 to AMC (# 72-74); RFP Set 3 to AMC (# 53- 54); Special Interrogatories (“SROGs”) Set 2 to SLI (#21-23); Form Interrogatories (“FROGs”) Set 1 to SPCI (#15.1); FROGs Set 1 to SLGP LLC (#15.1); RFA Set 1 to SPCI (#2); and RFP Set 1 to SLGP LLC (#2). (Ibid.)

The requests for “targeted attack” information from SLI and AMC are redundant, and the Court GRANTS IN PART Defendants’ protective order as to further “targeted attack” information sought from those entities.

Based on the example provided by Defendants, the Court agrees that it may be appropriate to impose reasonable limits and/or sequence discovery motions to prioritize issues that are central to the pending summary judgment motion. However, Defendants have not identified any other discovery sets, or requests, that they believe to be duplicative. (See supra Emerson Elec. Co.,16 Cal.4th at 1110.) Without more specific direction from Defendants, the Court is unable to

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV085509: GHANI vs STANDARD LAKESIDE I, LP, et al. 07/02/2026 Hearing on Motion for Protective Order filed by STANDARD LAKESIDE I, LP (Defendant) + CRS# 806085508739 in Department 23 determine which discovery sets or requests are duplicative or which motions should be prioritized. Accordingly, the motion is DENIED IN PART on this basis.

The Court expects the parties to meet and confer and resolve disputes informally prior to bringing matters before the Court. The parties are expected to notify the Court regarding the extent to which any of the pending discovery motions will narrow in scope as a result of this ruling.

Sanctions: The request for monetary sanctions is denied.