Motion to Compel Further Responses to Initial Disclosures
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25CV117269: CONRADT vs THE PERMANENTE MEDICAL GROUP, A CALIFORNIA CORPORATION, et al. 07/02/2026 Hearing on Motion to Compel PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO INITIAL DISCLOSURES; filed by Maria Conradt (Plaintiff) CRS# 266364522404 in Department 20
Tentative Ruling - 06/30/2026 Karin Schwartz
The Motion to Compel Further Discovery Responses filed by Maria Conradt on 05/21/2026 is Granted in Part.
Plaintiffs motion to compel further responses to initial disclosures is GRANTED IN PART and DENIED IN PART.
This is an employment dispute. Plaintiff Maria Conradt (Plaintiff) initiated this action on April 1, 2025 for violations of the Fair Employment and Housing Act (FEHA) against Defendants The Permanente Medical Group, Inc. (TPMG) and Kaiser Permanente LLC.
On April 29, 2025, Plaintiff propounded a Demand for Initial Disclosures on Defendant pursuant to Code of Civil Procedure section 2016.090. Defendant served its initial disclosure responses on June 11, 2025. Defendant identified twelve (12) individuals as persons likely to have discoverable information, including nine (9) individuals currently employed by Defendant and Dr. Hidalgo. Defendant did not provide their contact information pursuant to section 2016.090(a)(1)(A).
The parties met and conferred thereafter regarding disclosure of individuals contact information. The parties were unable to resolve their dispute and Plaintiff filed the instant motion for disclosure of the individuals contact information. Plaintiff contends that the information is necessary to serve deposition and trial subpoenas. Plaintiff also requests monetary sanctions.
Trial courts are vested with wide discretion to allow or prohibit discovery and a civil litigants right to discovery is generally broad. (Williams v. Superior Court (2017) 3 Cal.5th 531, 540- 541.) The right to discovery includes the entitlement to learn the identity and locations of persons having knowledge of any discoverable matter. (Id. at p. 541.) The disclosure of the names and addresses of potential witnesses is a routine and essential part of pretrial discovery Indeed, our discovery system is founded on the understanding that parties use discovery to obtain names and contact information for possible witnesses as the starting point for further investigations. (Id. at p. 543, internal citations omitted.)
The party asserting a privacy right must establish a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious. (Williams at p. 552, citing
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The Court must then balance the competing considerations. (Id.)
TPMG submits the declaration of Sheila Pedroso, a Physician HR Leader for TPMG. Ms. Pedroso states based on her review of personnel information, that as of July 11, 2025, six of the individuals disclosed were TPMG Senior Physicians and Shareholders; the declaration further identifies Dr. Frey (Senior Physician), Ms. DeHaro (HR Generalist), and herself as TPMG personnel. (Pedroso Decl. ¶ 3.) The date presents a concern that the information provided may be stale, and Counsel for Plaintiff states that in meet and confer discussions, at least one identified witness is no longer with TPMG and/or is not represented by Defendants counsel. (Lewis Decl. ¶¶ 4, 16-19.)
TPMG contends that the disclosed witnesses, including physicians and/or management-level employees, have a reasonable expectation of privacy as to their personal contact information, which includes home addresses and telephone numbers. (Williams at p. 554 [absent employees have bona fide interest in confidentiality of their contact information, and home contact information is generally considered private].) While TPMG contends that there have been increased threats and violence directed at those working in the healthcare industry recently, TPMG provides no evidence to support this position to establish that a disclosure of the witnesses personal contact information would be a serious intrusion of their privacy rights.
Moreover, TPMG fails to address the unambiguous language of C.C.P. § 2016.090, which states that in a civil action, within 60 days of a partys demand, each party that has appeared in the action shall provide to the other parties an initial disclosure that includes, inter alia, [t]he names, addresses, telephone numbers, and email addresses of all persons likely to have discoverable information that the disclosing party may use to support its claims or defenses, or that is relevant to the subject matter of the action. (C.C.P. § 2016.090(a)(1)(A).)
In sum, TPMG failed to carry its threshold burden to show a serious intrusion under Williams, and even on balancing, the statutory mandate of section 2016.090 and the minimal sensitivity of the contact information outweigh the asserted interest. However, the disclosure of the contact information is not without sensitivity for reasons stated in TPMGs opposition. Accordingly, the Court exercises its discretion to order staged production of the information as needed, as set forth in more detail below.
The Court acknowledges that the statutory deadline under section 2016.090 has since passed on these disclosures sought by Plaintiff in April 2025. The Court exercises its discretion to permit Plaintiff to seek such information beyond the time limit set forth in the statute.
Notices of depositions of current TPMG employees presumably may be served in the ordinary course through counsel. As to disclosed witnesses who have separated from TPMG, however,
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
25CV117269: CONRADT vs THE PERMANENTE MEDICAL GROUP, A CALIFORNIA CORPORATION, et al. 07/02/2026 Hearing on Motion to Compel PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO INITIAL DISCLOSURES; filed by Maria Conradt (Plaintiff) CRS# 266364522404 in Department 20 TPMG shall disclose last-known contact information for the former employee(s) no later than July 17, 2026, subject to the parties protective order, so that any deposition subpoenas may be properly served. Finally, TPMG shall provide (last known) personal contact information for all of the individuals (i.e., current employee or not) no later than 120 days before the trial date, subject to the parties protective order, to allow Plaintiff to issue trial subpoenas as necessary in a timely manner.
This order is made without prejudice for Plaintiff to seek further relief in the event of unforeseen issues warranting the Court to reconsider this ruling.
The Court declines to award sanctions. TPMG acted with substantial justification.
If a party does not timely contest the foregoing Tentative Ruling and appear at the hearing, the Tentative Ruling will become the order of the court.
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