JANE DOE VS. ERIC RHEINHEIMER

SF Superior Court - Law & Motion / Discovery Dept 302 - CGC24617680 - May 13, 2026 Hearing date: May 13, 2026 Case number: CGC24617680 Case title: JANE DOE VS. ERIC RHEINHEIMER Case Number: | | CGC24617680 | Case Title: | | JANE DOE VS. ERIC RHEINHEIMER | Court Date: | | 2026-05-13 09:00 AM | Calendar Matter: | | Notice Of Motion And Motion Per Ccp Section 2025.420 To Quash Defendant?S April 27th, 2026, Notice To Plaintiff; Motion For Protective Order; And Request For Sanctions | Rulings: | | Set for Law and Motion/Discovery on Wednesday, May 13, 2026, Line 4, PLAINTIFF JANE DOE's Motion Per CCP Section 2025.420 To Quash Defendant'S April 27th, 2026, Notice To Plaintiff; Motion For Protective Order; And Request For Sanctions.

Plaintiff Jane Doe's Motion Per CCP Section 2025.420 To Quash Defendant's April 27th, 2026, Notice To Plaintiff; Motion For Protective Order; And Request For Sanctions is GRANTED IN PART AND DENIED IN PART.

Under Code of Civil Procedure section 2025.420, the court may, for good cause shown, issue any order justice requires to protect a party or other person from unwarranted annoyance, embarrassment, oppression, or undue burden and expense. Protective orders are commonly granted to prevent disclosure of sensitive or proprietary information, including trade secrets and confidential business materials. (See Code of Civil Procedure section 2031.060 (b)(5); In re Providian Credit Card Cases (2002) 96 Cal.App.4th 292, 298-299.)

Plaintiff has withdrawn her request regarding the taking of the deposition and the timing. Plaintiff has not shown good cause to exclude Defendant from the deposition other than by audio connection. Defendant's video presence will not offend the civil protective order in place. The court finds good cause to order-and so orders-that Defendant shall not record the deposition or have unsupervised access to any recording until further order of the court.

The court finds good cause generally to address issues under Code of Civil Procedure section 2017.220. The court has balanced Plaintiff's substantial privacy interests and Defendant's substantial interest in development of an adequate and fair record to defend against Plaintiff's claims against him.

Good cause appearing, Defendant may make reasonable inquiry into pregnancies. Defendant shall not inquire into abortions. Defendant may make reasonable inquiry into Plaintiff's sexual history going back seven years before the earliest events at issue in this proceeding. Defendant may make reasonable inquiry into Plaintiff's sexual partners going back seven years before the earliest events at issue in this proceeding.

The parties are ordered to meet and confer before and during the deposition regarding the precise scope. The parties are advised to have a discovery referee in place or a noticed motion set for hearing on same, if they plan to raise several issues on these topics after the deposition.

Plaintiff's request in her reply that the court appoint a referee is denied without prejudice. A noticed motion is required. The court declines to award sanctions. (Part 1 of 2, tentative ruling continues in next entry) | |