Garcia vs. La Habra City School District

devoid of merit”].) Defendant’s anti-SLAPP motion relied on ample authorities that actions by a homeowners’ association can in fact constitute protected activity; that the court disagreed and found to the contrary, does not render the anti-SLAPP motion frivolous.

Defendant shall give notice.

4. Vangelos vs. Mehta

25-01520113

Motion for Sanctions

OFF CALENDAR 5. Garcia vs. La Habra City School District

25- 01535218 Motion to Quash Subpoena

Plaintiff Agustin Garcia’s motion to quash the records subpoena issued to nonparty deponent Providence St. Jude Medical Center is GRANTED. (See Code Civ. Proc., § 1987.1.)

This motion concerns the records subpoena issued by defendant La Habra City School District (defendant or District) to nonparty deponent Providence St. Jude Medical Center on 5/14/26, seeking any and all records pertaining to plaintiff without any limitation as to body part, medical condition, or subject matter, from 1/1/15 to the present. (Allton Decl. at Ex. A [subject subpoena].)

Plaintiff’s right to privacy in his medical and financial records is well established in law. (Vinson v. Superior Court (1987) 43 Cal.3d 833, 841 (Vinson) [medical records]; Davis v. Superior Court (1992) 7 Cal.App.4th 1008, 1014 (Davis) [medical records]; Cobb v. Superior Court (1979) 99 Cal.App.3d 543, 550 [financial information].)

Disclosure may be ordered when the information is directly relevant and essential to the fair resolution of the lawsuit, and where the need for disclosure outweighs privacy concerns. “The scope of any disclosure must be narrowly circumscribed, drawn with narrow specificity, and must proceed by the least intrusive manner. [Citation.]” (Davis, supra, 7 Cal.App.4th at p. 1014; see Williams v. Superior Court (2017) 3 Cal.5th 531, 552 [framework for determination of privacy objection]; Hill v. National Collegiate Athletic Assn. (1994) 7 Cal.4th 1, 35 (Hill) [same]; see also Puerto v. Superior Court (2008) 158 Cal.App.4th 1242, 1251 [harmonizing privacy analysis in pre and post-Hill decisions].) The party seeking disclosure of the constitutionally protected information bears the burden of establishing direct relevance. (Davis, supra, 7 Cal.App.4th at p. 1017.)

This has long been the law, there is nothing “bizarre” about it, and defendant has failed to meet this burden. While defendant is, to an extent, entitled to records concerning the body parts at issue in this action (see Vinson, supra, 43 Cal.3d at p. 842), this is not what the subpoena requests. The subpoena requests every single document concerning plaintiff regardless of body part or medical condition from a period of over 10 years.

To the Court, this is patently overbroad. (See, e.g., Hallendorf v. Superior Court (1978) 85 Cal.App.3d 553, 557.) Defendant fails to show how all of these records are directly relevant to this case. Defendant is not entitled to review plaintiff’s entire medical history in the hope that it may disclose some condition bearing on his present claims. (Davis, supra, 7 Cal.App.4th at p. 1017.) Defendant must show through evidence how the particular records sought are directly relevant and necessary; speculating that the records may reveal a contributing preexisting condition does not suffice. (Ibid.)

Sanctions are GRANTED in the amount of $1,650 in favor of plaintiff, and jointly and severally against defendant District and its counsel of record, Dominic A. Quiller, Esq. of McCune & Harber, LLP, payable within 30 days of notice. (See Code Civ. Proc., § 1987.2, subd. (a).) Defendant has opposed this motion without substantial justification, and the subpoena was oppressive as issued. (See Obregon v. Superior Court (1998) 67 Cal.App.4th 424, 431 [when discovery requests are grossly overbroad on their face, and hence do not appear reasonably related to a legitimate discovery need, a reasonable inference can be drawn of an intent to harass and improperly burden].)

Plaintiff shall give notice.

6. Doe vs. Country Village Preschool and Kindergarten

25-01497141

Motion to Quash Discovery Subpoena

Plaintiff JK Doe’s (a minor by and through her guardian ad litem, Christina Kayanan) motion to quash subpoenas is GRANTED IN PART and DENIED IN PART, as follows. (See Code Civ. Proc., § 1987.1.)

This motion concerns seven subpoenas issued by defendant Country Village Preschool and Kindergarten to the following nonparty deponents on 4/29/26: (1) Children’s Hospital of Orange County (CHOC) – medical records; (2) CHOC – billing records; (3) CHOC – radiology records; (4) Anthem Blue Cross Life and Health Insurance Company (Anthem); (5) Saddleback Valley Unified School District (Saddleback); (6) California Department of Social Services (CDSS),