VAUGHN vs ALAMEDA HEALTH SYSTEM

24CV072825: VAUGHN vs ALAMEDA HEALTH SYSTEM 08/19/2026 Hearing on Motion for Protective Order filed by Alameda Health System (Defendant) CRS# 819535502781 in Department 20

Tentative Ruling - 08/17/2026 Thomas Weathers

The Motion for Protective Order filed by Alameda Health System on 07/02/2026 is Granted in Part.

Defendant Alameda Health System’s Motion for Protective Order is GRANTED IN PART.

This action involves an employment dispute. Plaintiff Takiyah Vaughn initiated this action against Defendant Alameda Health System (“Defendant” or “AHS”) on April 24, 2024. The operative First Amended Complaint (“FAC”) filed on May 29, 2024 alleges (1) Race and Gender Discrimination in Violation of the Fair Employment and Housing Act (“FEHA”); (2) Harassment; (3) Hostile Work Environment Retaliation; (4) Failure to Prevent Discrimination, Harassment, and Retaliation; (5) Retaliation; and (6) Whistleblower Retaliation in Violation of Labor Code § 1102.5.

On April 7, 2026, Plaintiff served AHS with a Notice of Deposition of AHS’s Person Most Qualified (“PMQ”). (Fuller Decl. ¶ 3, Exh. 1.) The notice identified approximately 29 examination topics for the PMQ. (Id. pp. 3-4.) AHS objected to the notice on April 13, 2026. (Id. ¶ 4, Exh. 2.) The parties met and conferred thereafter regarding, inter alia, the PMQ deposition notice. (Id. ¶ 5.) Plaintiff agreed to narrow the amount, scope, and time frame of the noticed topics. (Id.) Plaintiff served an amended notice of deposition on May 28, 2026, but reiterated the prior examination topics. (Id. ¶ 7, Exh. 4.) Defendant objected and the parties met and conferred again regarding the amended notice. (Id. ¶¶ 8-10, Exhs. 5 and 6.)

Defendant now moves for a protective order to preclude Topic Nos. 3 and 9; preclude or consolidate duplicative Topic Nos. 11, 12, 16, 17, and 19; and to revise/narrow Topics 1, 2, 5, 6, 14, 21, 22, 23, 24, as well as mis-numbered Topic Nos. “1-5”, listed between Nos. 23 and 24.

On July 23, 2026, the Court granted in part Defendant’s ex parte application to advance the hearing date on the instant motion. The Order further states the following in pertinent part:

Finally, the Court has reviewed the underlying motion itself and orders the parties to meet and confer to see if they can resolve the issue consensually. The Court offers the following nonbinding tentative thoughts based on the limited record before it.

Topic 3 - probable grant

Topic 9 - probable deny, but defendants are free to identify more than one PMQ as appropriate 24CV072825: VAUGHN vs ALAMEDA HEALTH SYSTEM 08/19/2026 Hearing on Motion for Protective Order filed by Alameda Health System (Defendant) CRS# 819535502781 in Department 20 Topics 11, 12, 16, 17, 19 - probable deny as to 11, 16, 17, and 19, probable grant as to 12 (not really a proper PMQ topic; plaintiff can probably obtain this information through RFPs and other discovery devices).

Topics 1, 2, 5, 6, 14, 21, 22, 23 - Topic 1 probable grant (parties should be able to resolve this issue by stipulation or RFAs instead of a deposition); Topics 2, 14, 22 probable grant; Topics 5, 6, 21 probable deny; Topic 22 probable grant, not a proper PMQ topic; Topic 23 - probable grant, best resolved by an RFP or other discovery device.

(7/23/26 Order.)

Plaintiff filed a Non-Opposition to the Court’s July 23, 2026 Order, stating that she did not agree with Defendant’s proposed scope of the Protected Order, but did not intend to further oppose the Motion in light of the Court’s statements in the July 23, 2026 Order.

Before, during, or after a deposition, a party may promptly move for a protective order. (C.C.P. § 2025.420(a).) “The Court, for good cause shown, may make an order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense.” (Id., subd. (b).) In determining whether to issue a protective order, the trial court must weigh the competing needs and interests of the parties in regulating pretrial discovery. (Obregon v. Superior Court (1998) 67 Cal.App.4th 424, 431.)

In light of the record before the Court, including Plaintiff’s Non-Opposition to the July 23, 2026, Order, the Court now rules as follows:

As to Topic Nos. 1, 2, 3, 12, 14, 22, and 23 the motion is GRANTED. The requested topics may be better addressed via other discovery mechanisms, i.e., requests for production of documents or requests for admissions.

As to Topic Nos. “1” [sic], “2” [sic], “3” [sic], “4” [sic], “5” [sic] (listed in between Nos. 23 and 24 in both the original notice and amended notice of deposition), the motion is GRANTED. The requests as written fail to describe with reasonable particularity the matters for examination. The requested topics may be better addressed via written interrogatories.

As to Topic Nos. 5, 6, 9, 11, 16, 17, 19, 21, and 24 the motion is DENIED. Defendants may identify additional PMQ(s) as appropriate to address these topics.

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.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

24CV072825: VAUGHN vs ALAMEDA HEALTH SYSTEM 08/19/2026 Hearing on Motion for Protective Order filed by Alameda Health System (Defendant) CRS# 819535502781 in Department 20 HOW DO I CONTEST A TENTATIVE RULING?

THROUGH ECOURT Notify the Court and all the other parties no later than 4:00 PM one court day before the scheduled hearing, and briefly identify the issues you wish to argue through the following steps: 1. Log into eCourt Public Portal 2. Case Search 3. Enter the Case Number and select "Search" 4. Select the Case Name 5. Select the Tentative Rulings Tab 6. Select "Click to Contest this Ruling" 7. Enter your Name and Reason for Contesting 8. Select "Proceed" BY EMAIL Send an email to the DEPARTMENT CLERK and all the other parties no later than 4:00 PM one court day before the scheduled hearing. This will permit the department clerk to send invitations to counsel to appear remotely.

BOTH ECOURT AND EMAIL notices are required.