JANE ROE, AN INDIVIDUAL vs. SAN RAFAEL CITY SCHOOLS, A PUBLIC ENTITY, ET AL

The matter is before the Court on Plaintiff’s motion to compel further responses to requests for production of documents. Many of the disputes between the parties have been resolved through the able assistance of John Feeney, Esq., the Court’s Discovery Facilitator. The Court appreciates Mr. Feeney’s efforts in this matter.

As to the remaining disputes, the parties adopt different approaches to identifying the outstanding discovery disputes. The Court adopts both the format and the recommendations of the Discovery Facilitator in his letter to the parties dated May 12, 2026 (Nos. 1-12). The Court adopts the recommendations subject to the following findings and modifications.

First, any statutory or constitutional privacy rights that attach to the records and information in this case are not absolute. Plaintiff has justified the need for disclosure with a competing and compelling interest in vindicating her rights. In this context, concerns for privacy can be addressed by conditioning production on the entry of a Protective Order. Therefore, within ten (10) days of the Court’s ruling in this matter, the parties shall submit to the Court a proposed stipulated protective order to govern discovery in this case.

Second, the producing party is authorized to redact personally identifiable financial information, such as social security or financial account numbers, from any document it produces.

Third, as to the identity of individual students (other than Plaintiff) contained in the records to be produced, the producing party may redact the student’s name prior to production without prejudice to Plaintiff renewing the request to obtain this information based on showing of need. If the parties are unable to agree on the need to provide the name after meeting and

conferring, Plaintiff may renew its request to the Court to compel the production of the person’s name.

The Court sets the relevant time period for documents to be produced from 2008 to 2014 (three years before and after the alleged conduct). Except that there are no time limitations as to complaints, investigations, or reports of alleged sexual harassment or misconduct by Defendant Bosque with students, and further that time limitations do not apply to documents regarding the hiring or termination of Defendant Bosque.

All parties must comply with Marin County Superior Court Local Rules, Rule 2.10(B) to contest the tentative decision. Parties who request oral argument are required to appear in person or remotely by ZOOM. Regardless of whether a party requests oral argument in accordance with Rule 2.10(B), the prevailing party shall prepare an order consistent with the announced ruling as required by Marin County Superior Court Local Rules, Rule 2.11.