GARY ERWIN VS. BRIDGE HOUSING CORPORATION ET AL

SF Superior Court - Law & Motion / Discovery Dept 301 - CGC25626859 - August 28, 2026 Hearing date: August 28, 2026 Case number: CGC25626859 Case title: GARY ERWIN VS. BRIDGE HOUSING CORPORATION ET AL Case Number: | | CGC25626859 | Case Title: | | GARY ERWIN VS. BRIDGE HOUSING CORPORATION ET AL | Court Date: | | 2026-08-28 09:00 AM | Calendar Matter: | | Notice Of Motion And Motion For Protective Order Regarding Notice Of Deposition Of Lisa Laffer And Request For Production Of Documents | Rulings: | | On the Law & Motion/Discovery calendar for August 28, 2026, line 9. DEFENDANTS' Motion For Protective Order Regarding Notice Of Deposition Of Lisa Laffer And Request For Production Of Documents.

The motion for protective order prohibiting the deposition of Lisa Laffer, Chief Operating Officer of Bridge Housing, is granted in part and denied in part. Under the apex doctrine, "it amounts to an abuse of discretion to withhold a protective order when a plaintiff seeks to depose a corporate president, or corporate officer at the apex of the corporate hierarchy, absent a reasonable indication of the officer's personal knowledge of the case and absent exhaustion of less intrusive discovery methods." (Liberty Mutual Ins. Co. v. Superior Court (1992) 10 Cal.App.4th 1282, 1287.)

Here, plaintiff Gary Erwin shows that Laffer has verified discovery responses in this case and appears on relevant emails that have been produced. He has satisfied his burden that she has personal knowledge of issues in dispute. Moreover, Erwin volunteers reasonable limits: he will withdraw his current notice of deposition, seek Laffer's deposition only after deposing Bridge's person most qualified, withdraw his document requests to Laffer, and limit his deposition to no more than 90 minutes. These are reasonable parameters. The court adopts them as limitations on the Laffer deposition, but so long as Erwin maintains those limitations, a duly noticed deposition of Laffer may proceed. No sanctions are awarded; both parties' discovery positions have substantial justification.

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