MAYA BLYTH VS. LEAL UGRIN ET AL

Matter on the Law & Motion/Discovery Calendar for Tuesday, October 8, 2025, line 2, PLAINTIFF MAYA BLYTH'S Motion To Compel The In Person Deposition Of Defendant Leal Ugrin With Production Of Documents And Request For Monetary Sanctions (tentative rulikng part 1 of 2)

Plaintiff Maya Blyth's motion to compel the deposition of defendant Leal Ugrin is granted in part and denied in part. The parties are ordered to meet and confer about scheduling the deposition on a mutually agreed date within 90 days of entry of this order. Ugrin is ordered to appear for the deposition on that mutually agreed date unless he obtains a protective order from this court.

The objections were served by email on August 29 four calendar days in advance of a deposition set for September 2. The court concludes they were timely. A party who objects to a deposition notice "waives any error or irregularity unless that party promptly serves a written objection specifying that error or irregularity at least three calendar days prior to the date for which the deposition is scheduled . . . ." (Code Civ. Proc., section 2025.410, subd. (a).) "If an objection is made three calendar days before the deposition date, the objecting party shall make personal service of that objection . . . on the party who gave notice of the deposition." (Id., section 2025.410, subd. (b).)

Thus, personal service is required only for objections made three days in advance. Here the objection was made four days in advance. It was thus properly served by email, and email service is "deemed complete at the time of the electronic transmission of the document or at the time that the electronic notification of service of the document is sent." (Id., section 1010.6, subd. (a)(3)(A).)

The parties may meet and confer about a new date for deposition. Medical needs are an appropriate basis for a deposition objection, and a party is not required to provide complete medical records in order to secure this kind of accommodation. Vesco v. Superior Court (2013) 221 Cal.App.4th 275 is inapposite; it relates to court orders concerning ADA accommodations and not the ordinary give and take of the meet and confer process.

Blyth further seeks an order requiring Ugrin to produce documents pursuant to the deposition notice. The court concludes that Ugrin's objections lack merit other than privilege objections, for which he must provide a privilege log. Ugrin is ordered to produce the documents sought in the deposition notice at deposition.