Christopher Younger vs. Adventist Health and Rideout

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

Tentative Ruling

The motion of Plaintiff Christopher Younger, a minor, by and through his Guardian ad Litem, Eric Younger (“Plaintiff”) to compel further responses from Defendant Cerner Corporation (“Cerner”) to his Form Interrogatories, set one (“FIs”) is ruled upon as follows.

Background

This action concerns injuries Plaintiff sustained when he was 14 years old from untreated sepsis, septic thrombo-emboli, and endocarditis. (FAC ¶ 6.)

Plaintiff alleges that the causes of his injuries are two-fold: medical attention from various healthcare providers that fell below the relevant standard of care, and failures of Cerner’s electronic health record (“EHR”) software, which was being used by Defendant Adventist Health and Rideout dba Rideout Memorial Hospital (“Rideout”), where Plaintiff presented for treatment on August 25, 2021. (FAC ¶ 7.)

Plaintiff filed the Complaint in this action on January 3, 2023, alleging a single cause of action for medical negligence. On August 16, 2024, Plaintiff filed the operative, First Amended Complaint (“FAC”), adding Cerner as a defendant and causes of action for strict products liability, negligent products liability, and negligence.

On October 30, 2024, Cerner demurred to the causes of action alleged against it in the FAC (2nd – 4th causes of action), and the Court overruled the demurrer in its entirety on February 20, 2025. Cerner filed its Answer to the FAC on March 3, 2025.

Plaintiff served Cerner with the FIs on October 30, 2024. (Decl. of Mathew W. Clark ISO Mot. to Compel (“Clark Decl.”) ¶ 4, Ex. 1.) Cerner served unverified responses thereto on December 17, 2024. (Clark Decl. ¶ 5, Ex. 2.) Cerner provided a verification for its responses on February 5, 2025. (Clark Decl. ¶ 9, Ex. 6.)

On March 14, 2025, Cerner provided supplemental unverified responses to the FIs. (Clark Decl. ¶ 10, Ex. 7.) Cerner served a verification for its supplemental responses on March 23, 2025. (Clark Decl. ¶ 13, Ex. 9.)

After meeting and conferring regarding Cerner’s initial and supplemental responses to the FIs, the instant motion followed. The motion concerns FIs Nos. 4.1, 12.1-12.4, 12.6, 13.1, 13.2, and 15.1.

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

Discussion

A response to an interrogatory may consist of answers, objections, and/or the election to allow the inspection and copying of records. (Code Civ. Proc., § 2030.210, subd. (a).)

Responses must be “as complete and straightforward as the information reasonably available to the responding party permits.” (Code Civ. Proc., § 2030.220(a).) When an interrogatory cannot be answered completely, it must be answered to the extent possible. (Code Civ. Proc., § 2030.220(b).) Further, if the responding party does not have sufficient personal knowledge to fully respond to an interrogatory, the party may so state, but only after making a reasonable and good faith effort to obtain the information by asking other people and organizations, unless the information is equally available to the propounding party. (Code Civ.

Proc., § 2030.220(c); Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 406.) Responses should include all information that is then available to the responding party. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 782.)

When “an answer to an interrogatory would necessitate the preparation or making of a compilation, abstract, audit, or summary of or from the documents of the [responding party],” it is a sufficient answer to that interrogatory for the responding party to refer to Code of Civil Procedure section 2030.230 “and to specify the writings from which the answer may be derived or ascertained” “if the burden or expense of preparing [the compilation, etc.] would be substantially the same for the propounding and responding parties. (Code Civ. Proc., § 2030.230.) The responding party must describe the documents “in sufficient detail to permit the propounding party to locate and to identify, as readily as the responding party can, the documents from which the answer may be ascertained.” (Ibid.)

The propounding party may move to compel further responses to interrogatories if they deem that “(1) An answer to a particular interrogatory is evasive or incomplete[,] [¶] (2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate[,] [¶] [and/or] (3) An objection to an interrogatory is without merit or too general.” (Code Civ. Proc., § 2030.300(a).)

Applying the foregoing standards to Cerner’s responses to the subject FIs, the Court rules on Plaintiff’s Motion as follows.

No. 4.1:

Granted.

FI No. 4.1 asks:

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

At the time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of the INCIDENT? If so, for each policy state: (a) The kind of coverage; (b) The name and ADDRESS of the insurance company; (c) The name, ADDRESS, and telephone number of each named insured; (d) The policy number; (e) The limits of coverage for each type of coverage contained in the policy; (f) Whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and (g) The name, ADDRESS, and telephone number of the custodian of the policy. (Cerner’s Resp. to SS (“SS”) 1:17-2:1.)

Cerner’s original response to this FI states:

Cerner objects to this interrogatory as overbroad, unduly burdensome, and not relevant or reasonably calculated to lead to the discovery of admissible evidence as it pertains to plans through which Cerner may be insured in “any manner.” Cerner further objects to this interrogatory to the extent it seeks information protected by the attorney-client privilege, work product doctrine, common interest privilege or protection, joint defense privilege, risk management privilege, or any other privilege, protection, or immunity. Notwithstanding the foregoing objections and General Objections, Cerner has insurance. (a) Healthcare Liability

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

(b) National Fire & Marine Insurance Company, as administered by MedPro Group Company MedPro Group Attn: First Claim Reports 5814 Reed Road Fort Wayne, IN 46835 (c) Cerner Health Connections Inc.; Cerner Health Connections Inc. 2800 Rockcreek Pkwy MSW0141 Kansas City, MO 64117 (d) HN008655 (e) Professional Liability: $1,000,000 per event, $3,000,000 aggregate limit; General Liability: $1,000,000 per event, $3,000,000 aggregate limit, $3,000,000 products completed operations hazard aggregate limit, $1,000,000 personal and advertising injury limit; Cyber Liability and Breach Response: $50,000 per claim. (f) No (g) Not Applicable (SS 2:2-23.)

Cerner’s supplemental response provides information for an excess insurance policy “[s]ubject to and without waiving its General and Specific Objections.” (2:25-3:11.)

Plaintiff argues that it is entitled to a further response to this FI because, inter alia, Cerner “asserts various improper objections[,]” including “General Objections” that it made to every FI, collectively, and Cerner has stated in correspondence that its insurer has issued a declination of coverage, which is contrary to the information contained in Cerner’s verified responses. (SS 3:13-20.)

Cerner responds that its objections are entirely proper, but that it “is happy to supplement its response to reflect [the] denial of coverage.” (SS 4:26-5:4.) Cerner further responds that the issue

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

is now moot because it “is not withholding responsive information based on [its] objections” and has repeatedly told Plaintiff “that it has no additional responsive information to provide.” (SS 5:23-27.)

Plaintiff replies that “[i]f Cerner is not relying on objections or privileges to withhold information, it should say so, in verified responses,” not correspondence. (Reply 2:19-21.)

The Court agrees. The information Cerner has provided in meet and confer correspondence does not obviate its obligation to provide Code-compliant responses to the FIs. Code of Civil Procedure section 2030.220, subdivision (a), expressly requires the answer to each interrogatory to be “as complete and straightforward as the information reasonably available to the responding party permits.” Answers to interrogatories must “reveal all information that it then available to the responding party.” (Cal. Judges Benchbook: Civ. Proceedings – Discovery (CJER 2022) § 18.31, p. 457 [citing Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 782].)[1]

Cerner’s “General Objections” made as to the FIs, collectively, are overruled.[2] Objections to interrogatories “must be stated separately (no objections to entire set), and must bear the same number or letter as the interrogatory to which it is directed.” (Weil & Brown, Cal. Practice Guide: Civ. Procedure Before Trial (The Rutter Group 2024 Update) ¶ 8:1070 [citing Code Civ. Proc., § 2023.210, subd. (a)(3)].)

Cerner’s objection that the FI is overbroad and seeks information not relevant or reasonably calculated to lead to the discovery of admissible evidence is overruled.

Cerner’s objection that the FI is unduly burdensome is overruled. Undue burden objections must be accompanied by a specific factual showing setting forth the amount of work necessary to respond to the subject discovery. (West Pico Furniture Co. v. Superior Court (1961) 56 Cal.2d 407, 417-418.) Cerner’s opposition is devoid of any factual showing whatsoever.

Cerner’s remaining objection to the FI “to the extent it seeks information protected by the attorney-client privilege, work product doctrine, common interest privilege or protection, joint defense privilege, risk management privilege, or any other privilege, protection, or immunity” is also overruled. Cerner has not shown that these privileges or protections have any application to this FI.

Plaintiff is entitled to a further, Code-complaint response to FI No. 4.1 without objections.

No. 12.1

Granted.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

FI No. 12.1 asks:

State the name, ADDRESS, and telephone number of each individual: (a) Who witnessed the INCIDENT or the events occurring immediately before or after the INCIDENT; (b) Who made any statement at the scene of the INCIDENT; (c) Who heard any statements made about the incident by any individual at the scene; and (d) Who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code of Civil Procedure section 2034). (SS 6:2-9.) The FIs define “incident” as “the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” (SS 7:7-10.)

Cerner’s response to this FI states:

Cerner objects to the foregoing interrogatory on the grounds that it is premature, as Cerner recently was added as a party to this lawsuit, it has filed a demurrer, it has only begun to undertake its investigation, and discovery is just beginning. Cerner further objects to this interrogatory to the extent it seeks information outside Cerner[’s] knowledge. Cerner further objects to this interrogatory as overbroad insofar as it does not define the “INCIDENT.” Notwithstanding the foregoing objections and the General Objections, pursuant to California Code of Civil Procedure 2030.230, the answer to this interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from Cerner documents, and the burden or expense of preparing or making it would be substantially the same for Plaintiff as for Cerner, including in particular Plaintiffs’ medical records, from which the answer may be derived or ascertained.

Plaintiff already has these documents from which the answer may be ascertained.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

(SS 6:11-19.)

Plaintiff seeks a further response to this interrogatory, arguing that Cerner’s objections are improper and Cerner misuses Code of Civil Procedure section 2030.230 in its response because it does not sufficiently specify the documents from which Cerner claims Plaintiff can ascertain an answer. (SS 6:21-7:23.) Plaintiff argues that “[a] further response without improper objections and containing the information requested is needed.” (SS 7:22-23.)

Cerner rejoins that its objections are proper and that it has provided a Code-compliant response to this interrogatory. (SS 7:25-26, 9:10.) In particular, Cerner argues:

[This FI] seeks the identity of witnesses or individuals with knowledge of the “INCIDENT”—i.e., “the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” [Citation.] Cerner, however, is an EHR technology services provider; it is not a healthcare provider, and it was not present during Plaintiff’s visit to Rideout. Any Cerner employee who has knowledge about Plaintiff’s injuries are individuals who Cerner’s counsel has spoken with during their investigation of Plaintiff’s claims after Plaintiff filed this lawsuit.

These individuals have no non-privileged information specific to Plaintiff’s treatment at Rideout or injuries. Cerner has identified some of these individuals in response to other discovery requests where Plaintiff asked Cerner to identify Cerner personnel with relevant knowledge about, for example, the go-live of Cerner’s EHR software at Rideout, localized preferences relating to sepsis alerts, and training.

Cerner appropriately responded to Form Interrogatory 12.1 with the information within its knowledge by referring to Plaintiff’s medical records and Cerner documents concerning Mr. Younger. [Citation.] Referring to Plaintiff’s medical records is specific and appropriate where, as here, Plaintiff is familiar with and has access to his medical records, and they contain the identities of the doctors, nurses, and other healthcare providers who witnessed Plaintiff’s hospital visits and injuries. . . . Cerner . . . has not identified other individuals who witnessed the events at issue, who made or heard statements “at the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

scene,” or who have knowledge of the incident. Thus, there is no further information to provide in response to this form interrogatory. (SS 8:5-23.)

Plaintiff replies, inter alia, that Cerner improperly limits the scope of FI No. 12.1 to include only the events that occurred at Rideout. Plaintiff states that “incident” is defined in the FIs to include the “circumstances and events” surrounding Plaintiff’s injury, and Plaintiff has alleged that the installation, use, and defects in Cerner’s EHR was a cause of Plaintiff’s injuries. (Reply 4:8- 5:12.)

The Court agrees and finds that Cerner’s response to this interrogatory was improperly limited by the way Cerner construes the word “incident.” As defined in the FIs and framed by the FAC, “incident” includes not only Plaintiff’s medical treatment at Rideout, but also Cerner’s allegedly defective EHR software. (See, e.g., FAC ¶ 7.) Cerner’s response to Plaintiff’s separate statement makes clear that it limited its answer to this interrogatory to people with knowledge concerning the alleged medical negligence.

Cerner’s overbroad objection is overruled. The interrogatory does define the term “incident.”

Cerner’s objections that the FI is “premature” and “seeks information outside [of its] knowledge” are also overruled. They are not proper objections to an interrogatory. A plaintiff may propound interrogatories to a party without leave of court 10 or more days after the earlier of the service of the summons on, or appearance by, that party. (Code Civ. Proc., § 2030.020, subd. (b).) To the extent a responding party was only recently added to the litigation, the Civil Discovery Act only requires them to answer an interrogatory “as the information reasonably available to the responding party permits.” (Code Civ. Proc., § 2030.220, subd. (a).) Further, the Civil Discovery Act sets forth how a responding party should respond if they do not have personal knowledge sufficient to answer an interrogatory. (See Code Civ. Proc., § 2030.220, subd. (c).)

Finally, the Court finds that Cerner’s response to this interrogatory, to the extent it relies on Code of Civil Procedure section 2030.230, is insufficiently specific in its reference to “Cerner documents.” (See, e.g., Fuss v. Super. Ct. (1969) 273 Cal.App.2d 807, 815-817.)

Plaintiff is entitled to a further, Code-complaint response to FI No. 12.1 without objections.

Nos. 12.2-12.4, 12.6

Denied.

These interrogatories request information regarding the existence of any interviews,

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

written/recorded statements, photographs/films/videotapes, and reports concerning the incident. (SS 10:15-21, 16:1-8, 22:1-10, 28:3-8.)

Cerner responded by interposing objections that the interrogatories are premature and overbroad as they do not define “incident.” (SS 10:23-11:4, 16:9-17, 22:11-19, 28:10-18.) Cerner also objects to the extent the interrogatories seek information protected by the attorney-client privilege, word product doctrine, common interest privilege or protection, joint defense privilege, risk management privilege, or any other privilege, protection, or immunity. (Ibid.)

Notwithstanding the stated objections, Cerner responds “not that Cerner is aware of” (FI No. 12.2), “not that Cerner is aware of, other than Plaintiff’s medical records” (FI No. 12.3), “not that Cerner is aware of, other than what Plaintiff has produced” (FI No. 12.4), and “not that Cerner is aware of, other than Plaintiff’s medical records.” (Ibid.)

Plaintiff argues that further responses to these interrogatories are warranted because the objections asserted are meritless and the remaining responses are legally deficient and evasive because “it is not clear that Cerner sought information under its control.” (See, e.g., SS 12:21- 25.)

Cerner responds that there is nothing improper about its responses – the objections are “entirely proper,” and the responses “are complete and accurate. Cerner has no additional information.” (See, e.g., SS 13:12-13, 14:4-5.)[3]

Cerner’s “premature” and “overbroad” objections are overruled for the same reasons stated concerning FI No. 12.1.

Cerner’s objections “to the extent” the interrogatories seek information protected by the attorneyclient privilege, work product doctrine, or any other privilege/protection are also overruled as Cerner has provided no factual basis in the responses or the SS to support their application. “In response to a motion to compel answers [citation], the burden is on the party claiming a privilege to establish whatever preliminary facts are essential to the claim.” (Weil & Brown, supra, at ¶ 8:192 [citing Evid. Code, §§ 402, 405; Lopez v. Watchtower Bible & Tract Soc. Of New York, Inc. (2016) 246 Cal.App.4th 566, 596].) “Usually this is done by filing declarations in opposition to the motion to compel [citation].” (Weil & Brown, supra, at ¶ 8:1074; accord id., at ¶¶ 8:1179, 8:1179.1.)

However, the Court finds that a further response to these interrogatories is not required since Cerner provided responses to each of them notwithstanding the stated objections.

The Court finds that Cerner’s response, “not that Cerner is aware of,” is not evasive and is

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

sufficient under the Civil Discovery Act. Unlike responses to requests for production of documents, answers to interrogatories do not require an express affirmation that a diligent search and a reasonably inquiry have been made in an effort to comply with the request. (Compare Code Civ. Proc., § 2031.230 with § 2030.220, subd. (c).)

Nos. 13.1 and 13.2

Denied.

These FIs ask for information concerning any surveillance done by Cerner or anyone acting on its behalf of any party to this action or individual involved in the incident. (SS 34:6-13, 39:8-14.)

Cerner responded by interposing objections that the interrogatories are premature and overbroad as they do not define “incident.” (SS 34:15-22, 39:15-23.) Cerner also objected “to the extent [the interrogatories] seek[] information protected by the attorney-client privilege, word product doctrine, common interest privilege or protection, joint defense privilege, risk management privilege, or any other privilege, protection, or immunity.” (Ibid.) Notwithstanding the stated objections, Cerner responded, “not that Cerner is aware of.” (Ibid.)

Plaintiff argues that further responses to these interrogatories are warranted because the objections asserted are meritless and the remaining responses are legally deficient and evasive because “it is not clear that Cerner sought information under its control.” (See, e.g., SS 35:6-11, 36:7-17.)

Cerner responds that there is nothing improper about its responses – the objections are straightforward and proper, and the responses are as complete and straightforward as the information available to Cerner permitted at the time it served the responses. (See, e.g., SS 37:1- 8.) Cerner further rejoins that “it has no additional responsive information to provide.” (SS 38:38:8-10, 43:9-11.)

Here, the Court incorporates by reference its ruling concerning FI Nos. 12.2-12.4, and 12.6.

No. 15.1

Granted.

FI No. 15.1 asks for information regarding Cerner’s denials and affirmative defenses. (SS 44:10- 17.)

In its original response to this interrogatory, Cerner interposed objections on the grounds that it is premature (at the time it served its original responses, Cerner had not yet answered) and to the

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

extent it seeks information protected by the attorney-client privilege, work product doctrine, or any other privilege/protection. (SS 44:19-27.) Notwithstanding its objections, Cerner responded that it “reserves the right to supplement this response.” (Ibid.)

After filing its Answer, Cerner supplemented its response to this interrogatory as follows:

Subject to and without waiving the foregoing objections, this interrogatory is premature. Cerner has made denials and raised affirmative, special, and other defenses in its Answer to Plaintiff’s First Amended Complaint in accordance with California law. These denials and affirmative, special, and other defenses were asserted to protect Cerner’s legal rights and preserve such defenses. Cerner reserves the right to further respond to this interrogatory. (SS 45:2-6.)

Plaintiff argues that a further response to FI No. 15.1 should be compelled since it is no longer premature, i.e., Cerner has answered, and the privilege/protection objections are meritless and improper. (SS 45:11-15, 46:4-8.) Plaintiff states that Cerner has not provided any information concerning its denials or affirmative defenses, and its response that it “reserves the right to supplement this response” is “patently incomplete and evasive.” (SS 46:9-17.)

Cerner responds that its objections are entirely proper and it appropriately responded that it will supplement its response as it continues to investigate Plaintiff’s claims. (SS 46:26-47:11.)

Cerner’s premature objection is overruled. It filed an Answer before serving its supplemental responses to this interrogatory. Cerner’s objections “to the extent” the interrogatories seek information protected by the attorney-client privilege, work product doctrine, or any other privilege/protection are also overruled as Cerner has provided no factual basis in the responses or the SS to support their application.

Further, Cerner’s response, which was made subject to its objections, is inadequate.

Plaintiff is entitled to a further, Code-complaint response to FI No. 15.1 without objections. Cerner must identify each denial of a material allegation and affirmative defense in its Answer and for each provide the information that is responsive to subparts (a)-(c).

Conclusion

For the stated reasons, Plaintiff’s motion is granted in part and denied in part.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

Cerner must provide further Code-compliant responses to FIs 4.1, 12.1, and 15.1, without objections, no later than August 1, 2025, unless the parties mutually agree in writing to a later date.

The parties’ respective requests for monetary sanctions are denied given the mixed ruling on the motion.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.)

[1] The Court notes that Cerner makes its “moot” argument in response to several of the subject FIs. The Court’s ruling, here, applies to each of the FIs where Cerner has made this argument. [2] The “General Objections” are overruled as to all of the FIs at issue in this motion.

[3] Cerner also responds that Plaintiff has responded similarly to some of the same FIs, thereby demonstrating the appropriateness of Cerner’s responses and objections. (See, e.g., SS 13:11-12 [“Plaintiff took the same approach when responding to discovery.”]; SS 13:14-15 [“Indeed, Plaintiff asserted similar privilege objections to some of the very same form interrogatories.”].) Plaintiff’s responses to Cerner’s written discovery are not before the Court and are immaterial to the Court’s decision on this motion.

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Law and Motion Oral Argument Request Line at (916) 874-2615 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2023-00332374-CU-MM-GDS: Christopher Younger vs. Adventist Health and Rideout 07/01/2025 Hearing on Motion to Compel Further Responses Form Interrogatories in Department 54

to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings. The Department 53/54 Zoom Link is https://saccourt-cagov.zoomgov.com/my/sscdept53.54 and the Zoom Meeting ID is 161 4650 6749. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.pdf.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.