CHRISTOPHER RASCON vs. THE COUNTY OF LOS ANGELES

Case No.: 22STCV06583 Hearing Date: September 8, 2026 | Defendants' motion to quash Plaintiff's deposition subpoena for production of business records of the County of Los Angeles' County Equity Oversight Panel (CEOP) is

DENIED. On 2/23/2022, Plaintiff Christopher Rascon (Plaintiff) filed suit against the County of Los Angeles and Todd Jameson (collectively, Defendants), alleging: (1) racial discrimination; (2) racial harassment; (3) age discrimination; (4) age harassment; (5) retaliation; (6) failure to prevent. On 8/21/2026, Defendants moved to quash Plaintiff's deposition subpoena for production of business records of the County of Los Angeles' County Equity Oversight Panel (CEOP).

Discussion

Defendants argue that Plaintiff's subpoena is an improper attempt to obtain discovery directly from a represented party--the County of Los Angeles--through its non-party subdivision or instrumentality, thereby circumventing the formal discovery processes applicable to parties represented by counsel. The subpoena seeks County records regarding internal County Policy of Equity (CPOE) complaint investigations.

Defendants contend that these confidential records are protected by the official information privilege under California Evidence Code section 1040. The moving party asserting a privilege or privacy right bears the initial burden of establishing a prima facie case. Once a prima facie showing is made, the burden shifts to the party seeking discovery to demonstrate that the information is directly relevant, essential to a fair resolution of the lawsuit, and that the requesting party's interest outweighs the privilege holder's or affected person's confidentiality and privacy interests.

Here, the subpoena seeks "any and all documents" concerning two internal CPOE complaint investigations specifically involving Plaintiff, including designation letters, investigation materials, supporting documents, and interviews. As such, the documents do request records which contain private information. However, the Court finds that information is directly relevant and essential to the case as the records contain the investigative files relating to two internal CPOE complaint investigations specifically involving Plaintiff, including designation letters, investigation materials, supporting documents, and interviews. As such, Plaintiff's interest in the documents outweighs the privacy interests at stake.

Based on the foregoing, Defendants' motion to quash Plaintiff's deposition subpoena for production of business records of the County of Los Angeles' County Equity Oversight Panel (CEOP) is denied. It is so ordered. Dated: September, 2026 Hon. Jon R. Takasugi Judge of the Superior Court

Parties who intend to submit on this tentative must send an email to the court at [email protected] by 4 p.m. the day prior as directed by the instructions provided on the court website at www.lacourt.org. If a party submits on the tentative, the party's email must include the case number and must identify the party submitting on the tentative. If all parties to a motion submit, the court will adopt this tentative as the final order. If the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar. For more information, please contact the court clerk at (213) 633-0517.

Case Number: 24STCV28780 Hearing Date: September 8, 2026 Dept: 309 Superior Court of California County of Los Angeles DEPARTMENT 309 TENTATIVE RULING LORENA TAMAYO, et al. vs. FCA US, LLC, et al. |