Palma vs. South Orange County Community College District

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# Case Name Tentative

1. 2026-1539145 Defendants South Orange County Community College District (the Palma vs. “District”), Board of Trustees for the South Orange County South Orange Community College District, Bradley Fowler, Christine Lillja, and County Letitia Clark have demurred to plaintiff William Palma’s complaint Community and each of its 19 causes of action. [ROA # 71.] College District Defendant Dennis Walsh has separately demurred to Plaintiff’s complaint. [ROA #95.]

Both demurrers were served on Plaintiff, a self-represented litigant, by email. [See POS at ROA ## 71, 95.]

A self-represented litigant may not be served by email unless he expressly consents.

Express consent to electronic service is accomplished either by (i) serving a notice on all other parties and filing it with the court, or (ii) “[m]anifesting affirmative consent through electronic means with the court or the court’s electronic filing service provider, and concurrently providing the party’s electronic address with that consent for the purpose of receiving electronic service. The act of

electronic filing shall not be construed as express consent.” Code Civ. Proc. § 1010.6(c)(3); see CRC 2.251(b)(1).

Nothing in the Court’s file establishes that Plaintiff expressly consented to electronic service.

Accordingly, the hearing on the demurrers is continued to October 21, 2026, at 10:00 a.m., to allow Defendants to properly serve Plaintiff with the demurrers and notice of the continued hearing.

2. 2023-1311590 The unopposed motion of plaintiff CEP America – California dba CEP America - Vituity for an order sealing court records is granted. [ROA #871.] California vs. Citrus Valley Plaintiff moves, under Rule 2.550, for an order sealing the Physicians unredacted version of the transcript and Exhibit 352. The Group, A redactions include references to contracted reimbursement rates for Medical emergency services that Vituity has negotiated with payors. Corporation Plaintiff contends these rates constitute “confidential business and proprietary information.” Plaintiff also seeks to protect the Independent Physician Association (IPA) identity as not germane to this action and because disclosure would prejudice the IPA and limit Plaintiff’s ability to contract in the future with other IPAs. [See Kuo Decl. (ROA #468), ¶ 4.]

The court may order that a record be filed under seal only if it expressly finds facts that establish that: • there exists an overriding interest that overcomes the right of public access to the record; • the overriding interest supports sealing the record; • a substantial probability exists that the overriding interest will be prejudiced if the record is not sealed; • the proposed sealing is narrowly tailored; and • no less restrictive means exist to achieve the overriding interest. (Cal. R. Ct. Rule 2.550(d).)

Here, Plaintiff has provided Kuo’s supporting declaration. The court finds this information qualifies for protection as a trade secret, and that the harm that could occur if this information were disclosed to Plaintiff’s competitors and others is clear.

Further, Plaintiff complied with the rule by lodging unredacted copies and redacting only the information necessary to protect the trade secret information. Accordingly, the court finds Plaintiff has made the showing necessary for an order allowing Plaintiff to file the unredacted declaration (and accompanying exhibits) under seal. McGuan v. Endovascular Technologies, Inc. (2010) 182 Cal.App.4th 974, 988.