TAMAR HO VS. FIVE KEYS SCHOOLS AND PROGRAMS ET AL

Matter on the Law & Motion / Discovery calendar for Thursday, July 10, 2025, Line 7. PLAINTIFF TAMAR HO's Motion To Compel Further Responses Re Defendant Five Keys Schools And Programs' Amended Responses To Plaintiff's Form Interrogatories, Employment, Set Two; And Request For Monetary Sanctions.

Plaintiff Tamar Ho's motion to compel defendant Five Keys Schools and Programs to provide further responses to Form Interrogatories, Employment, Set Two (No. 216.1), is granted, and the court grants her request for sanctions of $1,110.

Five Keys argues that requiring it to supply factual information about what witnesses and documents support its factual defenses invades its counsel's work product. The court disagrees. By asserting affirmative defenses, Five Keys puts at issue what facts, witnesses, and documents support those defenses. Answering Form Interrogatory 216.1 is not the same as disclosing counsel's legal analysis or evaluation of the case.

It appears the parties have resolved their dispute about contact information for witness Chantia Miller. The court orders that Ho safeguard the privacy of the contact information and use it only for the purposes of this litigation. Five Keys' objections are overruled. Five Keys is ordered to amend its responses to Form Interrogatory 216.1 within 10 days of entry of this order. Five Keys' discovery position lacked substantial justification. Five Keys is ordered to pay $1,110 to Ho within 30 days of entry of this order.

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