GREENHILL vs CINEMA WEST LLC

24CV003721: GREENHILL vs CINEMA WEST LLC 08/19/2025 Hearing on Motion to Compel Country Club Cinema, LLC to Provide Further Amended Responses to Request for Special Interrogatories, Set One in Department 53

Tentative Ruling

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24CV003721: GREENHILL vs CINEMA WEST LLC 08/19/2025 Hearing on Motion to Compel Country Club Cinema, LLC to Provide Further Amended Responses to Request for Special Interrogatories, Set One in Department 53

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TENTATIVE RULING: Plaintiff Shelby Greenhill’s motion to compel Defendant Country Club Cinema, LLC’s further response to special interrogatories is ruled upon as follows.

At issue on this motion is Defendant’s response to Plaintiff’s special interrogatories nos. 1 and 6. Plaintiff contends that Defendant’s responses are insufficient generally because Defendant failed to provide contact information for witnesses as requested in the interrogatories.

“On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that [...] [a]n answer to a particular interrogatory is evasive or incomplete ..[or] [a]n objection to an interrogatory is without merit or too general.” (CCP § 2030.300(a)(1), (3).

Special interrogatory no. 1 asked Defendant to identify all witnesses that “may have relevant information regarding Plaintiff and the allegations alleged in this lawsuit, including a summary of the information Defendant believes that person(s) may possess.” (Telfer Decl. Exh. 1.) Defendant objected to the interrogatory on the basis that it is compound, overbroad and violates the attorney-client and work product privileges. Subject to the objections, Defendant referred to its answers to form interrogatories 12.1 and 12.3.

Here, the Court agrees that special interrogatory, as drafted, is impermissibly overbroad as it requires Defendant to not only review the allegations in the complaint, some of which it may have no knowledge of, and attempt to provide a list of any person that may have knowledge of any allegation in the complaint. The Court thus sustains Defendant’s overbroad objection. Special interrogatory no. 1 is to be contrasted with an interrogatory which asks Defendant to list, for example, witnesses regarding a specific affirmative defense, or specific claim.

The Court notes that Defendant indicates that it offered to provide contact information for witnesses it identified. Nevertheless, the Court will not compel Defendant to provide a further response to special interrogatory no.

1. Nothing precludes Plaintiff from propounding a more narrowly tailored interrogatory.

Special interrogatory no. 6 asked for identification of each person involved in the decision to terminate Plaintiff’s employment. (Telfer Decl. Exh. 1.) Defendant provided a list of names and indicated that they may be contacted through Defendant’s counsel. Defendant contends the motion is unnecessary as to this interrogatory because it offered to provide the witness contact information. However, Defendant has not amended its response to do so.

The motion is denied as to special interrogatory no. 1 and granted as to special interrogatory no.

6.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

24CV003721: GREENHILL vs CINEMA WEST LLC 08/19/2025 Hearing on Motion to Compel Country Club Cinema, LLC to Provide Further Amended Responses to Request for Special Interrogatories, Set One in Department 53

No later than September 2, 2025, Defendant shall serve a further verified response to Plaintiff’s special interrogatory no. 6 as requested in the moving papers.

No sanctions were requested and none are awarded.

The minute order is effective immediately. No formal order pursuant to CRC Rule 3.1312 or further notice is required.