GREENHILL vs CINEMA WEST LLC

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

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

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.

TENTATIVE RULING: Plaintiff Shelby Greenhill’s motion to compel Defendant Country Club Cinema, LLC’s further responses to requests for admissions is granted.

At issue on this motion is Defendant’s response to Plaintiff’s requests for admissions nos. 1 and 3. Plaintiff contends that Defendant’s responses are insufficient.

“On receipt of a response to requests for admission, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (1) An answer to a particular request is evasive or incomplete. (2) An objection to a particular request is without merit or too general.” (CCP § 2033.290(a).)

Request for admission no. 1 asked Defendant to admit that it terminated Plaintiff after she made health and safety complaints. Defendant objected that the request was compound and subject to the objection “admitted that Plaintiff’s employment was terminated.” (Telfer Decl. Exh. 2.) First, the Court overrules the compound objection. CCP § 2033.060(f) requires that requests for admission not be “compound, conjunctive or disjunctive.” Case law interpreting that identical language in Section 2030.060(f) governing interrogatories suggests that a practical approach be taken to such an objection and that the prohibition against compound, conjunctive, or disjunctive interrogatories should likely only apply where the interrogatory covers more than a single subject. (Clement v.

Alegre (2009) 177 Cal.App.4th 1277, 1291.) A similar approach to the identical language governing requests for admissions is appropriate. Here, the request covers a single subject (Plaintiff’s termination) and the compound objection is overruled. In addition, the substantive portion of the request is somewhat evasive because while admitting that Plaintiff’s employment was terminated, the request asked for an admission that Plaintiff’s was terminated after she made certain complaints. A further response must be provided removing the compound objection and directly responding to the request as stated.

Request no. 3 asked Defendant to admit that it “hired an usher who was a pedophile during Plaintiff’s employment.” Defendant objected on the grounds of privacy and declined to answer. Defendant’s privacy objection is overruled. The right to privacy provided for in Cal. Const., art. I, § 1 may be invoked by a litigant as justification for refusal to answer questions or respond to requests for information that unreasonably intrude on that right. A plaintiff asserting a privacy claim has the burden of establishing each element, specifically: 1. A legally protected privacy interest; 2. A reasonable expectation of privacy; and 3. A serious invasion of the privacy interest. (See, e.g. Hill v. National Collegiate Athletic Assn. (1994) 7 Cal. 4th 1) “Only obvious invasions of interests fundamental to personal autonomy must be supported by a compelling interest.”

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 Responsive Documents to Request for Admissions, Set One in Department 53

(Williams v. Superior Court (2017) 3 Cal.5th 531, 557.) Here, the framework for evaluating a privacy claim is not implicated. Answering the subject request only requires Defendant to respond “admit” or “deny”. There is no disclosure of any private information through such a response. It does not disclose any individual’s identity. The privacy objection must be removed from a further response and a substantive answer shall be provided.

The motion is granted.

No later than September 2, 2025, Defendant shall serve a further verified response to Plaintiff’s requests for admissions nos. 1 and 3 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.