CARRILLO DE GARCIA, et al. v. FIRE INSURANCE EXCHANGE

grievances against Plaintiff by anyone without limitation by timeframe or subject matter, and all documents concerning the investigation into any complaints or grievances against Plaintiff by anyone without limitation by timeframe or subject matter.

From Plaintiff’s workers’ compensation claim administrator, Helmsman Management Services LLC, Defendant demands all documents concerning or related to any workers’ compensation claim filed by Plaintiff, including medical records and investigation material, without limitation by timeframe, subject matter, or relevance to Plaintiff’s claims. Additionally, even for documents directly relevant to Plaintiff’s claims, such as documents pertaining to Plaintiff’s workers’ compensation claim arising out of the injuries he sustained from being hit by a semi-truck in March of 2022 (FAC, ¶¶ 26, 37), the documents are still protected by Plaintiff’s right to privacy and Defendant has not shown that it has no less intrusive means to obtain them. (See, Allen v. Superior Court (1984) 151 Cal.App.4th 447, 453 [court abuses its discretion when it fails to require a less intrusive method of discovery].)

From Plaintiff’s subsequent employer, Elite Underground, Inc., Defendant requests the entirety of Plaintiff’s personnel file, all payroll records, and all documents mentioning any reason(s) for termination without limitation by timeframe, subject matter, or relevance to Plaintiff’s claims. Again, to the extent that records pertaining to mitigation are directly relevant to Defendant’s defense, they are nonetheless protected by Plaintiff’s right to privacy and Defendant has not shown that it has no less intrusive means to obtain them.

CARRILLO DE GARCIA, et al. v. FIRE INSURANCE EXCHANGE Case No. CU25-11016

Motion by Attorney Angela Russell to Be Relieved as Attorney of Record

TENTATIVE RULING

The motion is granted, with withdrawal effective only upon prompt service of the client of the signed order.

Join ZoomGov Meeting https://www.zoomgov.com/j/1602210102?pwd=emlhR29SczExam56NFFqWHFvSitmZz09

Meeting ID: 160 221 0102 Passcode: 650928

One tap mobile