This case was last updated from Los Angeles County Superior Courts on 08/15/2019 at 09:25:25 (UTC).

MARIA LILIANA RAMIREZ VS CITRUS COMMUNITY COLLEGE DISTRICT

Case Summary

On 06/05/2017 MARIA LILIANA RAMIREZ filed a Personal Injury - Other Personal Injury lawsuit against CITRUS COMMUNITY COLLEGE DISTRICT. This case was filed in Los Angeles County Superior Courts, Pomona Courthouse South located in Los Angeles, California. The Judges overseeing this case are PETER A. HERNANDEZ and DUKES, ROBERT A.. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ****4056

  • Filing Date:

    06/05/2017

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Personal Injury - Other Personal Injury

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judges

PETER A. HERNANDEZ

DUKES, ROBERT A.

 

Party Details

Petitioner and Plaintiff

RAMIREZ MARIA LILIANA

Respondents and Defendants

SAMMIS ROBERT

DOE DEFENDANTS I TO 10

MAGELLAN ERIC

CITRUS COMMUNITY COLLEGE DISTRICT

PATINO VINCENT

Attorney/Law Firm Details

Petitioner and Plaintiff Attorneys

BOUCHER RAYMOND P. ESQ.

BOUCHER RAYMOND P. LAW OFFICES OF

BOUCHER RAYMOND PAUL

BEDNARSKI MARILYN ESQ.

Defendant Attorneys

WALSH DENNIS J. ESQ.

WALSH DENNIS JOHN ESQ.

HANEY BUCHANAN & PATTERSON

 

Court Documents

Unknown

6/5/2017: Unknown

Unknown

6/5/2017: Unknown

NOTICE OF PETITION AND PETITION PURSUANT TO GOVERNMENT CODE 946.6.TO BE RELIEVED FROM THE :CLAIM:FILING REQUIREMENT OF GOVERNMENT CODE ? 945.4; ETC.

6/6/2017: NOTICE OF PETITION AND PETITION PURSUANT TO GOVERNMENT CODE 946.6.TO BE RELIEVED FROM THE :CLAIM:FILING REQUIREMENT OF GOVERNMENT CODE ? 945.4; ETC.

PROOF OF SERVICE

6/6/2017: PROOF OF SERVICE

DECLARATION OF MARIA LILIANA RAMIREZ IN SUPPORT OF PLAINTIFF'S PETITION PURSUANT TO GOV. CODE ? 946.6

6/6/2017: DECLARATION OF MARIA LILIANA RAMIREZ IN SUPPORT OF PLAINTIFF'S PETITION PURSUANT TO GOV. CODE ? 946.6

DECLARATION OF BRIAN M. BUSH AND ATTACHED EXHIBITS IN SUPPORT OF PETITION PURSUANT TO GOVERNMENT CODE ? 946.6 TO BE RELIEVED FROM THE CLAIM FILING REQUIREMENT OF GOVERNMENT CODE ? 945.4

6/6/2017: DECLARATION OF BRIAN M. BUSH AND ATTACHED EXHIBITS IN SUPPORT OF PETITION PURSUANT TO GOVERNMENT CODE ? 946.6 TO BE RELIEVED FROM THE CLAIM FILING REQUIREMENT OF GOVERNMENT CODE ? 945.4

RESPONDENTS' OPPOSITION TO PETITIONER'S PETITION PURSUANT TO GOVERNMENT CODE SECTION 946.6 TO BE RELIEVED FROM THE CLAIM FILING REQUIREMENT OF GOVERNMENT CODE SECTION 945.4

6/22/2017: RESPONDENTS' OPPOSITION TO PETITIONER'S PETITION PURSUANT TO GOVERNMENT CODE SECTION 946.6 TO BE RELIEVED FROM THE CLAIM FILING REQUIREMENT OF GOVERNMENT CODE SECTION 945.4

Legacy Document

6/27/2017: Legacy Document

Minute Order

6/27/2017: Minute Order

Minute Order

6/27/2017: Minute Order

Notice of Case Management Conference

7/6/2017: Notice of Case Management Conference

Proof of Personal Service

7/31/2017: Proof of Personal Service

Proof of Personal Service

7/31/2017: Proof of Personal Service

Proof of Service by Substituted Service

7/31/2017: Proof of Service by Substituted Service

Proof of Personal Service

7/31/2017: Proof of Personal Service

Legacy Document

8/25/2017: Legacy Document

Proof of Service (not Summons and Complaint)

9/15/2017: Proof of Service (not Summons and Complaint)

Case Management Statement

9/15/2017: Case Management Statement

44 More Documents Available

 

Docket Entries

  • 10/21/2019
  • Hearingat 08:30 AM in Department O at 400 Civic Center Plaza, Pomona, CA 91766; Trial Setting Conference

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  • 03/06/2019
  • Docketat 08:30 AM in Department O, Peter A. Hernandez, Presiding; Jury Trial - Not Held - Advanced and Vacated

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  • 03/05/2019
  • DocketNotice (of Order); Filed by Maria Liliana Ramirez (Plaintiff)

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  • 03/04/2019
  • DocketAffidavit (Affidavit of Fault re Failure to Appear); Filed by Vincent Patino (Defendant)

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  • 02/20/2019
  • Docketat 09:00 AM in Department O, Peter A. Hernandez, Presiding; Ex-Parte Proceedings (to Continue Trial) - Held - Motion Granted

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  • 02/20/2019
  • Docketat 08:30 AM in Department O, Peter A. Hernandez, Presiding; Final Status Conference - Not Held - Taken Off Calendar by Party

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  • 02/20/2019
  • DocketMinute Order ( (Final Status Conference; Ex-Parte Proceedings to Continue Trial)); Filed by Clerk

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  • 02/20/2019
  • DocketOrder (Re: Ex-parte Application to Continue Trial); Filed by Maria Liliana Ramirez (Plaintiff)

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  • 02/19/2019
  • DocketEx Parte Application (to Continue Trial); Filed by Maria Liliana Ramirez (Plaintiff)

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  • 02/04/2019
  • Docketat 08:31 AM in Department O, Peter A. Hernandez, Presiding; Hearing on Motion for Summary Judgment

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90 More Docket Entries
  • 06/06/2017
  • DocketPROOF OF SERVICE

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  • 06/06/2017
  • DocketNOTICE OF PETITION AND PETITION PURSUANT TO GOVERNMENT CODE 946.6.TO BE RELIEVED FROM THE :CLAIM:FILING REQUIREMENT OF GOVERNMENT CODE 945.4; ETC.

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  • 06/06/2017
  • DocketDECLARATION OF BRIAN M. BUSH AND ATTACHED EXHIBITS IN SUPPORT OF PETITION PURSUANT TO GOVERNMENT CODE 946.6 TO BE RELIEVED FROM THE CLAIM FILING REQUIREMENT OF GOVERNMENT CODE 945.4

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  • 06/06/2017
  • DocketDECLARATION OF MARIA LILIANA RAMIREZ IN SUPPORT OF PLAINTIFF'S PETITION PURSUANT TO GOV. CODE 946.6

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  • 06/06/2017
  • DocketMotion for an Order (TO BE RELIEVED FROM THE CLAIM FILING ); Filed by Attorney for Plaintiff

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  • 06/06/2017
  • DocketMotion for an Order

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  • 06/05/2017
  • DocketComplaint Filed

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  • 06/05/2017
  • DocketComplaint; Filed by Maria Liliana Ramirez (Plaintiff)

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  • 06/05/2017
  • DocketCOMPLAINT FOR DAMAGES 1. SEXUAL HARASSMENT IN VIOLATION OF GOV. CODE 12940(A) & (J); ETC

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  • 06/05/2017
  • DocketSUMMONS

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Tentative Rulings

b'

Case Number: BC664056 Hearing Date: November 1, 2021 Dept: O

After considering the evidence\r\nand arguments presented in the record, the Court GRANTS Plaintiff Maria Liliana\r\nRamirez’s Motion for Protective Order, as follows:

\r\n\r\n

1. Defendant Citrus Community\r\nCollege District will withdraw its Special Interrogatories, Set One, Requests\r\nfor Admissions, Set One, and Form Interrogatories, Set Two, propounded on May\r\n21, 2021;

\r\n\r\n

2. Defendant Citrus Community\r\nCollege District then propound the latter discovery requests under the\r\nfollowing conditions:

\r\n\r\n

a. Defendant may only propound a\r\nmaximum of 60 SROGs;

\r\n\r\n

b. Defendant may propound RFAs.\r\nWhile there is no limit on the number of RFAs that can be made relating to the genuineness of documents (CCP § 2033.030(a)), the Defendant may not propound\r\nmore than 35 RFAs as to matters other than the genuineness of documents (CCP §\r\n2033.030(a)); and

\r\n\r\n

c. Defendant may propound FROGS;\r\nhowever,

\r\n\r\n

d. Plaintiff may use its previous\r\nresponses from the Alvarez Case in the instant action to avoid serving\r\nresponses to discovery that has already been propounded in the Alvarez\r\nCase. Justice so requires.

\r\n\r\n

Last, the Court GRANTS Plaintiff\r\nMaria Liliana Ramirez’s request for monetary sanctions against Defendant Citrus\r\nCommunity College District in the amount of $1,185.00 for costs, including\r\nattorney’s fees, incurred by Plaintiff herein. (CCP §§ 2030.090(d),\r\n2033.080(d).) Sanctions are to be made payable to Boucher LLP.

\r\n\r\n

Meet and Confer

\r\n\r\n

The motion for a protective order\r\nmust be accompanied by a meet and confer declaration. (CCP § 2031.060(a).) The\r\nparties’ meet and confer efforts must be a significant attempt at informal\r\nresolution of the dispute. (Stewart v. Colonial Western Agency, Inc.\r\n(2001) 87 Cal.App.4th 1006, 1016 (internal quotations and citations omitted); CCP\r\n§ 2016.040).)

\r\n\r\n

Here, the parties have satisfied\r\nthe meet and confer requirement pursuant to CCP section 2031.060(a).

\r\n\r\n

Legal Standard

\r\n\r\n

California Code of Civil\r\nProcedure (“CCP”) section 2030.090 provides that “[w]hen interrogatories have\r\nbeen propounded, the responding party, and any other party or affected natural\r\nperson or organization may promptly move for a protective order....” (CCP §\r\n2030.090(a).)

\r\n\r\n

“The court, for good cause shown,\r\nmay make any order that justice requires to protect any party or other natural\r\nperson or organization from unwarranted annoyance, embarrassment, or\r\noppression, or undue burden and expense.” (CCP § 2030.090(b).) “In considering\r\nwhether the discovery is unduly burdensome or expensive, the court takes into\r\naccount ‘the needs of the case, the amount in controversy, and the importance\r\nof the issues at stake in the litigation.’ ” (People ex rel. Harris v.\r\nSarpas (2014) 225 Cal.App.4th 1539, 1552 [citing CCP § 2019.030(a)(2)\r\n].)

\r\n\r\n

As with other objections in\r\nresponse to interrogatories, the party opposing discovery has an obligation to\r\nsupply the basis for this determination. An ‘objection based upon burden must\r\nbe sustained by evidence showing the quantum of work required.’ ” (Williams\r\nv. Superior Court (2017) 3 Cal.5th 531, 549; W. Pico Furniture\r\nCo. v. Superior Court (1961) 56 Cal.2d 407, 417.)

\r\n\r\n

The concept of good cause\r\nrequires a showing of specific facts demonstrating undue burden, etc., and\r\njustifying the relief sought.¿(See¿Goodman v. Citizens Life &\r\nCasualty Ins. Co.¿(1967)\r\n253 Cal.App.3d 807, 819.)¿The\r\nfacts are normally established in declarations by counsel for the party seeking\r\nthe protective order.¿The\r\ndeclaration must contain competent evidence - i.e., first-hand knowledge of the\r\nfacts.¿¿Hearsay\r\nallegations¿on\r\ninformation and belief¿and\r\nconclusory statements that particular relief is¿necessary¿are\r\nnot enough.¿(Id.)

\r\n\r\n

A trial court “shall limit the scope of discovery if it determines that\r\nthe burden, expense, or intrusiveness of that discovery clearly outweighs the\r\nlikelihood that the information sought will lead to the discovery of admissible\r\nevidence.” (CCP § 2017.020(a).)

\r\n\r\n\r\n\r\n

A protective order may include\r\nthe direction that “the set of interrogatories, or particular interrogatories\r\nin the set, need not be answered,” “the response be made only on specified\r\nterms and conditions,” or “the method of discovery be an oral deposition\r\ninstead of interrogatories to a party.” (CCP §§ 2030.090(b)(1), (b)(4), (b)(5)\r\n(5).) Protective orders of a similar nature are also available for inspection\r\ndemands and requests for admission. (See id., §§ 2031.060, 2033.080.)

\r\n\r\n

The Motion at Hand is Granted.

\r\n\r\n

Here, Plaintiff moves the Court\r\nfor a protective order pursuant to CCP sections 2030.090 and 2033.080 excusing\r\nPlaintiff from responding to the Defendant District’s SROGs, FROGs, and RFAs\r\nserved on May 21, 2021.

\r\n\r\n

Two\r\nCause of Action is in Controversy

\r\n\r\n

Plaintiff’s\r\nfifth cause of action for Supervisory Liability is alleged against Defendants\r\nSammis and Magallon, in their individual capacities. (Arjang Decl. ¶ 3, Exh.\r\n1.) Nominally, the cause of action is titled “Supervisory Liability.” To establish supervisory liability\r\nunder section 1983, a plaintiff is required to prove: (1) the supervisor had\r\nactual or constructive knowledge of the [subordinate’s] wrongful conduct; (2)\r\nthe supervisor’s response was so inadequate as to show ‘deliberate\r\nindifference’ to or tacit authorization of the alleged offensive practices; and\r\n(3) the existence of an ‘affirmative causal link’ between the supervisor’s\r\ninaction and [plaintiffs’] injuries.” (Grassilli v. Barr (2006) 142\r\nCal.App.4th 1260, 1279-1280.)

\r\n\r\n

Plaintiff has alleged a wide\r\nvariety of facts against Mr. Sammis, the Director of Human Resources, and Mr.\r\nMagallon, the bookstore supervisor. (Complaint, ¶¶ 8-9, 90-103.)

\r\n\r\n

For example, Plaintiff alleges\r\nthat “notwithstanding the former sexual harassment complaint, of which\r\nPLAINTIFF is informed and believes SAMMIS and MAGELLAN were aware, PATINO continued\r\nto be employed by Defendant COLLEGE and Defendants SAMMIS and MAGELLAN made no\r\neffort to improve the education and training related to sexual harassment at\r\nthe Bookstore and Café.” (Complaint, ¶ 98.)

\r\n\r\n

Additionally, the Complaint’s\r\nrecital of facts include allegations that several other employees of Defendant\r\nwere “[s]upervisors-in title or, if not by title, by virtue of the job\r\nfunctions and responsibilities entrusted to them by Defendant…included\r\nCarmelita Alvarez, Todd Wilcox, and VINCENT PATTINO” (Complaint, ¶ 15.)

\r\n\r\n

In addition, the fourth cause of\r\naction for gender based discrimination includes Patino,

\r\n\r\n

Discovery\r\nRequests Pertaining to the Instant Action

\r\n\r\n

On January 19, 2018, Plaintiff\r\nRamirez served comprehensive responses to Defendant’s Form Interrogatories, Set\r\nOne. (Bush Decl. ¶ 7.) Defendant’s Form Interrogatories, Set One, contained\r\nforty-six (46) individually numbered interrogatories propounded to each of the\r\nPlaintiffs, not including the subparts of those interrogatories. (Id. at ¶\r\n7(a).) Defendant’s Form Interrogatories included the basic background\r\ninterrogatories (2-series questions), damages and treatment interrogatories\r\n(6-series questions), loss of earnings interrogatories (8-series questions),\r\nadditional damages interrogatories (9-series questions), preexisting condition\r\ninterrogatories (10-series questions), past claims interrogatories (11-series\r\nquestions), witness and document identification and substance interrogatories\r\n(12-series questions), surveillance interrogatories (13-series questions), and\r\nlegal violation contention interrogatories (14- series questions). (Id. at ¶\r\n7(b).)

\r\n\r\n

On January 26, 2018, Plaintiff\r\nserved comprehensive responses to Defendant Vincent Patino’s Form\r\nInterrogatories and Requests for Admissions, Requests for Production and\r\nSpecial Interrogatories, Sets One, copying her responses to the Citrus College\r\ndefendants. (Bush Decl. ¶ 9.)

\r\n\r\n

On May 21, 2021, Defendant propounded\r\nthe SROGs to all Plaintiffs, including Ms. Ramirez, seeking (among other\r\ndiscovery requests) all the facts in support of Plaintiff’s contentions that\r\nDefendants Mr. Sammis and Mr. Magallon violated Plaintiff’s constitutional\r\nrights. (Arjang Decl. ¶ 5, Exh. 2.) The SROGs contained a total of 144 special\r\ninterrogatories. (Id.)The latter discovery requests had been previously\r\npropounded in the related matter, Case No. BC681378.

\r\n\r\n

On May 21, 2021, Defendant also\r\npropounded the RFAs on all Plaintiffs, including Ms. Ramirez, seeking an\r\nadmission (among other discovery requests) from Plaintiff that Defendants Mr.\r\nSammis and Mr. Magallon had no prior notice of Defendant Patino’s conduct.\r\n(Arjang Decl. ¶ 6, Exh. 3.) The RFAs contained a total of 64 special\r\ninterrogatories. (Id.) The latter discovery requests had also been\r\npreviously propounded in the related matter, Case No. BC681378.

\r\n\r\n

In\r\naddition, on May 21, 2021, Defendant also propounded the Second FROGs on all\r\nPlaintiffs, including Ms. Ramirez, consisting\r\nof Form Interrogatory 17.1, which, taken together with the Requests for\r\nAdmissions (assuming denials to each) and including the three subparts of 17.1,\r\nconsists of 192 interrogatory subparts. (Bush Decl. ¶ 30.)

\r\n\r\n\r\n\r\n

Good Cause Shown for Limited\r\nPurposes

\r\n\r\n

Here, court\r\nfinds that Plaintiff has shown good cause for the pending motion on limited\r\nground, while Defendants have not met their burden of justifying the SROGs,\r\nRFAs, or Second FROGs on those limited grounds. “In considering whether the\r\ndiscovery is unduly burdensome or expensive, the court takes into account ‘the\r\nneeds of the case, the amount in controversy, and the importance of the issues\r\nat stake in the litigation.’ ” (Sarpas, supra, 225\r\nCal.App.4th at p. 1552 [citing CCP § 2019.030(a)(2) ].)

\r\n\r\n

Some of Defendants’ requests are\r\nunduly burdensome in that they request information that are repeated, in one\r\nform or another, in several of the subject discovery requests.

\r\n\r\n

For example, the Complaint’s\r\nrecital of facts includes allegations that several other employees of\r\nDefendant, other than Sammis and Magellan were “[s]upervisors-in title or, if\r\nnot by title, by virtue of the job functions and responsibilities entrusted to\r\nthem by Defendant…included Carmelita Alvarez, Todd Wilcox, and VINCENT PATINO.”\r\n(Complaint, ¶ 15.)

\r\n\r\n

Yet, the subject discovery\r\nrequests ask Plaintiff to essentially reaffirm the unambiguous allegations, as follows.\r\nWith respect to the SROGs, SROG No. 129 asks: “Do you contend that Patino was a\r\nsupervisor?” (Bush Decl., Exh. 6, p. 17:23-24.) SROG No. 133 asks: “Do you\r\ncontend that Carmelita was a supervisor?” (Id., Exh. 6, p. 18:5-6.) SROG\r\nNo. 137 asks: “Do you contend that Rose was a supervisor?” (Id., Exh. 6,\r\np. 18:16-17.)

\r\n\r\n

With respect to the RFAs, RFA No.\r\n21 requests Plaintiff admit that “Patino was not your supervisor.” (Bush Decl.,\r\nExh. 7, p. 4:24-26.) RFA No. 37 requests Plaintiff admit that “during YOUR\r\nemployment with the DISTRICT, Todd Wilcox was not YOUR supervisor.” (Bush\r\nDecl., Exh. 7, p. 6:17-19.)

\r\n\r\n

The requests also redundant\r\nbecause they sought to settle issues that were clearly disputed by the\r\nComplaint. The Complaint alleged that Patino, Wilcox, and Alvarez, though not nominally\r\nsupervisors, had actual or apparent authority. (Complaint, ¶¶ 7-9, 15-34.) Yet,\r\nthe subject discovery requests directed some redundant requests by asking\r\nPlaintiff to admit either Patino, Wilcox, or Alvarez, were not supervisors. The\r\ncrux of the Complaint’s allegations is that the latter individuals had actual\r\nor apparent authority, even if not nominally titled supervisors. (Id. at\r\n¶¶ 7-9.) What the requests in question sought did not distinguish Plaintiff’s\r\nreliance on allegations of actual authority despite a lack of title.

\r\n\r\n

The better approach would have\r\nbeen to propound an interrogatory that requested the evidence that supported\r\nPlaintiff’s assertions. Yet, the subject discovery requests went on to repeat\r\nother redundant requests that essentially sought to make out Defendant’s case\r\nfor summary judgment.

\r\n\r\n

Next, Plaintiff’s counsel\r\nprovides that, at a minimum, the subject discovery requests will result in approximately 44\r\nhours of attorney time to simply compile partial responses. This time does not\r\ninclude the additional time it will take to comb through documents to ensure\r\nthat responses are also consistent with the evidence in the documents that have\r\nbeen produced in this case. The additional work will increase the time required\r\nbeyond 55 hours of attorney time in order to duplicate responses that Defendant\r\nalready has from prior discovery requests in this action. (Bush Decl., ¶ 34.)

\r\n\r\n

In opposition, Defendant District\r\nargues that the fifth cause of action invokes other constitutional claims. The\r\nComplaint, however, asserts two causes of action including the fifth cause of\r\naction for Supervisory Liability and the fourth cause of action for\r\nUnconstitutional\r\nGender Based Discrimination. The number of questions in the SROGs (134) are not\r\nwarranted because the complexity and the quantity of the existing and potential\r\nissues in this particular case are limited.

\r\n\r\n

Thus, the Court makes a limited\r\nfinding that some of the individual requests under the SROGs, FROGs, and RFAs\r\nburden Plaintiff such that their burden clearly outweighs the likelihood that\r\nthe information sought will lead to the discovery of admissible evidence. (CCP §\r\n2017.020(a).)

\r\n\r\n

Modified\r\nProtective Order

\r\n\r\n

However, the subject discovery\r\nrequests also made valid requests for information that Plaintiff did not bother\r\nto distinguish. Defendant District met its burden in propounding more than 35\r\nSROGs, etc., though not for all of 134 interrogatories and not for all requests\r\nunder the RFAs and FROGs. A court may make any order that justice requires to\r\nprotect a party or other natural person from “unwarranted annoyance,\r\nembarrassment, or oppression or undue burden and expense.” (CCP § 2030.090(b).)

\r\n\r\n

Under the Complaint, the fifth\r\ncause of action incorporates the preceding fourth causes of action and the 46\r\nparagraphs of factual allegations that prefaced them. Thus, the allegations are\r\nnumerous for even one cause of action. Considering the circumstances, the Court\r\nwill limit the maximum number of SROGs which Defendant may propound to a total\r\nof 60.

\r\n\r\n

Further,\r\nwhile there is no limit on the number of RFAs that can be made\r\nrelating to the genuineness of documents (CCP § 2033.030(a)), the\r\nDefendant may not propound more than 35 RFAs as to matters other than the\r\ngenuineness of documents. (CCP § 2033.030(a).)

\r\n\r\n\r\n\r\n

As to\r\nthe FROGs, Defendant District may propound the FROGs anew. However, Plaintiff may\r\nuse the same responses from the Alvarez Case in the instant action to avoid\r\nserving responses to (any) discovery that has already been propounded in the\r\nrelated case. Here,\r\nPlaintiff argued that the subject discovery requests were burdensome and argued,\r\nin part, that the requests had been previously propounded in the Alvarez Case.

\r\n\r\n

Sanctions

\r\n\r\n

Here, Plaintiff requests an award\r\nof monetary sanctions in the amount of $1,185.00 pursuant to CCP sections\r\n2030.090(d) and 2033.080(d). Defendant has unsuccessfully opposed the pending\r\nmotion. Moreover, the Court does not find that sanctions under the\r\ncircumstances would be unjust.

\r\n\r\n

Next, Plaintiff’s counsel, Brian\r\nM. Bush (“Bush”) provides that his standard hourly rate is $395.00/hour. (Bush\r\nDecl., ¶ 40.) Bush states that he expended 1.9 hours drafting his declaration\r\n(as a revised version of a previous declaration used to move for a protective\r\norder in the Alvarez case) inclusive of the time necessary to compile, audit\r\nand summarize the information, documents, and prior responses necessary to set\r\nforth the detailed description of prior discovery activity included in\r\nparagraphs 7-35. (Id. at 41.)

\r\n\r\n

In addition, Plaintiff’s counsel\r\nexpended: (a) 1 hour drafting the pending Motion for Protective Order filed\r\nconcurrently herewith (as a revised version of a previous motion used to move\r\nfor a protective order in the Alvarez case); and (b) 0.1 hours drafting the\r\nProposed Order filed concurrently herewith. In total, Plaintiff’s counsel\r\nexpended 3 hours at $395/hr., and therefore requests an order of sanctions\r\nagainst Defendants in the amount of $1,185.00 made\r\npayable to Boucher LLP. (Bush Decl., ¶¶ 42-44.)

\r\n\r\n

Here, the Court finds that\r\nPlaintiff’s stated costs were reasonably and necessarily incurred for purposes\r\nof the pending.

\r\n\r\n

Therefore,\r\nthe Court grants Plaintiff’s request for monetary sanctions against Defendant Citrus\r\nCommunity College District in the amount of $1,185.00 for costs, including\r\nattorney’s fees, incurred by Plaintiff herein. (CCP §§ 2030.090(d), 2033.080(d).)

\r\n\r\n\r\n\r\n

CONCLUSION

\r\n\r\n

Accordingly,\r\nthe Court GRANTS Plaintiff Maria Liliana Ramirez’s Motion for Protective\r\nOrder, as follows

\r\n\r\n

1. Defendant Citrus Community\r\nCollege District will withdraw its Special Interrogatories, Set One, Requests\r\nfor Admissions, Set One, and Form Interrogatories, Set Two, propounded on May\r\n21, 2021;

\r\n\r\n

2. Defendant Citrus Community\r\nCollege District then propound the latter discovery requests under the\r\nfollowing conditions:

\r\n\r\n

a. Defendant may only propound a\r\nmaximum of 60 SROGs;

\r\n\r\n

b. Defendant may propound RFAs. While\r\nthere is no limit on the number of RFAs that can be made relating to the\r\ngenuineness of documents (CCP § 2033.030(a)), the Defendant may not propound\r\nmore than 35 RFAs as to matters other than the genuineness of documents (CCP §\r\n2033.030(a)); and

\r\n\r\n

c. Defendant may propound FROGS;\r\nhowever,

\r\n\r\n

d. Plaintiff may use its previous\r\nresponses from the Alvarez Case in the instant action to avoid serving\r\nresponses to discovery that has already been propounded in the Alvarez Case. Justice\r\nso requires.

\r\n\r\n

Last,\r\nthe Court GRANTS Plaintiff Maria Liliana Ramirez’s request for monetary\r\nsanctions against Defendant Citrus Community College District in the amount of\r\n$1,185.00 for costs, including attorney’s fees, incurred by Plaintiff herein.\r\n(CCP §§ 2030.090(d), 2033.080(d).) Sanctions are to be made payable to Boucher\r\nLLP.

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