Motion to Compel Further Responses to Special Interrogatories
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34-2023-00333876-CU-WT-GDS: Ryan Crowley vs. California Correctional Health Care Services 02/09/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories in Department 28
Tentative Ruling
NOTICE:
PLEASE TAKE NOTICE that any oral arguments regarding this tentative ruling will be heard at 1:30 p.m. in Department 28, located at 720 9th Street, Sacramento, CA, the Hon. Richard C. Miadich presiding.
Any party who wishes to contest the tentative ruling below must:
(1) request a hearing by calling the Law and Motion Oral Argument Request Line at (916) 874-2615, by 4:00 p.m. the Court day before the noticed hearing date, and leave a voicemail message (a) identifying themselves as the party requesting oral argument; (b) indicating the specific matter/motion for which they are requesting oral argument; and (c) confirming that they have notified the opposing party of their intention to appear; and
(2) advise the opposing party of the location and time of hearing pursuant to Local Rule 1.06.
If a hearing is not requested by 4:00 p.m. on the Court day before the noticed hearing date, the tentative ruling will become the final order of the Court.
If a hearing is requested, the Court prefers in-person attendance by the parties. However, parties may appear by Zoom unless the Court specifically orders in-person attendance. Parties choosing to appear by Zoom are reminded, however, that a Zoom appearance is still a formal appearance before the Court. Parties appearing via Zoom should do so from a quiet location, free from undue distractions, and wear attire suitable for an in-person court appearance.
The parties may join the Zoom session for hearing on the tentative ruling by audio and/or video through the following link:
https://saccourt-ca-gov.zoomgov.com/my/sscdept28
SIP Address:
16039062174@sip.zoomgov.com
(833) 568-8864
34-2023-00333876-CU-WT-GDS: Ryan Crowley vs. California Correctional Health Care Services 02/09/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories in Department 28
ID: 16039062174
Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://www.saccourt.ca.gov/court-reporters/docs/crtrp- 13.Pdf
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 Courts 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 or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will be forward the form to the Court Reporters Office and an official reporter will be provided.
TENTATIVE RULING
Plaintiff Ryan Crowleys (Plaintiff) motion for an order compelling Defendant California Correctional Health Care Services (Defendant) to serve further responses to Plaintiffs Special Interrogatories, Set One is ruled upon as follows.
The notice of motion does not provide notice of the Courts tentative ruling system, as required by Local Rule 1.06. Moving counsel is directed to contact opposing counsel and advise of Local Rule 1.06 and the Courts tentative ruling procedure and the manner to request a hearing. If moving counsel is unable to contact opposing counsel prior to the hearing, moving counsel is ordered to appear at the hearing by Zoom or in person.
This is an employment action. The Complaint includes two causes of action: (1) whistleblower retaliation under Labor Code section 1102.5; and (2) retaliation under FEHA. Plaintiff alleges that he was employed by Defendant as a dentist at San Quentin State Prison from December 10,
SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO
34-2023-00333876-CU-WT-GDS: Ryan Crowley vs. California Correctional Health Care Services 02/09/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories in Department 28
2007 until his termination on August 3, 2022. Plaintiff alleges that in 2014, he began reporting to Alma Clark, D.D.S. (Dr. Clark). Plaintiff alleges that Dr. Clark sexually harassed him during group and one-on-one meetings by engaging in various forms of unwanted touching. In May of 2014, Plaintiff filed a discrimination complaint with Defendant. Plaintiff alleges that Defendant took adverse actions against him in retaliation. In August of 2017, Plaintiff filed a lawsuit against Defendant in Marin County alleging sexual harassment and retaliation, which ultimately settled in November of 2017.
Plaintiff then alleges that during the Covid-19 pandemic, Defendant required him to perform routine dental screenings on inmates despite recommendations from the American Dental Association that only urgent and emergent dental procedures be performed. Plaintiff and his coworkers objected and consulted with union representatives, but when Defendant continued to require the screenings, Plaintiff and his coworkers reported their concerns to an OSHA investigator, who ordered the San Quentin Dental Clinic closed due to unsafe practices and procedures following an inspection.
Plaintiff alleges that he thereafter received additional disciplinary action and was ultimately terminated.
Plaintiff served the subject interrogatories in September of 2023. Defendant served its initial responses on January 10, 2024. The parties thereafter engaged in significant meet and confer efforts. On April 25, 2025, Defendant served amended responses. At the same time, Defendant served amended responses to Plaintiffs Requests for Production of Documents, Set One and produced nearly 2,000 pages of documents consisting primarily of disciplinary materials Plaintiff had previously been provided during his employment. After the parties further met and conferred, Defendant served second amended responses on September 12, 2025. Plaintiff deemed the second amended responses deficient and ultimately filed this motion on January 15, 2016.
This motion seeks further responses to Special Interrogatory Nos. 1-35. Nos. 1-25 present the same issues as those presented in Plaintiffs motion to compel further responses to form interrogatories on todays calendar. Plaintiffs motion to compel further responses is GRANTED as to Special Interrogatory Nos. 1-25 for the same reasons discussed in the Courts order on Plaintiffs form interrogatory motion. However, the Court limits Nos. 16-25 to any employee employed under the California Correctional Health Care Services (as opposed to the State of California).
Nos. 26-35 ask for information about incarcerated persons at San Quentin State Prison at various times, specifically the number of incarcerated persons, the number of incarcerated persons who tested positive for and/or died of Covid-19, and similar categories of persons specifically within the San Quentin State Dental Clinic. Defendant argues that the information is not relevant. However, the Court agrees with Plaintiff that the information is relevant to his whistleblower
SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO
34-2023-00333876-CU-WT-GDS: Ryan Crowley vs. California Correctional Health Care Services 02/09/2026 Hearing on Motion to Compel Further Responses to Special Interrogatories in Department 28
retaliation claim, specifically the reasonableness of his belief that he had disclosed a violation of law. (See Lawson v. PPG Architectural Finishes, Inc. (2022) 12 Cal.5th 703, 712-713.) That it is widely known, as Defendant admits, that San Quentin State Prison experienced a severe Covid outbreak does not make the information sought by Plaintiff undiscoverable. The Court is also not persuaded that this information is unreasonably cumulative. Finally, there are no privacy concerns, since Plaintiff seeks only general population data, not any individual identifying information. Accordingly, Plaintiffs motion is GRANTED as to Special Interrogatory Nos. 26- 35.
Disposition
Pursuant to the above discussion, Plaintiffs motion to compel is GRANTED in full.
Defendant shall serve verified further responses by no later than February 20, 2026.
This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. § 1019.5; Cal. Rules of Court, rule 3.1312.)
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