Motion to quash subpoena
Case No.: 25STCV32864 Hearing Date: May 18, 2026 [TENTATIVE] order RE:
plaintiff’s motion to quash subpoena BACKGROUND On November 10, 2025, Plaintiff Timothy Sean Grizzle filed this action against Defendants County of Los Angeles, Dara Smith, George Renkei, and Scott Thornberry. Plaintiff filed the operative First Amended Complaint on December 30, 2025, asserting a single cause of action for whistleblower retaliation.
On March 27, 2026, Plaintiff filed the instant motion to quash a subpoena to his previous employer, The Walt Disney Company. Defendant filed an opposition on May 5, 2026. Plaintiff filed a reply on May 11, 2026.
LEGAL STANDARD “If a subpoena requires the attendance of a witness or the production of books, documents, electronically stored information, or other things”, the court, upon motion reasonably made by [a party] . . . may make an order quashing the subpoena entirely, modifying it, or directing compliance with it upon those terms or conditions as the court shall declare, including protective orders.” (Code Civ. Proc., § 1987.1, subd. (a), (b).)
Good cause must be shown to compel a nonparty to produce documents. (See Calcor Space Facility, Inc. v. Superior Court (1997) 53 Cal.App.4th 216, 224.)
DISCUSSION The subpoena to Disney seeks Plaintiff’s personnel file from April 2008 to August 2009. However, Defendant has failed to establish good cause for the information. The information is from over fifteen years ago, and five years before Plaintiff began working for Defendant in 2014. (See FAC ¶ 11.) This is too remote to be considered relevant and is not reasonably calculated to lead to admissible evidence. (See Code Civ. Proc., § 2017.010.)
Defendant argues that Plaintiff placed his work performance at issue by alleging an exemplary record. (See FAC ¶¶ 12, 16.) However, the allegations refer to Plaintiff’s performance while working for Defendant. The FAC does not mention Plaintiff’s prior employment, nor does Plaintiff rely on his prior employment performance to support his case. Records from over fifteen years before the events in question are not relevant to Plaintiff’s performance while working for Defendant, nor are they relevant to Defendant’s justification for terminating Plaintiff.
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Defendant also argues that the records are relevant for assessing Plaintiff’s damages, including “lost past and future income and employment benefits, damage to his career, and lost wages.” (See FAC ¶ 17.) Defendant contends that Plaintiff has placed his career trajectory and earning history at issue. Defendant argues that the information is also relevant to mitigation of damages. However, Defendant fails to demonstrate that records from over fifteen years before the events in question, and five years before Plaintiff began working for Defendant, are relevant for the stated purposes.
Personnel records are considered private (Board of Trustees v. Superior Court of Santa Clara County (1981) 119 Cal.App.3d 516, 528-30), and Defendant has not demonstrated direct relevance to overcome the privacy interest (Williams v. Sup. Ct. (2017) 3 Cal.5th 531, 552; Davis v. Superior Court (1992) 7 Cal.App.4th 1008, 1017).
CONCLUSION Plaintiff’s motion to quash is GRANTED. The subpoena to The Walt Disney Company is quashed in its entirety. Sanctions are denied as the parties acted with substantial justification.
Case Number: 25STCV35131 Hearing Date: May 18, 2026 Dept: 32 MARIA GARCIA, et al., Plaintiffs, v. 833 FEDORA RE LLC, et al., Defendants.