L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al.

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

Tentative Ruling

*** If oral argument is requested, the parties must at the time oral argument is requested notify the clerk and opposing counsel of the specific discovery requests that will be addressed at the hearing. Counsel are also reminded that pursuant to local court rules, only limited oral argument is permitted on law and motion matters. ***

Plaintiff T.F.’s (“Plaintiff”) motion to compel Defendant San Juan Unified School District’s (“District”) further responses to special interrogatories (set one) is ruled upon as follows.

This is a childhood sexual abuse case. Plaintiff alleges that during the period of September 2024 through December 2024, when he was approximately five years old, he was sexually abused by Ricky Anthony Linan (“Linan”), a teacher with the District.[1]

The first amended complaint asserts causes of action for: (1) sexual abuse of a minor; (2) intentional infliction of emotional distress; (3) negligent hiring, supervision, training, and retention; (4) breach of mandatory duty: failure to report suspected child abuse; (5) negligent supervision of students; and (6) negligence.

No trial date is currently scheduled.

The parties entered into a stipulated protective order on July 28, 2025.

Plaintiff moves to compel the District’s further responses to special interrogatory (“SROG”) no. 16 and 31. The District opposes.

Legal Standard

Pursuant to Code of Civil Procedure section 2030.210[2], a party shall respond in writing under oath separately to each interrogatory by any of the following:

(1) An answer containing the information sought to be discovered. (2) An exercise of the party’s option to produce writings. (3) An objection to the particular interrogatory.

A propounding party may move to compel a further response to an interrogatory, if the propounding party deems that any of the following apply:

(1) An answer to a particular interrogatory is evasive or incomplete.

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

(2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate.

(3) An objection to an interrogatory is without merit or too general.

(Code Civ. Proc. §2030.300(a).)

Section 2030.220 requires that responses to interrogatories be as complete and straightforward as the information reasonably available to the responding party permits, and “if an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220(a)-(b); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 788-89.) If the responding party does not have personal knowledge sufficient to respond to the interrogatory, “that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.” (Code Civ. Proc. §2030.220(c).)

SROG 16

“IDENTIFY each of YOUR students who made any COMPLAINT(S) against LINAN.” [3]

The District responded, “Objection. This request violates the attorney/client privilege, attorney work-product doctrine, and the privacy rights of third parties including minors.”

Plaintiff insists that the District’s responses are improper. He first argues that the identity of the students is not protected by the attorney-client privilege nor the work-product doctrine. With respect to the privacy rights of third parties, he argues that a protective order is already in place that strictly limits the use and disclosure of confidential information. He acknowledges that the minor students have “immense” privacy rights, but suggests that those privacy rights are outweighed by the “compelling social interest in disclosure of information relating to sexual predators of children outweigh the privacy interests asserted on behalf of (yet to be identified) third-party minors in the instant case.” (Plaintiff’s Separate Statement, 5:10-12 citing In Re Clergy Cases I (2010) 188 Cal.App.4th 1224 (“Clergy Cases”).) Plaintiff adds that:

The minor students who made complaints against Linan (a) may have percipient knowledge of the abuse that was occurring in District’s campuses, (b) likely knew the Plaintiffs, and (c) likely witnessed the abuse of the Plaintiffs while they were in District’s campuses. These are the precise witnesses that Plaintiffs need to depose, in order to fully establish notice, foreseeability, or the extent of District’s failure to protect minor students in its care.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

(Plaintiff’s Separate Statement, 6:21-26.)

In opposition, the District makes no argument regarding the attorney-client privilege or the workproduct doctrine. Accordingly, those objections are OVERRULED.

The District focuses solely on the privacy rights of the minor students. It explains that the disclosure of names is not required for Plaintiff to receive the potential information sought. The District emphasizes that “[t]he student’s names who have or may have made complaints can be limited to dates and details of the complaints absent identifying the student. Furthermore, the complaints should be limited to those to the extent that they may exist which DISTRICT denies, that occurred prior to Plaintiff T.F.’s alleged abuse. And lastly, the Complaints should be narrowly tailored to the same type of allegations or those relevant to the allegations as proffered by Plaintiff T.F.” (District’s Separate Statement, 8:28-9:4.) It adds that the protective order does not alleviate all privacy concerns because it:

cannot prohibit the Guardian ad Litem from disclosing the names of fellow students or community members to their minor children. These minor children or even if disclosed to them when they are adults may further disclose the alleged sexual abuse of these non party students who did not choose to be part of a public personal injury lawsuit. Whether any such disclosure is purposeful or not, the trauma and/or impact upon the non-party student who was ordered to disclose their name and alleged abuse is unknowable.

(District’s Separate Statement, 9:18-23.)

Here, there is no dispute that the SROG is reasonably likely to lead to the discovery of admissible evidence. The question is whether Plaintiff has shown a compelling need for the discovery that outweighs the minor students’ right to privacy, and whether the stipulated protective order is sufficient to protect those interests.

Plaintiff’s reliance on Clergy Cases for the proposition that a compelling social interest in protecting minors from sexual abuse by holding abusers accountable outweighs any privacy interests is misplaced. In Clergy Cases, the privacy rights implicated were those of the individual perpetrators, and the court found that compelling social interests in protecting children from sexual predators outweighed individual perpetrators’ privacy interests. In the case at bar, Plaintiff seeks the identity of other victims of Linan who have chosen not to become public with any accusations, rather than vice-versa.

Additionally, the settlement agreement in Clergy Cases provided a specific procedure to provide notice to the individual perpetrators of the pending release of their private information. Here, there is no mechanism for providing notice to the students who made complaints against Linan. The Court further notes that the SROG also

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

encompasses all student complaints made against Linan, whether they involved alleged sexual abuse or not, and even after Plaintiff’s alleged abuse. The Court also agrees with the District that the current stipulated protective order is insufficient to protect the minor students who have chosen not to become public with any accusations. The Court finds that Plaintiff has not demonstrated a compelling need for the students’ names because Plaintiff can obtain relevant information without the disclosure of the students’ names.

District’s reliance on Poway Unified School Dist. v. Superior Court (Copley Press Inc.)[4] is inapposite. While it correctly states the law that minors have a strong constitutional right of privacy, Poway involved a request by a newspaper under the Public Records Act. It did not involve discovery by a litigant.

District cited County of Los Angeles v. Superior Court. The Court finds that the privacy interests of minor victims of sexual abuse is even more important than the privacy of patients who were prescribed medicine in that case. They have a legally protected privacy interest, an objectively reasonable expectation of privacy in the given circumstances, and a threatened intrusion that is serious. The question is whether Plaintiff has established countervailing interests that outweigh this serious potential invasion of privacy rights.

Moskowitz v. Superior Court, cited by Plaintiff, involved a request to protect disclosure of personal financial information. The court ordered that disclosure of the claimant’s financial information be “limited by allowing the use of such information only for purposes related to the lawsuit, and only by persons having a legitimate interest in that information for such purposes.” Although the privacy of the minor victims of sexual abuse, if any, is more significant here than the personal financial information in Moskowitz, that case made it clear that protected information can be limited and restricted to those involved in a lawsuit having a legitimate interest in the information. Plaintiff in this fits those parameters.

Defendant argues that “The disclosure of the names is not required for Plaintiff to receive the potential information sought,” and suggested providing the dates and details of complaints without identifying the complaining students. That appears to the Court to be a reasonable approach that would provide Plaintiff with the information he seeks and still protect the nonparty minor victims. Defendant denied that there are any other complaints, and if there were none the matter is moot.

It is therefore ordered that Defendant provide the dates and details of all complaints about defendant Linan by students about events occurring prior to the abuse alleged by Plaintiff in this case. The complaining students, if any, are to be identified as Vroe 1, Vroe 2 etc. Because the identity of the students is protected, Defendant is to provide the information about all complaints, whether or not Defendant thinks they are relevant. That may well satisfy Plaintiff’s need for

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

information. If Plaintiff believes that he needs further information about prior complaints, he may file another motion seeking further responses and set forth specific facts showing the need for further responses.

The Court disagrees with Defendant’s assertion that the existing protective order is insufficient to protect the privacy of the non-party minor complainants. It is ordered that Defendant’s response to Interrogatory 16 be included in the documents covered by the existing protective order and designated confidential.

District’s objection based on third-party privacy is overruled subject to the limitations set forth above.

District’s objections based on the attorney/client privilege and attorney work-product doctrine are overruled and the Court will GRANT the motion to compel a further response, but only with respect to the attorney/client privilege and attorney work-product doctrine objections.

SROG 31

“Please IDENTIFY any and all PERSONS interviewed by YOU regarding the allegations in Plaintiff’s Complaint.”

The District responded, “Objection. This interrogatory invades the attorney/client privilege and attorney work-product doctrine. Without waiving said objections, responding party states: None, which are not privileged.”

The District focuses solely on the privacy rights of the minor students. The District did not object to this SROG on the grounds of privacy. “The failure to timely respond to an inspection demand waives all objections, including objections based on privilege [citation], and the failure to assert a specific objection waives that particular objection [citation].” (Catalina Island Yacht Club v. Superior Court (2015) 242 Cal.App.4th 1116, 1125; see also Scottsdale Ins. Co. v. Superior Court (1997) 59 Cal.App.4th 263, 273-274 [failure to assert an objection in the initial response waives objection].)

The District makes no argument regarding the attorney-client privilege or the work-product doctrine. Accordingly, those objections are OVERRULED.

Plaintiff’s motion to compel a further response to SROG 31 is GRANTED.

Subject to the above, no later than September 1, 2026, the District shall serve further responses to the SROGs, unless the parties agree in writing to a later date.

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc. §1019.5; CRC Rule 3.1312.)

Moving counsel’s notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Moving counsel is directed to contact the District’s counsel and advise counsel of Local Rule 1.06 and the Court’s tentative ruling procedure and the manner to request a hearing. If moving counsel is unable to contact District’s counsel prior to hearing, moving counsel is ordered to appear at the hearing.

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Department 16C Oral Argument Request Line at (916) 874-1475 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail 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 it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below.

If no request for oral argument is made, the tentative ruling becomes the final order of the Court. Unless ordered to appear in person by the Court, parties may appear remotely either telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings.

The Department 16C Zoom Link is https://saccourt-ca-gov.zoomgov.com/j/16030877014 and the Zoom Meeting ID is 160 3087 7014. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.

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 on the Court Reporter Services webpage available on the Sacramento Superior Court website at https://saccourt.ca.gov/general-information/court-reporter-services-transcripts. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV005323: L. vs SAN JUAN UNIFIED SCHOOL DISTRICT, et al. 08/18/2026 Hearing on Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, to Defendant San Juan Unified School District in Department 16C

Official Reporters Pro Tempore available at https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000.

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 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. [1] Linan’s criminal trial is currently scheduled for August 24, 2026. [2] Unless otherwise indicated, all further statutory references are to the Code of Civil Procedure. [3] The Court notes that Plaintiff’s separate statement did not include the definition of “COMPLAINT(S).” [4] The Court notes several errors in District’s pleadings in this motion.

In its “DEFENDANT SAN JUAN UNIFIED SCHOOL DISTRICT'S RESPONSE TO PLAINITFF'S SEPARATE STATEMENT TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)” filed July 15, 2026 the word “Plaintiff’s” is misspelled in the title as “Plainitff’s.” The “Response” goes on to state, “Defendant SAN JUAN UNIFIED SCHOOL DISTRICT ('DISTRICT').by and through their attorneys of record, hereby submits their Separate Statement of Discovery in Dispute in Opposition to Plaintiffs' Motion to Compel Further Responses to Request for Production of Documents, Set One.” Note the punction period between “(DISTRICT)” and “by” in the middle of the sentence.

In its Response filed August 5, 2026 District cites Poway Unified School Dist. v. Superior Court (Copley Press Inc.) (1998) as “District v Poway Unified School District (year).” Counsel is advised to proofread all documents prior to filing.