If one wants to depose a high-level official who seeks a protective order to prohibit the deposition, the court should determine whether there is good cause showing that the official has unique or superior personal knowledge of discoverable information, a California court has said.
In the case of Eleni Gavriiloglou v. Prime Healthcare Management, Inc. et al., the plaintiff filed a complaint against her former employer and its alleged alter egos – Prime Healthcare Management, Inc., Prime Healthcare Management II, Inc., Hospital Business Services, Inc., and Dr. Prem Reddy.
She asked for damages for the following violations of California’s Labor Code:
- failure to provide meal and rest periods under section 226.7;
- failure to pay overtime under section 510;
- failure to provide all wages due at termination under section 201;
- waiting time penalties under section 203;
- failure to produce an employee file under section 1198.5;
- misclassification as exempt under section 515;
- retaliation under section 1102.5;
- penalties under the Private Attorneys General Act (PAGA).
The plaintiff also alleged the following breaches of the California Fair Employment and Housing Act (FEHA): discrimination, harassment, and retaliation; failure to prevent discrimination, harassment, and retaliation; failure to provide reasonable accommodation; failure to engage in the good faith interactive process to determine effective reasonable accommodation; and wrongful termination.
The defendants filed a motion to...
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