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FILEO/EMDORSED
1 JOSHUA S. FALAKASSA (SBN: 295045) AUG 0 5 2022
FALAKASSA LAW, P.C.
2 1901 Avenue of the Stars Suite # 450
By: E. Macdonald
3 Los Angeles, Califomia 90067 Uepijly Clerk
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY MAN LAW, P.C.
1010 F Sfreet, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDAZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO
13
14
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
15 RESERVATION ID: 2665216
Plaintiff,
16 DECLARATION OF ARASH S.
vs. KHOSROWSHAHI IN SUPPORT OF
17 MOTION TO QUASH OR MODIFY THE
LIQUI-BOX CORPORATION, and DOES 1 SCOPE OF SUBPOENA TO US
18 through 20, inclusive. HEALTHWORKS AND MONETARY
SANCTIONS
19 Defendants.
20 Date: October 20, 2022
Time: 1:30pm 3
21 Dept.: 53 Li.
>-
Trial Date: September 12, 2022 CQ
22
I, ARASH KHOSROWSHAHI, declare as follows:
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1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei
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is 293246.
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2. I represent Plaintiff Sajida Zaman ("Plaintiff) in the above-entitled action. I have
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knowledge of the facts stated herein and can testify competently thereto.
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
1 of 4
1 3. On or about July 21, 2022, counsel for Defendant served a subpoena to US Healthworks
2 requesting the entirety of Plaintiff s medical records as follows:
3 "Complete medical records from the first date of treatment to the present, including
4 but not limited to any records/docimients that may be stored digitally and/or electronically:
5 TeleHealth Records and any recordings, documents, correspondence, correspondence from
6 the patient or patient's attomey, patient intake forms, copies of health insurance cards and
7 photo ID'S, medical reports, doctor's entries, nurse's notes, medication administration
8 records, office notes, progress reports, cardiology reports, radiology reports, x-ray reports
9 MRI reports, CT reports, myelogram reports, lab reports, pathology reports, monitor strips
10 physical therapy records, occupational therapy records, case history, emergency records
11 outpatient records, diagnosis and prognosis documentation, admit and discharge records
12 notation(s) on any file folder. All emails between physicians and the patient regarding
13 physical complaints, symptoms, and treatment, including secure messages. And every such
14 record, including those existing in electronic or magnetic form, in the possession, custody
15 or control of the said witness, and every such record to which the witness may have access
16 The date rage of records needed is Any and all records."
17 (Attached as Exhibit A is a tme and correct copy of the Deposition Subpoena foi
18 Production of Business Records & Notice to Consumer or Employee and Objection; see
19 Attachment 3 therein [emphasis added].)
20 4. Upon receipt of the subpoena, I sent a detailed meet and confer letter on or about July 28
21 2022 arguing in sum that the requested records were overbroad and violated Plaintiffs
22 right to privacy in her medical records. (Attached as Exhibit B is a tme and correct copy
23 of the July 28, 2022 meet and confer letter.) Plaintiff offered to limit the scope of the
24 subpoena to encompass the disabilities related to the instant wrongfiil termination suit,
25 along with her related emotional distress. (See Exhibit B.)
26 5. On July 29, 2022, counsel for Defendant requested that the records encompass Plaintiffs
27 2013 workers compensation injury, given that Plaintiff placed that injury at issue in hei
28 opposition to Defendant's Motion for Summary Judgment. (Attached as Exhibit C are
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
2 of 4
1 emails between counselfi-omJuly 29, 2022 to August 1, 2022.) Counsel for Defendant
2 fiirther claimed that Defendant wanted medical records documenting any other condition
3 that precluded Plaintiff from working, but that if her workers compensation file for a related
4 subpoena referred to unrelated information, he would agree to limit the scope. (See Exhibit
5 C.)
6 6. That same day, I sent a follow-up email asking whether Defendant's counsel proposal
7 regarding the 2013 injury applied only to the related subpoena, or the medical records
8 subpoena to US Healthworks and other medical record subpoenas as well. (Id.) Not having
9 heard a response, I sent a follow-up email on August 1, 2022. (Id.) But Defendant did not
10 follow up.
11 7. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a
12 Top 14 law school. Ifiirthergraduated with a Bachelor of Science in Mathematics (Honors)
13 and a Bachelor of Arts in Philosophy (Highest Honors)fi-omthe University of Califomia.
14 Davis in 2009. I run a solo practice in Sacramento, Califomia, and have been practicing
15 law since December 2013.1 primarily handle unlimited civil litigation cases in employment
16 law, which include class-action wage-and-hour cases as well as wrongful termination
17 cases. I practice throughout the State of Califomia, having litigated cases successfully in
18 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also
19 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as
20 well as six-figure settlements for wrongfiil termination matters. I was selected as a Super
21 Lawyer Rising Star in Northem Califomia in 2020, 2021, and 2022, a distinction that is
22 reserved for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I
23 believe an hourly rate of $500 is a reasonable hourly rate.
24 8. I spent 1.5 hours researching and drafting this instant Motion and related documents herein,
25 resulting in $750.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion
26 filing fee. I therefore respectfully request sanctions in the amoimt of $810.00 for reasonable
27 costs and attorney's fees.
28
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
3 of 4
1 I declare under penalty of perjury under the laws of the State of California that the
2 foregoing is tme and correct.
3 Dated: August 5, 2022
4
5 By:
Arash S. Khosrowshahi
6
Attomey for Plaintiff Sajida Zaman
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
4 of 4
EXHIBIT A
SUBP-025
MTORNEY OR PARTY WrTHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY
James Jones, Bar # 167967
Jackson Lewis P.C. -132849
WO Capital Mall #1600
Sacramento, CA 95814
TELEPHONE NO.:916-341-0404 FAX NO. (Opfon8/):916-340-0141
E-MAIL ADDRESS (Opffona/):
OktrORNEY FOR (Wame): Defendant, LIQUI-BOX CORPORATION
SUPERIOR COURT OF CAUFORNIA, COUNTY OF SACRAMENTO
STREET ADDRESS: 720 Ninth Street
CITY AND ZIP CODE: Sacramento, CA 95814
CASE NUMBER:
Sajida Zaman VS. Liquf-BOX corporation, and DOES 1 through 20, inclusive
34-2019-00252121-GU-WT-GDS
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Civ. Proc, §§ 1985.3,1985.6)
NOTICE TO CONSUMER OR EMPLOYEE
To Sajida Zaman and/or attomeys of record: Liberty Man Law, Arash S. Khosrowshahi, 1010 F Street, SuHe 300, Sacramento,
CA 95&14 and FALAi object only to the production of the following specified records:
3. The specHic grounds for my objection are as follows:
Date:
(TYPE OR PRINT NAME) (SIGNATURE)
(Proof of seroice on reverse)
Fonn Adopted for Mandatory Uso NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Code of Civil Procedure.
JudlcEal Council of CaGIomia §§ 188S.3. ISSG.S,
SUBFM)25 [Rev. January t. 2008] 2020.010-2020.510
wmif.LE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, ffltnown):
US Health Worlts, 1675 Ailiambra Blvd., Sutte B, Sacramento, CA 95816
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described In item 3, as follows:
To (name of deposition officer): Onteilus, Phone No. 877-807-5162
On (date): 8/12/2022 At: (time): 10:00 a.m.
Locatton (address): 170 E. Arrow Highway, San Dimas, CA 91773
Do not release tite requested records to tiie deposition officer prior to the date and time stated above.
a. I I by deliverina a true, legible, and durable copy of the business records described in item 3. enclosed in a sealed Inner
wrapper with the title and number of the action, name of witness, and date of subpoena deariy written on it. The inner
wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the
address in Item 1.
b. I I by delivering a tme, legible, and durable copy of the business records descritted in item 3 to the deposition officer at the
witness's address, on receipt of payment In cash or by checi< of the reasonable costs of preparing the copy, as detennined
under Evidence Coda section 1563(b).
c. i X i by malting the origlnal business records described in item 3 available tor inspection at your business address by the
attomey's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
2. TTie recofds are to be produced by the date and time shown (n item 1 (but not sooner than 20 days after ttie issuance of the
deposition sut)f)oena, or 15 days after sen/ice, wNcheverdate is later). Reasonable costs of locating records, making them available
or copying tftem, and postage. If any, are recoverable as set forth in Evidence Code section 1563(b). The records 5/>a// be
accompanied by an affidavit of the custodian or other qualilied witness pursuant to Evidence Code section 1561.
3. The records to be produced are descriiied as foliows (if electronically stored infonmation Is demanded, the form or forms in
whidft each type of information is to be produced may be specified):
Record Subject: Sajida Zaman; DOB: 3/19/1965 SSN: xxx-xx-4074
I X I Continued on Attachment 3
4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER
CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN
SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WRTNESSES. AND CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO B E LIABLE
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOlJfif\FAiLURE TO OBEY.
(TITLE)
(Proof of service on reverse) Page 1 of 2
Fam Adopted fcr ttandatny Use DEPOSITION SUBPOENA FOR PRODUCTION CodaafCMPiwedura. §$2020.410-2020.440
Judldal Council of CaSbmla Qovemment Code, §(8097.
SUBP^IO (Rev, January 1, 2012] OF BUSINESS RECORDS
Order No.: 440643-004
Attachment 3 (Records To Be Produced)
Please provide the following records pertaining to:
Sajida Zaman
DOB: 3/19/1965 SSN: xxx-xx-4074
(Domptete medical records from the first date of treatment tc the present, including but not
limited to any records/documents that may be stored digitally and/or electronically:
TeleHealth Records and any recordings, documents, correspondenc®, correspondence
from the patient or patient's attorney, patient intake forms, copies of heaWi insurance
cards and photo ID's, medical reports, doctor's entries, nurse's notes, medication
administration records, office notes, progress reports, cardiology reports, radiology reports,
x-ray reports, MRI reports, CT reports, myelogram reports, lab reports, pathology reports,
monitor strips, physical therapy records, occupational therapy records, case history,
emergency records, outpatient records, diagnosis and prognosis documentation, admit
and discharge records, notation(s) on any file folder. All emails between physicians and
the patient regarding physical complaints, symptoms, and treatment, including secure
messages, and every such record, including those existing in electronic or magnetic form,
in the possession, custody or c:ontrol of the said witness, and every such record to which
the witness may have access.
The date range of records needed is Any and all records.
Order No.: 440643-004
SUBP-010
Sajida Zaman CASE NUMBER:
V.
Liqui-BOX corporation, and DOES 1 through 20, Induslve 34-2019-00252121-CU-WT-GDS
PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
1. I served this Deposition Subpoena for Production of Business Records by personally delivering a copy to the person served as
a. Person served (name):
b. Address where served: ) I u s Health Worte
n 1675 Alhambra Blvd.. Suite B
Sacramento, CA 95816
c. Date of delivery:
d. Time of delivery:
e- (1) n Witness fess were paid.
Amount $
(2) O Copying fees were paid.
Amount $
f. Fee for service $
2.1 received this subpoena for service on (date):
3. Person Serving:
a. Not a registered Califomia process server
b. Califomia sheriff or marshal
c. Registered California process server
d. Employee or independent contractor of a registered California process server
Exempt from registration under Business of a Professions Code section 22350(b).
Registered professional photocopier.
9 Exempt from registration under Business of a Professions Code section 22451.
h. Name, address, telephone number, and, if applicable, a>unty of rsgistration and number
Onteilus, 170 E. Arrow Highway, San Dimas, CA 91773; 800-229-7477
County of IJOS Angeles
Registration Number. 2017064325
I declare under penalty of perjury under the laws of the State of (For California sheriff or marshal u&e only)
Califomia that the foregoing is true and correct. I certify that the foregoing is true and correct.
Date:
(SIGNATURE) (SIGNATURE)
Forni AdoptedforMandatory Use DEPOSITION SUBPOENA FOR PRODUCTION Code of Civil Procedure. §§2020.410-2020.440
Judicial CouncS of CaSSortia Govelnnient Code. §66097.
SUBP-010 (Rev. January 1,2012] OF BUSINESS RECORDS
Orda-No.: 440643-004
EXHIBIT B
uM
LIBERTY MAN LAW, P.C.
1010 F Street, Ste. 300
Sacramento, California 95814
Tel.: (916) 573-0469
Fax: (866) 700-0787
Email: ash(a).libertvmanlaw.com
www.libertvmanlaw.com
July 28, 2022
SENT VIA EMAIL
CcJACKSON LEWIS P.C.
Attn: JAMES T. JONES
400 Capitol Mall, Suite 1600
Sacramento, Califomia 95814
Email: iames.iones@iacksonlewis.com
Kelly. Asano(a),iacksonlewis.com
SENT VIA U.S. MAIL
Cc: US Health Works
1675 Alhambra Blvd., Suite B,
Sacramento, CA 95816
Re: Zaman v. Liqui-Box Corporation, et al., Case No.: 34-2019-00252121
Meet and confer re: medical records subpoena for Plaintiff Sajida Zaman.
Counsel:
Our office received your recent subpoena for Plaintiff Sajida Zaman's ("Plaintiff') medical
records at US Health Works, wherein Defendant Liqui-Box Corporation ("Defendant") requested
the following documents:
"Complete medical records from the first date of treatment to the present, including
but not limited to any records/documents that may be stored digitally and/or electronically:
TeleHealth Records and any recordings, documents, correspondence, correspondence from
the patient or patient's attomey, patient intake forms, copies of health insurance cards and
photo ID'S, medical reports, doctor's entries, nurse's notes, medication administration
records, office notes, progress reports, cardiology reports, radiology reports, x-ray reports,
MRI reports, CT reports, myelogram reports, lab reports, pathology reports, monitor strips,
physical therapy records, occupational therapy records, case history, emergency records,
outpatient records, diagnosis and prognosis documentation, admit and discharge records,
notation(s) on any file folder, All emails between physicians and the patient regarding
physical complaints, symptoms, and treatment, including secure messages. And every such
record, including those existing in electronic or magnetic form, in the possession, custody
or control of the said witness, and every such record to which the witness may have access.
The date rage of records needed is Any and all records."
1 of 3
(emphasis added.)
This request for Plaintiffs medical records is clearly overbroad and intended to harass our
client by violating her right to medical privacy as to records not related to her instant wrongful
termination suit against Defendant.
"In evaluating privacy claims, considerations which, among others, will affect the exercise
of the trial court's discretion include the purpose of the information sought, the effect that
disclosure will have on the parties and on the trial, the nature of the objections urged by the
party resisting disclosure, and ability of the court to make an alternative order which may
grant partial disclosure, disclosure in another form, or disclosure only in the event that the
party seeking the information undertakes certain specified burdens which appear just under
the circumstances." (Alch v. Superior Court (2008) 165 Cal.App.4th 1412, 1425-26 [emphasis
added][citations omitted].)
Plaintiff has a statutory physician-patient privilege to her medical records. (See Evid. Code
§§ 990, 1014.) She also has an "inalienable right of privacy" provided by the Califomia
Constitution, Article 1 § 1. Here, the language in the subpoena must not include any medical
records referring to any medical conditions not claimed in the lawsuit, which in this case are
Plaintiffs disabilities and emotional distress. As confirmed in Hale v. Superior Court (1994) 28
Cal.App.4th 1421, 1424, even if part of a medical condition is at issue, it does not follow that the
plaintiff waived the privilege as to otherwise-protected aspects of her medical history during her
lifetime, or some condition that they may have suffered from at the time of her termination which
is clearly uiu-elated to the termination.
In addition, the court inBritt v. Sup. Ct. (1978) 20 Cal.3d 844, 863-64, explained that,
"[P]laintiffs are not 'obligated to sacrifice all privacy to seek redress for a specific [physical],
mental or emotional injury'; while they may not withhold information which relates to any
physical or mental condition which they have put in issue by bringing this lawsuit, they are entitled
to retain the confidentiality of all unrelated medical or psychotherapeutic treatment they may have
undergone in the past." The burden is on the party seeking the constitutionally protected
information to establish direct relevance. Mere speculation that portions of the medical records
might be relevant to some substantive issue is not enough. (See also Davis v. Superior
Court (1992) 7 Cal.App.4th 1008, 1117, 1120.)
Further, while Code of Civil Procedure § 2017.010 allows a party to obtain discovery
regarding any matter not privileged so long as the requests are reasonably calculated to lead to the
discovery of admissible evidence, the statute does not give counsel the right to engage in improper
fishing expeditions. In Greyhound Corp. v. Superior Cowr^ (1961) 56 Cal.2d 355, 384-85, the
Supreme Court of Califomia stated:
"The method of 'fishing' may be, in a particular case, entirely improper (i.e., insufficient
identification of the requested information to acquaint the other party with the nature of
information desired, attempt to place the burden and cost of supplying information equally
available to both solely upon the adversary, placing more burden upon the adversary
than the value of the information warrants, etc.)"
(emphasis added.)
2 of 3
We understand if the requests are reasonably limited to records regarding Plaintiffs
specific disabilities and/or related treatments, as well as records related to her emotional distress.
But to broadly request "Any and all records" and "Complete medical recordsfromthe fu-st date of
treatment to the present" goes beyond what is directly relevant to the case at hand. Indeed, the
subpoena language is so broad that it does not limit its request to the knee or hamstring disabilities
Plaintiff alleges in her operative complaint, but broadly requests documents related to any
disability or medical condition whatsoever, and incidental documents such as what
communications healthcare providers have had with Plaintiff regarding her records outside the
scope of this case. In short, the proposed subpoena language is not directly relevant to the case at
hand and is overbroad as to scope.
Defendant cannot use the subpoena power to unearth and uncover every bit of personal and
private detail of Plaintiff s medical history. As such, the scope of the proposed subpoena language
must be curtailed to not infringe on Plaintiffs rights to privacy.
Please let me know by August 4, 2022 whether you will agree to modify the scope of the
subpoena to only seek Plaintiffs medical records in relation to her knee/hamstring disabilities
involved in this case and related emotional distress—otherwise we will file a motion to
quash/modify the scope of the subpoena and seek sanctions.
Regards,
Arash S. Khosrowshahi, Attomey at Law
Cc: Sajida Zaman
Joshua Falakassa
Kasra Torabi
3 of 3
EXHIBIT C
8/5/22,10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
^nriiBll Arasli Khosrowshahi
Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
Arash Khosrowshahi Mon, Aug 1, 2022 at 10:00 AM
To: "Jones, James T (Sacramento)"
Cc: "Asano, Kelly H.. (Sacramento)" , Joshua Falakassa , Kasra
Torabi
Hi James,
IHope you had a great weekend.
I am following up on my email Friday. Are you proposing a limitation in scope as to Plaintiffs disabilities involved in this
case and emotional distress, along with the 2013 workers compensation injury, for all of the subpoenas, or just the one
issued to Travelers?
Please clarify soon as the motion to quash deadline is fast approaching.
Regards,
Arash "Ash" Khosrowshahi, Esq. (he/him)
Liberty Man Law, P.C.
1010 F Street, Ste. 300
Sacramento, CA 95814
Tel.: (916) 573-0469
Fax: (866) 700-0787
ash@libertymanlaw.com
www.libertymanlaw.com
"The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu
OM
CONFIDENTIAL NOTICE:
This email and any files transmitted with it are confidential and intended solely for the use of the individual or
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On Fri, Jul 29, 2022 at 1:15 PM Arash Khosrowshahi wrote:
James,
Is your proposal re: the 2013 injury only as to the Travelers' subpoena or as to all of the medical record subpoenas?
Regards,
Arash "Ash" Khosrowshahi, Esq. (he/him)
Liberty l^an Law, P.C.
1010 F Street, Ste. 300
j Sacramento, CA 95814
I Tel.: (916) 573-0469
( Fax: (866) 700-0787
I ash@libertymanlaw.com
I www.libertymanlaw.com
https://mail.google.com/mail/u/0/?il<=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 1/4
8/5/22, 10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
"The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu
CONFIDENTIAL NOTICE:
This email and any files transmitted with it are confidential and intended solely for the use of the individual or
entity to whom they are addressed. If you have received this email in error please notify the sender. This
message contains confidential Information and is intended only for the individual named. If you are not the
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If
you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in
reliance on the contents of this information is strictly prohibited.
On Fri, Jul 29, 2022 at 11:38 AM Jones, James T. (Sacramento) wrote:
I \ Ash,
It should also include references in that file related to the 2013 injury that you placed at issue in your opposition to
the MSJ and any other condition that precluded her from working. However, if her WC file refers to medical
information unrelated to these issues, we can definitely limit it. I do not need or want to know her whole medical
history.
Can we agree on these parameters?
James T. Jones
o Attomey at Law
Jackson Lewis P.C.
400 Capitol Mall
Suite 1600
Sacramento, CA 95814
Direct: (916) 288-3020 | Main: (916) 341-0404
James.Jones(S)jacksonlewis.com | www.jacksonlewis.com
From: Arash Khosrowshahi
Sent: Friday, July 29, 2022 11:24 AM
To: Jones, James T. (Sacramento) ; Asano, Kelly H.. (Sacramento)
Cc: Joshua Falakassa ; Kasra Torabi
Subject: Re: Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
lEXTERNAL SENDER]
Counsel,
Please see this additional meet and confer letter related to the Travelers' subpoena.
tittps://mail.google.com/mail/u/0/?ik=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 2/4
8/5/22, 10:40 AM Liberty Man Law, P.C. Mall - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
Regards,
Arash "Ash" Khosrowshahi, Esq. (he/him)
Liberty l^lan Law, P.C.
1010 F Street, Ste. 300
Sacramento, CA 95814
Tel.: (916) 573-0469
Fax: (866) 700-0787
ash@llbertymanlaw.com
www.libertymanlaw.com
"The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu
CONFIDENTIAL NOTICE:
This email and any files transmitted with it are confidential and intended solely for the use of the individual or
entity to whom they are addressed. If you have received this email in error please notify the sender. This
message contains confidential information and is intended only for the individual named. If you are not the
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If
you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in
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On Thu, Jul 28, 2022 at 5:13 PM Arash Khosrowshahi wrote:
Counsel,
Please review the attached meet and confer letters.
i I Regards,
Arash "Ash" Khosrowshahi, Esq. (he/him)
Liberty Man Law, P.C.
1010 F Street, Ste. 300
Sacramento, CA 95814
Tel.: (916) 573-0469
Fax: (866) 700-0787
https://mail.google.com/mail/u/0/?ik=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 3/4
8/5/22, 10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas
ash@libertymanlaw.com
www.libertymanlaw.com
"The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu
CONFIDENTIAL NOTICE:
This email and any files transmitted with it are confidential and intended solely for the use of the individual
or entity to whom they are addressed. If you have received this email in error please notify the sender. This
message contains confidential information and is intended only for the individual named. If you are not the
named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.
If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any
action in reliance on the contents of this information is strictly prohibited.
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FILEO/EMDORSED 1 JOSHUA S. FALAKASSA (SBN: 295045) AUG 0 5 2022 FALAKASSA LAW, P.C. 2 1901 Avenue of the Stars Suite # 450 By: E. Macdonald 3 Los Angeles, Califomia 90067 Uepijly Clerk Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY MAN LAW, P.C. 1010 F Sfreet, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDAZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 14 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 15 RESERVATION ID: 2665216 Plaintiff, 16 DECLARATION OF ARASH S. vs. KHOSROWSHAHI IN SUPPORT OF 17 MOTION TO QUASH OR MODIFY THE LIQUI-BOX CORPORATION, and DOES 1 SCOPE OF SUBPOENA TO US 18 through 20, inclusive. HEALTHWORKS AND MONETARY SANCTIONS 19 Defendants. 20 Date: October 20, 2022 Time: 1:30pm 3 21 Dept.: 53 Li. >- Trial Date: September 12, 2022 CQ 22 I, ARASH KHOSROWSHAHI, declare as follows: 23 1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei 24 is 293246. 25 2. I represent Plaintiff Sajida Zaman ("Plaintiff) in the above-entitled action. I have 26 knowledge of the facts stated herein and can testify competently thereto. 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 1 of 4 1 3. On or about July 21, 2022, counsel for Defendant served a subpoena to US Healthworks 2 requesting the entirety of Plaintiff s medical records as follows: 3 "Complete medical records from the first date of treatment to the present, including 4 but not limited to any records/docimients that may be stored digitally and/or electronically: 5 TeleHealth Records and any recordings, documents, correspondence, correspondence from 6 the patient or patient's attomey, patient intake forms, copies of health insurance cards and 7 photo ID'S, medical reports, doctor's entries, nurse's notes, medication administration 8 records, office notes, progress reports, cardiology reports, radiology reports, x-ray reports 9 MRI reports, CT reports, myelogram reports, lab reports, pathology reports, monitor strips 10 physical therapy records, occupational therapy records, case history, emergency records 11 outpatient records, diagnosis and prognosis documentation, admit and discharge records 12 notation(s) on any file folder. All emails between physicians and the patient regarding 13 physical complaints, symptoms, and treatment, including secure messages. And every such 14 record, including those existing in electronic or magnetic form, in the possession, custody 15 or control of the said witness, and every such record to which the witness may have access 16 The date rage of records needed is Any and all records." 17 (Attached as Exhibit A is a tme and correct copy of the Deposition Subpoena foi 18 Production of Business Records & Notice to Consumer or Employee and Objection; see 19 Attachment 3 therein [emphasis added].) 20 4. Upon receipt of the subpoena, I sent a detailed meet and confer letter on or about July 28 21 2022 arguing in sum that the requested records were overbroad and violated Plaintiffs 22 right to privacy in her medical records. (Attached as Exhibit B is a tme and correct copy 23 of the July 28, 2022 meet and confer letter.) Plaintiff offered to limit the scope of the 24 subpoena to encompass the disabilities related to the instant wrongfiil termination suit, 25 along with her related emotional distress. (See Exhibit B.) 26 5. On July 29, 2022, counsel for Defendant requested that the records encompass Plaintiffs 27 2013 workers compensation injury, given that Plaintiff placed that injury at issue in hei 28 opposition to Defendant's Motion for Summary Judgment. (Attached as Exhibit C are DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 2 of 4 1 emails between counselfi-omJuly 29, 2022 to August 1, 2022.) Counsel for Defendant 2 fiirther claimed that Defendant wanted medical records documenting any other condition 3 that precluded Plaintiff from working, but that if her workers compensation file for a related 4 subpoena referred to unrelated information, he would agree to limit the scope. (See Exhibit 5 C.) 6 6. That same day, I sent a follow-up email asking whether Defendant's counsel proposal 7 regarding the 2013 injury applied only to the related subpoena, or the medical records 8 subpoena to US Healthworks and other medical record subpoenas as well. (Id.) Not having 9 heard a response, I sent a follow-up email on August 1, 2022. (Id.) But Defendant did not 10 follow up. 11 7. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a 12 Top 14 law school. Ifiirthergraduated with a Bachelor of Science in Mathematics (Honors) 13 and a Bachelor of Arts in Philosophy (Highest Honors)fi-omthe University of Califomia. 14 Davis in 2009. I run a solo practice in Sacramento, Califomia, and have been practicing 15 law since December 2013.1 primarily handle unlimited civil litigation cases in employment 16 law, which include class-action wage-and-hour cases as well as wrongful termination 17 cases. I practice throughout the State of Califomia, having litigated cases successfully in 18 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also 19 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as 20 well as six-figure settlements for wrongfiil termination matters. I was selected as a Super 21 Lawyer Rising Star in Northem Califomia in 2020, 2021, and 2022, a distinction that is 22 reserved for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I 23 believe an hourly rate of $500 is a reasonable hourly rate. 24 8. I spent 1.5 hours researching and drafting this instant Motion and related documents herein, 25 resulting in $750.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion 26 filing fee. I therefore respectfully request sanctions in the amoimt of $810.00 for reasonable 27 costs and attorney's fees. 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 3 of 4 1 I declare under penalty of perjury under the laws of the State of California that the 2 foregoing is tme and correct. 3 Dated: August 5, 2022 4 5 By: Arash S. Khosrowshahi 6 Attomey for Plaintiff Sajida Zaman 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 4 of 4 EXHIBIT A SUBP-025 MTORNEY OR PARTY WrTHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY James Jones, Bar # 167967 Jackson Lewis P.C. -132849 WO Capital Mall #1600 Sacramento, CA 95814 TELEPHONE NO.:916-341-0404 FAX NO. (Opfon8/):916-340-0141 E-MAIL ADDRESS (Opffona/): OktrORNEY FOR (Wame): Defendant, LIQUI-BOX CORPORATION SUPERIOR COURT OF CAUFORNIA, COUNTY OF SACRAMENTO STREET ADDRESS: 720 Ninth Street CITY AND ZIP CODE: Sacramento, CA 95814 CASE NUMBER: Sajida Zaman VS. Liquf-BOX corporation, and DOES 1 through 20, inclusive 34-2019-00252121-GU-WT-GDS NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Civ. Proc, §§ 1985.3,1985.6) NOTICE TO CONSUMER OR EMPLOYEE To Sajida Zaman and/or attomeys of record: Liberty Man Law, Arash S. Khosrowshahi, 1010 F Street, SuHe 300, Sacramento, CA 95&14 and FALAi object only to the production of the following specified records: 3. The specHic grounds for my objection are as follows: Date: (TYPE OR PRINT NAME) (SIGNATURE) (Proof of seroice on reverse) Fonn Adopted for Mandatory Uso NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Code of Civil Procedure. JudlcEal Council of CaGIomia §§ 188S.3. ISSG.S, SUBFM)25 [Rev. January t. 2008] 2020.010-2020.510 wmif.LE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, ffltnown): US Health Worlts, 1675 Ailiambra Blvd., Sutte B, Sacramento, CA 95816 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described In item 3, as follows: To (name of deposition officer): Onteilus, Phone No. 877-807-5162 On (date): 8/12/2022 At: (time): 10:00 a.m. Locatton (address): 170 E. Arrow Highway, San Dimas, CA 91773 Do not release tite requested records to tiie deposition officer prior to the date and time stated above. a. I I by deliverina a true, legible, and durable copy of the business records described in item 3. enclosed in a sealed Inner wrapper with the title and number of the action, name of witness, and date of subpoena deariy written on it. The inner wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the address in Item 1. b. I I by delivering a tme, legible, and durable copy of the business records descritted in item 3 to the deposition officer at the witness's address, on receipt of payment In cash or by checi< of the reasonable costs of preparing the copy, as detennined under Evidence Coda section 1563(b). c. i X i by malting the origlnal business records described in item 3 available tor inspection at your business address by the attomey's representative and permitting copying at your business address under reasonable conditions during normal business hours. 2. TTie recofds are to be produced by the date and time shown (n item 1 (but not sooner than 20 days after ttie issuance of the deposition sut)f)oena, or 15 days after sen/ice, wNcheverdate is later). Reasonable costs of locating records, making them available or copying tftem, and postage. If any, are recoverable as set forth in Evidence Code section 1563(b). The records 5/>a// be accompanied by an affidavit of the custodian or other qualilied witness pursuant to Evidence Code section 1561. 3. The records to be produced are descriiied as foliows (if electronically stored infonmation Is demanded, the form or forms in whidft each type of information is to be produced may be specified): Record Subject: Sajida Zaman; DOB: 3/19/1965 SSN: xxx-xx-4074 I X I Continued on Attachment 3 4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WRTNESSES. AND CONSUMER OR EMPLOYEE AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS. DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO B E LIABLE FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOlJfif\FAiLURE TO OBEY. (TITLE) (Proof of service on reverse) Page 1 of 2 Fam Adopted fcr ttandatny Use DEPOSITION SUBPOENA FOR PRODUCTION CodaafCMPiwedura. §$2020.410-2020.440 Judldal Council of CaSbmla Qovemment Code, §(8097. SUBP^IO (Rev, January 1, 2012] OF BUSINESS RECORDS Order No.: 440643-004 Attachment 3 (Records To Be Produced) Please provide the following records pertaining to: Sajida Zaman DOB: 3/19/1965 SSN: xxx-xx-4074 (Domptete medical records from the first date of treatment tc the present, including but not limited to any records/documents that may be stored digitally and/or electronically: TeleHealth Records and any recordings, documents, correspondenc®, correspondence from the patient or patient's attorney, patient intake forms, copies of heaWi insurance cards and photo ID's, medical reports, doctor's entries, nurse's notes, medication administration records, office notes, progress reports, cardiology reports, radiology reports, x-ray reports, MRI reports, CT reports, myelogram reports, lab reports, pathology reports, monitor strips, physical therapy records, occupational therapy records, case history, emergency records, outpatient records, diagnosis and prognosis documentation, admit and discharge records, notation(s) on any file folder. All emails between physicians and the patient regarding physical complaints, symptoms, and treatment, including secure messages, and every such record, including those existing in electronic or magnetic form, in the possession, custody or c:ontrol of the said witness, and every such record to which the witness may have access. The date range of records needed is Any and all records. Order No.: 440643-004 SUBP-010 Sajida Zaman CASE NUMBER: V. Liqui-BOX corporation, and DOES 1 through 20, Induslve 34-2019-00252121-CU-WT-GDS PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS 1. I served this Deposition Subpoena for Production of Business Records by personally delivering a copy to the person served as a. Person served (name): b. Address where served: ) I u s Health Worte n 1675 Alhambra Blvd.. Suite B Sacramento, CA 95816 c. Date of delivery: d. Time of delivery: e- (1) n Witness fess were paid. Amount $ (2) O Copying fees were paid. Amount $ f. Fee for service $ 2.1 received this subpoena for service on (date): 3. Person Serving: a. Not a registered Califomia process server b. Califomia sheriff or marshal c. Registered California process server d. Employee or independent contractor of a registered California process server Exempt from registration under Business of a Professions Code section 22350(b). Registered professional photocopier. 9 Exempt from registration under Business of a Professions Code section 22451. h. Name, address, telephone number, and, if applicable, a>unty of rsgistration and number Onteilus, 170 E. Arrow Highway, San Dimas, CA 91773; 800-229-7477 County of IJOS Angeles Registration Number. 2017064325 I declare under penalty of perjury under the laws of the State of (For California sheriff or marshal u&e only) Califomia that the foregoing is true and correct. I certify that the foregoing is true and correct. Date: (SIGNATURE) (SIGNATURE) Forni AdoptedforMandatory Use DEPOSITION SUBPOENA FOR PRODUCTION Code of Civil Procedure. §§2020.410-2020.440 Judicial CouncS of CaSSortia Govelnnient Code. §66097. SUBP-010 (Rev. January 1,2012] OF BUSINESS RECORDS Orda-No.: 440643-004 EXHIBIT B uM LIBERTY MAN LAW, P.C. 1010 F Street, Ste. 300 Sacramento, California 95814 Tel.: (916) 573-0469 Fax: (866) 700-0787 Email: ash(a).libertvmanlaw.com www.libertvmanlaw.com July 28, 2022 SENT VIA EMAIL CcJACKSON LEWIS P.C. Attn: JAMES T. JONES 400 Capitol Mall, Suite 1600 Sacramento, Califomia 95814 Email: iames.iones@iacksonlewis.com Kelly. Asano(a),iacksonlewis.com SENT VIA U.S. MAIL Cc: US Health Works 1675 Alhambra Blvd., Suite B, Sacramento, CA 95816 Re: Zaman v. Liqui-Box Corporation, et al., Case No.: 34-2019-00252121 Meet and confer re: medical records subpoena for Plaintiff Sajida Zaman. Counsel: Our office received your recent subpoena for Plaintiff Sajida Zaman's ("Plaintiff') medical records at US Health Works, wherein Defendant Liqui-Box Corporation ("Defendant") requested the following documents: "Complete medical records from the first date of treatment to the present, including but not limited to any records/documents that may be stored digitally and/or electronically: TeleHealth Records and any recordings, documents, correspondence, correspondence from the patient or patient's attomey, patient intake forms, copies of health insurance cards and photo ID'S, medical reports, doctor's entries, nurse's notes, medication administration records, office notes, progress reports, cardiology reports, radiology reports, x-ray reports, MRI reports, CT reports, myelogram reports, lab reports, pathology reports, monitor strips, physical therapy records, occupational therapy records, case history, emergency records, outpatient records, diagnosis and prognosis documentation, admit and discharge records, notation(s) on any file folder, All emails between physicians and the patient regarding physical complaints, symptoms, and treatment, including secure messages. And every such record, including those existing in electronic or magnetic form, in the possession, custody or control of the said witness, and every such record to which the witness may have access. The date rage of records needed is Any and all records." 1 of 3 (emphasis added.) This request for Plaintiffs medical records is clearly overbroad and intended to harass our client by violating her right to medical privacy as to records not related to her instant wrongful termination suit against Defendant. "In evaluating privacy claims, considerations which, among others, will affect the exercise of the trial court's discretion include the purpose of the information sought, the effect that disclosure will have on the parties and on the trial, the nature of the objections urged by the party resisting disclosure, and ability of the court to make an alternative order which may grant partial disclosure, disclosure in another form, or disclosure only in the event that the party seeking the information undertakes certain specified burdens which appear just under the circumstances." (Alch v. Superior Court (2008) 165 Cal.App.4th 1412, 1425-26 [emphasis added][citations omitted].) Plaintiff has a statutory physician-patient privilege to her medical records. (See Evid. Code §§ 990, 1014.) She also has an "inalienable right of privacy" provided by the Califomia Constitution, Article 1 § 1. Here, the language in the subpoena must not include any medical records referring to any medical conditions not claimed in the lawsuit, which in this case are Plaintiffs disabilities and emotional distress. As confirmed in Hale v. Superior Court (1994) 28 Cal.App.4th 1421, 1424, even if part of a medical condition is at issue, it does not follow that the plaintiff waived the privilege as to otherwise-protected aspects of her medical history during her lifetime, or some condition that they may have suffered from at the time of her termination which is clearly uiu-elated to the termination. In addition, the court inBritt v. Sup. Ct. (1978) 20 Cal.3d 844, 863-64, explained that, "[P]laintiffs are not 'obligated to sacrifice all privacy to seek redress for a specific [physical], mental or emotional injury'; while they may not withhold information which relates to any physical or mental condition which they have put in issue by bringing this lawsuit, they are entitled to retain the confidentiality of all unrelated medical or psychotherapeutic treatment they may have undergone in the past." The burden is on the party seeking the constitutionally protected information to establish direct relevance. Mere speculation that portions of the medical records might be relevant to some substantive issue is not enough. (See also Davis v. Superior Court (1992) 7 Cal.App.4th 1008, 1117, 1120.) Further, while Code of Civil Procedure § 2017.010 allows a party to obtain discovery regarding any matter not privileged so long as the requests are reasonably calculated to lead to the discovery of admissible evidence, the statute does not give counsel the right to engage in improper fishing expeditions. In Greyhound Corp. v. Superior Cowr^ (1961) 56 Cal.2d 355, 384-85, the Supreme Court of Califomia stated: "The method of 'fishing' may be, in a particular case, entirely improper (i.e., insufficient identification of the requested information to acquaint the other party with the nature of information desired, attempt to place the burden and cost of supplying information equally available to both solely upon the adversary, placing more burden upon the adversary than the value of the information warrants, etc.)" (emphasis added.) 2 of 3 We understand if the requests are reasonably limited to records regarding Plaintiffs specific disabilities and/or related treatments, as well as records related to her emotional distress. But to broadly request "Any and all records" and "Complete medical recordsfromthe fu-st date of treatment to the present" goes beyond what is directly relevant to the case at hand. Indeed, the subpoena language is so broad that it does not limit its request to the knee or hamstring disabilities Plaintiff alleges in her operative complaint, but broadly requests documents related to any disability or medical condition whatsoever, and incidental documents such as what communications healthcare providers have had with Plaintiff regarding her records outside the scope of this case. In short, the proposed subpoena language is not directly relevant to the case at hand and is overbroad as to scope. Defendant cannot use the subpoena power to unearth and uncover every bit of personal and private detail of Plaintiff s medical history. As such, the scope of the proposed subpoena language must be curtailed to not infringe on Plaintiffs rights to privacy. Please let me know by August 4, 2022 whether you will agree to modify the scope of the subpoena to only seek Plaintiffs medical records in relation to her knee/hamstring disabilities involved in this case and related emotional distress—otherwise we will file a motion to quash/modify the scope of the subpoena and seek sanctions. Regards, Arash S. Khosrowshahi, Attomey at Law Cc: Sajida Zaman Joshua Falakassa Kasra Torabi 3 of 3 EXHIBIT C 8/5/22,10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas ^nriiBll Arasli Khosrowshahi Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas Arash Khosrowshahi Mon, Aug 1, 2022 at 10:00 AM To: "Jones, James T (Sacramento)" Cc: "Asano, Kelly H.. (Sacramento)" , Joshua Falakassa , Kasra Torabi Hi James, IHope you had a great weekend. I am following up on my email Friday. Are you proposing a limitation in scope as to Plaintiffs disabilities involved in this case and emotional distress, along with the 2013 workers compensation injury, for all of the subpoenas, or just the one issued to Travelers? Please clarify soon as the motion to quash deadline is fast approaching. Regards, Arash "Ash" Khosrowshahi, Esq. (he/him) Liberty Man Law, P.C. 1010 F Street, Ste. 300 Sacramento, CA 95814 Tel.: (916) 573-0469 Fax: (866) 700-0787 ash@libertymanlaw.com www.libertymanlaw.com "The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu OM CONFIDENTIAL NOTICE: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e- mail If you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On Fri, Jul 29, 2022 at 1:15 PM Arash Khosrowshahi wrote: James, Is your proposal re: the 2013 injury only as to the Travelers' subpoena or as to all of the medical record subpoenas? Regards, Arash "Ash" Khosrowshahi, Esq. (he/him) Liberty l^an Law, P.C. 1010 F Street, Ste. 300 j Sacramento, CA 95814 I Tel.: (916) 573-0469 ( Fax: (866) 700-0787 I ash@libertymanlaw.com I www.libertymanlaw.com https://mail.google.com/mail/u/0/?il<=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 1/4 8/5/22, 10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas "The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu CONFIDENTIAL NOTICE: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. This message contains confidential Information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On Fri, Jul 29, 2022 at 11:38 AM Jones, James T. (Sacramento) wrote: I \ Ash, It should also include references in that file related to the 2013 injury that you placed at issue in your opposition to the MSJ and any other condition that precluded her from working. However, if her WC file refers to medical information unrelated to these issues, we can definitely limit it. I do not need or want to know her whole medical history. Can we agree on these parameters? James T. Jones o Attomey at Law Jackson Lewis P.C. 400 Capitol Mall Suite 1600 Sacramento, CA 95814 Direct: (916) 288-3020 | Main: (916) 341-0404 James.Jones(S)jacksonlewis.com | www.jacksonlewis.com From: Arash Khosrowshahi Sent: Friday, July 29, 2022 11:24 AM To: Jones, James T. (Sacramento) ; Asano, Kelly H.. (Sacramento) Cc: Joshua Falakassa ; Kasra Torabi Subject: Re: Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas lEXTERNAL SENDER] Counsel, Please see this additional meet and confer letter related to the Travelers' subpoena. tittps://mail.google.com/mail/u/0/?ik=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 2/4 8/5/22, 10:40 AM Liberty Man Law, P.C. Mall - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas Regards, Arash "Ash" Khosrowshahi, Esq. (he/him) Liberty l^lan Law, P.C. 1010 F Street, Ste. 300 Sacramento, CA 95814 Tel.: (916) 573-0469 Fax: (866) 700-0787 ash@llbertymanlaw.com www.libertymanlaw.com "The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu CONFIDENTIAL NOTICE: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. On Thu, Jul 28, 2022 at 5:13 PM Arash Khosrowshahi wrote: Counsel, Please review the attached meet and confer letters. i I Regards, Arash "Ash" Khosrowshahi, Esq. (he/him) Liberty Man Law, P.C. 1010 F Street, Ste. 300 Sacramento, CA 95814 Tel.: (916) 573-0469 Fax: (866) 700-0787 https://mail.google.com/mail/u/0/?ik=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpl=msg-a%3Ar4... 3/4 8/5/22, 10:40 AM Liberty Man Law, P.C. Mail - Zaman v. Liqui-Box Corp: meet and confer re: medical record subpoenas ash@libertymanlaw.com www.libertymanlaw.com "The victorious win and then go to war, the defeated go to war and then seek to win." ~ Sun Tzu CONFIDENTIAL NOTICE: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. https://mail.google.com/maii/u/0/?ll<=2c35811dd3&view=pt&search=all&permmsgid=msg-a%3Ar4325038082277996702&dsqt=1&simpi=msg-a%3Ar4... 4/4