Preview
1 Molly Thurmond, SBN: 104973
Cyrus Khosh-Chashm, SBN: 290643
2 MC LAW GROUP, APC
3905 State Street, Suite 7-351
3
Santa Barbara, CA 93105
4 Ph: (805) 979-9052
molly@mcgrouplaw.com
5 cyrus@mcgrouplaw.com
6 Attorneys for: Defendants, Santa Barbara
Unified School District, San Marcos High
7
School, Shannon Saleh, and Alex Sheldon
8
Fee Exempt Pursuant to Govt Code § 6103
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF SANTA BARBARA
12 ANACAPA DIVISION
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13
SOPHIE STRASBURG; GIDGET CASE NO.: 20CV00740
14 STRASBURG; KEVEN STRASBURG; [Assigned to Hon. Donna D. Geck in Dept. 4
SUMMER STRASBURG for all purposes]
15
16 Plaintiffs,
vs. DEFENDANT SANTA BARBARA
17 UNIFIED SCHOOL DISTRICT’S
SANTA BARBARA UNIFIED HIGH SEPARATE STATEMENT IN SUPPORT
18 SCHOOL DISTRICT; SAN MARCOS HIGH OF MOTION TO COMPEL PLAINTIFF’S
SCHOOL; SHANNON SALEH; ALEX FURTHER RESPONSES TO SPECIAL
19 INTERROGATORIES, SET THREE
SHELDON;
20 Date: May 31, 2024
Defendants.
21 Time: 10:00 a.m.
Dept: 4
22
Complaint Filed: February 07, 2020
23
24
25 Defendant Santa Barbara Unified School District hereby respectfully submits this Separate
26 Statement in Support of Motion to Compel Plaintiff’s Further Responses to Special Interrogatories,
27 Set Three, to Plaintiff Sophie Strasburg, pursuant to California Rules of Court Rule 3.1345. The
28 legal analysis begins on page 242, line 16.
1
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 SPECIAL INTERROGATORY NO. 602:
2 Please identify, with specificity, each and every area of YOUR body that YOU have suffered
3 bruising as a result of YOUR fall from the stage on February 22, 2019.
4 RESPONSE TO SPECIAL INTERROGATORY NO. 602:
5 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
6 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
7 preparation for, supervision of and presentation of a theatrical performance. As a result of their
8 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
9 malpractice case nor a class action case and does not involve a request for punitive damages. This
10 case is not complex either legally or factually.
11 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
12 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
14 previously propounded (bringing the total number of Special Interrogatories to 814) without having
15 included a declaration with sufficient factual bases to justify the excessive number of Special
16 Interrogatories.
17 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
18 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
19 Interrogatories relating to her injuries have previously been propounded to and responded to by
20 Sophie.
21 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
22 or summary from Plaintiff's previous discovery responses and deposition testimony already in
23 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
24 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
25 related medical records in response to Defendant's requests for production. Further, on July 11,
26 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
27 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
28 requested information has been provided previously. Continuous discovery into the same matter
2
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
2 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
3 SPECIAL INTERROGATORY NO. 603:
4 Please state, with specificity, how often YOU suffer from bruising as a result of YOUR fall from the
5 stage on February 22, 2019.
6 RESPONSE TO SPECIAL INTERROGATORY NO. 603:
7 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
8 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
9 preparation for, supervision of and presentation of a theatrical performance. As a result of their
10 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
11 malpractice case nor a class action case and does not involve a request for punitive damages. This
12 case is not complex either legally or factually.
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
14 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
15 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
16 previously propounded (bringing the total number of Special Interrogatories to 814) without having
17 included a declaration with sufficient factual bases to justify the excessive number of Special
18 Interrogatories.
19 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
20 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
21 Interrogatories relating to her injuries have previously been propounded to and responded to by
22 Sophie.
23 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
24 or summary from Plaintiff's previous discovery responses and deposition testimony already in
25 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
26 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
27 related medical records in response to Defendant's requests for production. Further, on July 11,
28 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
3
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
2 requested information has been provided previously. Continuous discovery into the same matter
3 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
4 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
5 SPECIAL INTERROGATORY NO. 604:
6 Please state, with specificity, each and every trigger that causes bruising as a result of YOUR fall
7 from the stage on February 22, 2019.
8 RESPONSE TO SPECIAL INTERROGATORY NO. 604:
9 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
10 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
11 preparation for, supervision of and presentation of a theatrical performance. As a result of their
12 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 malpractice case nor a class action case and does not involve a request for punitive damages. This
14 case is not complex either legally or factually.
15 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
16 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
17 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
18 previously propounded (bringing the total number of Special Interrogatories to 814) without having
19 included a declaration with sufficient factual bases to justify the excessive number of Special
20 Interrogatories.
21 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
22 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
23 Interrogatories relating to her injuries have previously been propounded to and responded to by
24 Sophie.
25 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
26 or summary from Plaintiff's previous discovery responses and deposition testimony already in
27 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
28 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
4
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 related medical records in response to Defendant's requests for production. Further, on July 11,
2 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
3 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
4 requested information has been provided previously. Continuous discovery into the same matter
5 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
6 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
7 SPECIAL INTERROGATORY NO. 605:
8 Please identify each and every mental injury YOU associate with bruising as a result of YOUR fall
9 from the stage on February 22, 2019.
10 RESPONSE TO SPECIAL INTERROGATORY NO. 605:
11 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
12 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 preparation for, supervision of and presentation of a theatrical performance. As a result of their
14 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
15 malpractice case nor a class action case and does not involve a request for punitive damages. This
16 case is not complex either legally or factually.
17 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
18 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
19 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
20 previously propounded (bringing the total number of Special Interrogatories to 814) without having
21 included a declaration with sufficient factual bases to justify the excessive number of Special
22 Interrogatories.
23 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
24 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
25 Interrogatories relating to her injuries have previously been propounded to and responded to by
26 Sophie.
27 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
28 or summary from Plaintiff's previous discovery responses and deposition testimony already in
5
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
2 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
3 related medical records in response to Defendant's requests for production. Further, on July 11,
4 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
5 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
6 requested information has been provided previously. Continuous discovery into the same matter
7 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
8 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
9 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define
10 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or
11 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction.
12 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries
14 that any ordinary person would experience in any similar situation arising from her accident. These
15 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief,
16 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable
17 to respond to this Special Interrogatory.
18 SPECIAL INTERROGATORY NO. 606:
19 Do YOU associate any of the mental injuries in the immediately preceding interrogatory with any
20 physical injury other than bruising?
21 RESPONSE TO SPECIAL INTERROGATORY NO. 606:
22 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
23 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
24 preparation for, supervision of and presentation of a theatrical performance. As a result of their
25 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
26 malpractice case nor a class action case and does not involve a request for punitive damages. This
27 case is not complex either legally or factually.
28 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
6
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
2 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
3 previously propounded (bringing the total number of Special Interrogatories to 814) without having
4 included a declaration with sufficient factual bases to justify the excessive number of Special
5 Interrogatories.
6 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
7 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
8 Interrogatories relating to her injuries have previously been propounded to and responded to by
9 Sophie.
10 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
11 or summary from Plaintiff's previous discovery responses and deposition testimony already in
12 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
14 related medical records in response to Defendant's requests for production. Further, on July 11,
15 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
16 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
17 requested information has been provided previously. Continuous discovery into the same matter
18 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
19 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
20 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define
21 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or
22 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction.
23 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from
24 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries
25 that any ordinary person would experience in any similar situation arising from her accident. These
26 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief,
27 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable
28 to respond to this Special Interrogatory.
7
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 SPECIAL INTERROGATORY NO. 607:
2 If YOUR answer to interrogatory 606 is “yes”, identify each and every physical injury other than
3 bruising.
4 RESPONSE TO SPECIAL INTERROGATORY NO. 607:
5 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
6 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
7 preparation for, supervision of and presentation of a theatrical performance. As a result of their
8 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
9 malpractice case nor a class action case and does not involve a request for punitive damages. This
10 case is not complex either legally or factually.
11 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
12 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
14 previously propounded (bringing the total number of Special Interrogatories to 814) without having
15 included a declaration with sufficient factual bases to justify the excessive number of Special
16 Interrogatories.
17 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
18 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
19 Interrogatories relating to her injuries have previously been propounded to and responded to by
20 Sophie.
21 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
22 or summary from Plaintiff's previous discovery responses and deposition testimony already in
23 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
24 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
25 related medical records in response to Defendant's requests for production. Further, on July 11,
26 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
27 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
28 requested information has been provided previously. Continuous discovery into the same matter
8
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
2 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
3 SPECIAL INTERROGATORY NO. 608:
4 Please identify, with specificity, each and every area of YOUR body that YOU have suffered
5 swelling as a result of YOUR fall from the stage on February 22, 2019.
6 RESPONSE TO SPECIAL INTERROGATORY NO. 608:
7 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
8 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
9 preparation for, supervision of and presentation of a theatrical performance. As a result of their
10 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
11 malpractice case nor a class action case and does not involve a request for punitive damages. This
12 case is not complex either legally or factually.
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
14 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
15 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
16 previously propounded (bringing the total number of Special Interrogatories to 814) without having
17 included a declaration with sufficient factual bases to justify the excessive number of Special
18 Interrogatories.
19 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
20 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
21 Interrogatories relating to her injuries have previously been propounded to and responded to by
22 Sophie.
23 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
24 or summary from Plaintiff's previous discovery responses and deposition testimony already in
25 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
26 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
27 related medical records in response to Defendant's requests for production. Further, on July 11,
28 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
9
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
2 requested information has been provided previously. Continuous discovery into the same matter
3 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
4 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
5 SPECIAL INTERROGATORY NO. 609:
6 Please state, with specificity, how often YOU suffer from swelling as a result of YOUR fall from the
7 stage on February 22, 2019.
8 RESPONSE TO SPECIAL INTERROGATORY NO. 609:
9 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
10 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
11 preparation for, supervision of and presentation of a theatrical performance. As a result of their
12 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 malpractice case nor a class action case and does not involve a request for punitive damages. This
14 case is not complex either legally or factually.
15 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
16 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
17 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
18 previously propounded (bringing the total number of Special Interrogatories to 814) without having
19 included a declaration with sufficient factual bases to justify the excessive number of Special
20 Interrogatories.
21 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
22 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
23 Interrogatories relating to her injuries have previously been propounded to and responded to by
24 Sophie.
25 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
26 or summary from Plaintiff's previous discovery responses and deposition testimony already in
27 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
28 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
10
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 related medical records in response to Defendant's requests for production. Further, on July 11,
2 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
3 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
4 requested information has been provided previously. Continuous discovery into the same matter
5 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
6 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
7 SPECIAL INTERROGATORY NO. 610:
8 Please state, with specificity, each and every trigger that causes swelling as a result of YOUR fall
9 from the stage on February 22, 2019.
10 RESPONSE TO SPECIAL INTERROGATORY NO. 610:
11 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
12 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 preparation for, supervision of and presentation of a theatrical performance. As a result of their
14 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
15 malpractice case nor a class action case and does not involve a request for punitive damages. This
16 case is not complex either legally or factually.
17 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
18 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
19 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
20 previously propounded (bringing the total number of Special Interrogatories to 814) without having
21 included a declaration with sufficient factual bases to justify the excessive number of Special
22 Interrogatories.
23 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
24 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
25 Interrogatories relating to her injuries have previously been propounded to and responded to by
26 Sophie.
27 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
28 or summary from Plaintiff's previous discovery responses and deposition testimony already in
11
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
2 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
3 related medical records in response to Defendant's requests for production. Further, on July 11,
4 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
5 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
6 requested information has been provided previously. Continuous discovery into the same matter
7 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
8 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
9 SPECIAL INTERROGATORY NO. 611:
10 Please identify each and every mental injury YOU associate with swelling as a result of YOUR fall
11 from the stage on February 22, 2019.
12 RESPONSE TO SPECIAL INTERROGATORY NO. 611:
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
14 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
15 preparation for, supervision of and presentation of a theatrical performance. As a result of their
16 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
17 malpractice case nor a class action case and does not involve a request for punitive damages. This
18 case is not complex either legally or factually.
19 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050
20 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by
21 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories
22 previously propounded (bringing the total number of Special Interrogatories to 814) without having
23 included a declaration with sufficient factual bases to justify the excessive number of Special
24 Interrogatories.
25 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already
26 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special
27 Interrogatories relating to her injuries have previously been propounded to and responded to by
28 Sophie.
12
SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE
1 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation
2 or summary from Plaintiff's previous discovery responses and deposition testimony already in
3 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form
4 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her
5 related medical records in response to Defendant's requests for production. Further, on July 11,
6 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in
7 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the
8 requested information has been provided previously. Continuous discovery into the same matter
9 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v.
10 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494.
11 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define
12 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or
Santa Barbara, CA 93105-3138
3905 State Street, Suite 7-351
MC LAW GROUP, APC
13 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction.
14 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from
15 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries
16 that any ordinary person would experience in any similar situation arising from her accident. These
17 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief,
18 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable
19 to respond to this Special Interrogatory.
20 SPECIAL INTERROGATORY NO. 612:
21 Do YOU associate any of the mental injuries in the immediately preceding interrogatory with any
22 physical injury other than swelling?
23 RESPONSE TO SPECIAL INTERROGATORY NO. 612:
24 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara
25 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their
26 preparation for, supervision of and presentation of a theatrical performance. As a result of their
27 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical
Preview
1 Molly Thurmond, SBN: 104973 Cyrus Khosh-Chashm, SBN: 290643 2 MC LAW GROUP, APC 3905 State Street, Suite 7-351 3 Santa Barbara, CA 93105 4 Ph: (805) 979-9052 molly@mcgrouplaw.com 5 cyrus@mcgrouplaw.com 6 Attorneys for: Defendants, Santa Barbara Unified School District, San Marcos High 7 School, Shannon Saleh, and Alex Sheldon 8 Fee Exempt Pursuant to Govt Code § 6103 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SANTA BARBARA 12 ANACAPA DIVISION Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 SOPHIE STRASBURG; GIDGET CASE NO.: 20CV00740 14 STRASBURG; KEVEN STRASBURG; [Assigned to Hon. Donna D. Geck in Dept. 4 SUMMER STRASBURG for all purposes] 15 16 Plaintiffs, vs. DEFENDANT SANTA BARBARA 17 UNIFIED SCHOOL DISTRICT’S SANTA BARBARA UNIFIED HIGH SEPARATE STATEMENT IN SUPPORT 18 SCHOOL DISTRICT; SAN MARCOS HIGH OF MOTION TO COMPEL PLAINTIFF’S SCHOOL; SHANNON SALEH; ALEX FURTHER RESPONSES TO SPECIAL 19 INTERROGATORIES, SET THREE SHELDON; 20 Date: May 31, 2024 Defendants. 21 Time: 10:00 a.m. Dept: 4 22 Complaint Filed: February 07, 2020 23 24 25 Defendant Santa Barbara Unified School District hereby respectfully submits this Separate 26 Statement in Support of Motion to Compel Plaintiff’s Further Responses to Special Interrogatories, 27 Set Three, to Plaintiff Sophie Strasburg, pursuant to California Rules of Court Rule 3.1345. The 28 legal analysis begins on page 242, line 16. 1 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 SPECIAL INTERROGATORY NO. 602: 2 Please identify, with specificity, each and every area of YOUR body that YOU have suffered 3 bruising as a result of YOUR fall from the stage on February 22, 2019. 4 RESPONSE TO SPECIAL INTERROGATORY NO. 602: 5 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 6 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 7 preparation for, supervision of and presentation of a theatrical performance. As a result of their 8 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 9 malpractice case nor a class action case and does not involve a request for punitive damages. This 10 case is not complex either legally or factually. 11 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 12 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 14 previously propounded (bringing the total number of Special Interrogatories to 814) without having 15 included a declaration with sufficient factual bases to justify the excessive number of Special 16 Interrogatories. 17 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 18 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 19 Interrogatories relating to her injuries have previously been propounded to and responded to by 20 Sophie. 21 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 22 or summary from Plaintiff's previous discovery responses and deposition testimony already in 23 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 24 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 25 related medical records in response to Defendant's requests for production. Further, on July 11, 26 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 27 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 28 requested information has been provided previously. Continuous discovery into the same matter 2 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 2 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 3 SPECIAL INTERROGATORY NO. 603: 4 Please state, with specificity, how often YOU suffer from bruising as a result of YOUR fall from the 5 stage on February 22, 2019. 6 RESPONSE TO SPECIAL INTERROGATORY NO. 603: 7 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 8 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 9 preparation for, supervision of and presentation of a theatrical performance. As a result of their 10 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 11 malpractice case nor a class action case and does not involve a request for punitive damages. This 12 case is not complex either legally or factually. Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 14 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 15 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 16 previously propounded (bringing the total number of Special Interrogatories to 814) without having 17 included a declaration with sufficient factual bases to justify the excessive number of Special 18 Interrogatories. 19 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 20 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 21 Interrogatories relating to her injuries have previously been propounded to and responded to by 22 Sophie. 23 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 24 or summary from Plaintiff's previous discovery responses and deposition testimony already in 25 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 26 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 27 related medical records in response to Defendant's requests for production. Further, on July 11, 28 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 3 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 2 requested information has been provided previously. Continuous discovery into the same matter 3 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 4 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 5 SPECIAL INTERROGATORY NO. 604: 6 Please state, with specificity, each and every trigger that causes bruising as a result of YOUR fall 7 from the stage on February 22, 2019. 8 RESPONSE TO SPECIAL INTERROGATORY NO. 604: 9 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 10 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 11 preparation for, supervision of and presentation of a theatrical performance. As a result of their 12 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 malpractice case nor a class action case and does not involve a request for punitive damages. This 14 case is not complex either legally or factually. 15 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 16 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 17 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 18 previously propounded (bringing the total number of Special Interrogatories to 814) without having 19 included a declaration with sufficient factual bases to justify the excessive number of Special 20 Interrogatories. 21 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 22 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 23 Interrogatories relating to her injuries have previously been propounded to and responded to by 24 Sophie. 25 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 26 or summary from Plaintiff's previous discovery responses and deposition testimony already in 27 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 28 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 4 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 related medical records in response to Defendant's requests for production. Further, on July 11, 2 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 3 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 4 requested information has been provided previously. Continuous discovery into the same matter 5 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 6 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 7 SPECIAL INTERROGATORY NO. 605: 8 Please identify each and every mental injury YOU associate with bruising as a result of YOUR fall 9 from the stage on February 22, 2019. 10 RESPONSE TO SPECIAL INTERROGATORY NO. 605: 11 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 12 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 preparation for, supervision of and presentation of a theatrical performance. As a result of their 14 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 15 malpractice case nor a class action case and does not involve a request for punitive damages. This 16 case is not complex either legally or factually. 17 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 18 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 19 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 20 previously propounded (bringing the total number of Special Interrogatories to 814) without having 21 included a declaration with sufficient factual bases to justify the excessive number of Special 22 Interrogatories. 23 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 24 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 25 Interrogatories relating to her injuries have previously been propounded to and responded to by 26 Sophie. 27 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 28 or summary from Plaintiff's previous discovery responses and deposition testimony already in 5 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 2 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 3 related medical records in response to Defendant's requests for production. Further, on July 11, 4 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 5 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 6 requested information has been provided previously. Continuous discovery into the same matter 7 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 8 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 9 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define 10 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or 11 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction. 12 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries 14 that any ordinary person would experience in any similar situation arising from her accident. These 15 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief, 16 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable 17 to respond to this Special Interrogatory. 18 SPECIAL INTERROGATORY NO. 606: 19 Do YOU associate any of the mental injuries in the immediately preceding interrogatory with any 20 physical injury other than bruising? 21 RESPONSE TO SPECIAL INTERROGATORY NO. 606: 22 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 23 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 24 preparation for, supervision of and presentation of a theatrical performance. As a result of their 25 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 26 malpractice case nor a class action case and does not involve a request for punitive damages. This 27 case is not complex either legally or factually. 28 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 6 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 2 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 3 previously propounded (bringing the total number of Special Interrogatories to 814) without having 4 included a declaration with sufficient factual bases to justify the excessive number of Special 5 Interrogatories. 6 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 7 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 8 Interrogatories relating to her injuries have previously been propounded to and responded to by 9 Sophie. 10 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 11 or summary from Plaintiff's previous discovery responses and deposition testimony already in 12 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 14 related medical records in response to Defendant's requests for production. Further, on July 11, 15 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 16 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 17 requested information has been provided previously. Continuous discovery into the same matter 18 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 19 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 20 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define 21 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or 22 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction. 23 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from 24 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries 25 that any ordinary person would experience in any similar situation arising from her accident. These 26 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief, 27 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable 28 to respond to this Special Interrogatory. 7 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 SPECIAL INTERROGATORY NO. 607: 2 If YOUR answer to interrogatory 606 is “yes”, identify each and every physical injury other than 3 bruising. 4 RESPONSE TO SPECIAL INTERROGATORY NO. 607: 5 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 6 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 7 preparation for, supervision of and presentation of a theatrical performance. As a result of their 8 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 9 malpractice case nor a class action case and does not involve a request for punitive damages. This 10 case is not complex either legally or factually. 11 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 12 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 14 previously propounded (bringing the total number of Special Interrogatories to 814) without having 15 included a declaration with sufficient factual bases to justify the excessive number of Special 16 Interrogatories. 17 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 18 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 19 Interrogatories relating to her injuries have previously been propounded to and responded to by 20 Sophie. 21 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 22 or summary from Plaintiff's previous discovery responses and deposition testimony already in 23 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 24 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 25 related medical records in response to Defendant's requests for production. Further, on July 11, 26 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 27 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 28 requested information has been provided previously. Continuous discovery into the same matter 8 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 2 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 3 SPECIAL INTERROGATORY NO. 608: 4 Please identify, with specificity, each and every area of YOUR body that YOU have suffered 5 swelling as a result of YOUR fall from the stage on February 22, 2019. 6 RESPONSE TO SPECIAL INTERROGATORY NO. 608: 7 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 8 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 9 preparation for, supervision of and presentation of a theatrical performance. As a result of their 10 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 11 malpractice case nor a class action case and does not involve a request for punitive damages. This 12 case is not complex either legally or factually. Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 14 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 15 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 16 previously propounded (bringing the total number of Special Interrogatories to 814) without having 17 included a declaration with sufficient factual bases to justify the excessive number of Special 18 Interrogatories. 19 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 20 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 21 Interrogatories relating to her injuries have previously been propounded to and responded to by 22 Sophie. 23 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 24 or summary from Plaintiff's previous discovery responses and deposition testimony already in 25 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 26 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 27 related medical records in response to Defendant's requests for production. Further, on July 11, 28 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 9 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 2 requested information has been provided previously. Continuous discovery into the same matter 3 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 4 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 5 SPECIAL INTERROGATORY NO. 609: 6 Please state, with specificity, how often YOU suffer from swelling as a result of YOUR fall from the 7 stage on February 22, 2019. 8 RESPONSE TO SPECIAL INTERROGATORY NO. 609: 9 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 10 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 11 preparation for, supervision of and presentation of a theatrical performance. As a result of their 12 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 malpractice case nor a class action case and does not involve a request for punitive damages. This 14 case is not complex either legally or factually. 15 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 16 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 17 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 18 previously propounded (bringing the total number of Special Interrogatories to 814) without having 19 included a declaration with sufficient factual bases to justify the excessive number of Special 20 Interrogatories. 21 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 22 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 23 Interrogatories relating to her injuries have previously been propounded to and responded to by 24 Sophie. 25 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 26 or summary from Plaintiff's previous discovery responses and deposition testimony already in 27 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 28 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 10 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 related medical records in response to Defendant's requests for production. Further, on July 11, 2 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 3 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 4 requested information has been provided previously. Continuous discovery into the same matter 5 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 6 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 7 SPECIAL INTERROGATORY NO. 610: 8 Please state, with specificity, each and every trigger that causes swelling as a result of YOUR fall 9 from the stage on February 22, 2019. 10 RESPONSE TO SPECIAL INTERROGATORY NO. 610: 11 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 12 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 preparation for, supervision of and presentation of a theatrical performance. As a result of their 14 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 15 malpractice case nor a class action case and does not involve a request for punitive damages. This 16 case is not complex either legally or factually. 17 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 18 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 19 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 20 previously propounded (bringing the total number of Special Interrogatories to 814) without having 21 included a declaration with sufficient factual bases to justify the excessive number of Special 22 Interrogatories. 23 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 24 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 25 Interrogatories relating to her injuries have previously been propounded to and responded to by 26 Sophie. 27 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 28 or summary from Plaintiff's previous discovery responses and deposition testimony already in 11 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 2 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 3 related medical records in response to Defendant's requests for production. Further, on July 11, 4 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 5 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 6 requested information has been provided previously. Continuous discovery into the same matter 7 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 8 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 9 SPECIAL INTERROGATORY NO. 611: 10 Please identify each and every mental injury YOU associate with swelling as a result of YOUR fall 11 from the stage on February 22, 2019. 12 RESPONSE TO SPECIAL INTERROGATORY NO. 611: Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 14 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 15 preparation for, supervision of and presentation of a theatrical performance. As a result of their 16 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical 17 malpractice case nor a class action case and does not involve a request for punitive damages. This 18 case is not complex either legally or factually. 19 This Special Interrogatory fails to comply with C.C.P. §§ 2030.030 (a) and (c), 2030.040, 2030.050 20 and 2030.070 as the propounding party has far exceeded the limit of 35 Special Interrogatories by 21 propounding an additional 212 Special Interrogatories over and about the 601 Special Interrogatories 22 previously propounded (bringing the total number of Special Interrogatories to 814) without having 23 included a declaration with sufficient factual bases to justify the excessive number of Special 24 Interrogatories. 25 Counsel’s Declaration was insufficient to justify more than the 601 Special Interrogatories already 26 propounded to and responded to by Sophie. Three Form Interrogatories and at least 41 Special 27 Interrogatories relating to her injuries have previously been propounded to and responded to by 28 Sophie. 12 SANTA BARBARA UNIFIED SCHOOL DISTRICT’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE 1 Objection. This Special Interrogatory is burdensome and oppressive and would require a compilation 2 or summary from Plaintiff's previous discovery responses and deposition testimony already in 3 Defendant's possession. Thus far, Plaintiff Sophie Strasburg has provided answers to form 4 interrogatories, has provided answers to over 600 special interrogatories, and has provided all her 5 related medical records in response to Defendant's requests for production. Further, on July 11, 6 2023, Sophie was deposed for over six hours. Sophie's deposition transcript is over 300 pages in 7 length. To comply with this Special Interrogatory would be an undue burden on Sophie because the 8 requested information has been provided previously. Continuous discovery into the same matter 9 constitutes oppression and Sophie further objects on this ground. Professional Career Colleges v. 10 Superior Court (1989) 207 Cal. App. 3d. 490, 493-494. 11 Objection. This Special Interrogatory is vague, ambiguous, and unclear in that it fails to define 12 “Mental Injuries.” The phrase “Mental Injury” normally means a loss of mental faculties, a mental or Santa Barbara, CA 93105-3138 3905 State Street, Suite 7-351 MC LAW GROUP, APC 13 behavioral disorder or a clinically significant behavioral cognitive or psychological dysfunction. 14 Sophie is not claiming that she suffered any traumatic brain injury or that she is suffering from 15 memory issues, confusion, or any other cognitive deficits. She is claiming emotional distress injuries 16 that any ordinary person would experience in any similar situation arising from her accident. These 17 injuries include physical pain, mental suffering, loss of enjoyment of life, disfigurement, grief, 18 anxiety, and humiliation. Without an explanation as to definition of mental injuries, Sophie is unable 19 to respond to this Special Interrogatory. 20 SPECIAL INTERROGATORY NO. 612: 21 Do YOU associate any of the mental injuries in the immediately preceding interrogatory with any 22 physical injury other than swelling? 23 RESPONSE TO SPECIAL INTERROGATORY NO. 612: 24 Objection. The lawsuit filed by Sophie Strasburg, hereafter Sophie, against the Santa Barbara 25 Unified School District, et al. is a simple case. Sophie alleges that Defendants were negligent in their 26 preparation for, supervision of and presentation of a theatrical performance. As a result of their 27 negligence, Sophie fell off a stage and suffered severe injuries. Sophie’s case is neither a medical