On August 14, 2018, Donald Cunningham (“Plaintiff”) filed this personal injury action against the San Luis Obispo Regional Transportation Authority (“Defendant”). The dispute concerns an accident which occurred on September 27, 2016, while Plaintiff was a passenger on one of Defendant’s buses. According to the complaint, the bus took a right hand turn too quickly, jumped the curb, and struck a light pole. Plaintiff states he was thrown from his seat, struck his face on the back of a hard plastic seat, and was then thrown to the floor. (Cunningham Decl., ¶ 5.)
On August 15, 2018, Defendant served Form Interrogatories, Special Interrogatories (set one), and Requests for Production of Documents (set one) on Plaintiff. Defendant granted Plaintiff three extensions to submit responses; the latest deadline falling on December 10, 2018. Plaintiff has not yet provided responses.1
Plaintiff seeks a protective order on the ground the propounded discovery is unduly burdensome, unwarranted, overbro