PLAINTIFF'S MOTION TO COMPEL DEPOSITION IS GRANTED.

Background

On July 5, 2019, Plaintiff Amanda Martinez filed the instant action against Defendant Good Neighbor Clinic and Does 1 through 20. The Complaint asserts causes of action for:

Discrimination in Violation of Gov’t Code §§ 12940, et seq.;

Retaliation in Violation of Gov’t Code §§ 12940, et seq.;

Failure to Prevent Discrimination and Retaliation in Violation of Gov’t Code § 12940(k);

Declaratory Judgment;

Retaliation (Lab. Code §§ 98.6, 1030, et seq.); and

Wrongful Termination in Violation of Public Policy.

Plaintiff moves for an order compelling the deposition of Defendant’s Person(s) Most Knowledgeable (“PMK”) and for an award of monetary sanctions against Defendant and its counsel of record, Leslie McAfee and the Law Offices of Leslie McAfee in the amount of $7,820.10.

Legal Standard

Any party may obtain discovery, subject to restrictions, by taking the oral deposition of any person, including any party to the acti