1. Motion to Quash or Modify Deposition Subpoena For Production of Business Records filed on 3-1-17 by Pltf. Debra Mazer; In the First Amended Complaint, Plaintiff Mazer contends she suffered “bouts of anxiety, anger, and crying” as a result of the chlorine smell, pain and discomfort it brought. (FAC, at ¶ 20.) In addition, in Plaintiff Mazer’s deposition, she stated that she and her husband, Defendant Schoensiegel, started seeing Dr. Andrea Schoon for marriage counseling and personal therapy around 2015 as a result of the marital discord caused by the issues alleged in this action. (Defendant’s Exhibit A, Depo. of Plaintiff Mazer, at pp. 51-173:25.) Plaintiff alleges she and her husband have seen Dr. Schoon approximately once a week since 2015, and that they never had “ups and downs” prior to the incident and had “20 years of marital bliss.” (Id.)
Plaintiff and her husband Defendant Schoensiegel have waived their right to privacy and the psychotherapist-patient privilege to communicat