Plaintiff Gemma Romero brings this motion to compel production of documents. Plaintiff served Defendant Century Design, Inc. with a Demand for Production of Documents on April 29, 2019. Defendant served code-compliant responses nearly a year later, on April 13, 2020. In defendant's responses, defendant asserted objections based on attorney-client privilege and attorney work product doctrine.

In the meet and confer process, plaintiff requested defendant to produce a privilege log, identifying documents not being produced and withheld based on the attorney-client/work product objections. The privilege log issue seems to have gotten lost when defendant informed plaintiff that defendant was withholding schematics and technical diagrams that were "confidential and proprietary." Defendant insisted plaintiff agree to a protective order before these items were produced. The dispute over privilege log and the demand for a protective order resulted in this motion. Plaintiff seeks an order compe