Plaintiffs’ Motion to Quash, Modify or Limit Subpoenas GRANTED with respect to the request to quash the subpoenas. This is without prejudice to Victor Sanders potentially seeking a more limited range of information based upon a sufficient showing of facts supporting the need for it.
A person’s psychiatric records are protected by the right of privacy and, if communications between a person and that person’s psychotherapist, also by the statutory privilege set forth in Evidence Code section 1014. Roe v. Sup. Ct. (1991) 229 Cal.App.3d 832, 837.
When seeking information that potentially falls under the right of privacy, the party demanding disclosure must show a particularized need for the confidential information. Merely being relevant to the subject matter is not enough, and the moving party must show that the information is directly relevant to the case, in other words that it is essential to determining the truth of the matters in dispute. Britt v. Sup. Ct. (San Diego Unif. Port Dist.