Crochet v. California College of the Arts

Background

Jillian Crochet sought discovery from California College of the Arts (CCA) before her October 12 deposition of CCA’s representative. The court considered Crochet’s October 2 letter brief and CCA’s July 22 letter brief. The order addressed discovery concerning access barriers identified in Crochet’s complaint, including barriers involving facilities and issues of access for people with physical disabilities.

Rulings on Discovery

- Interrogatory No. 5: CCA had to amend its response for each access barrier Crochet had specifically identified in her complaint and identify any administrative remedies that CCA alleged Crochet had not exhausted. - Requests for Admission Nos. 1, 6, 11, 12, 18, and 50: CCA had to amend its responses to identify more clearly what it admitted and denied. It did not have to use the exact wording of the requests. - Requests for Admission Nos. 14, 15, and 46–48: The court overruled CCA’s objections that the requests were vague, ambiguous, or lacked foundation. CCA had to admit, deny, or give qualified responses; if it could not do so, it had to explain in detail why not. - Requests for Admission Nos. 31–40 and 42–45: CCA had to clarify whether it had made a reasonable inquiry and whether the information it knew or could readily obtain was insufficient to admit or deny the requests. CCA had to amend its responses again after obtaining information needed to answer them, which might not occur until after the deposition. - Request for Admission No. 41: No supplemental response was required because CCA had denied the request in full. - Requests for Production Nos. 5–8 and 18: CCA had to produce responsive documents concerning facilities specifically identified in Crochet’s complaint, access issues for people with physical disabilities, and documents created from 2015 through the present. After the deposition, Crochet could seek a broader production but would have to explain why documents outside those limits were relevant. - Requests for Production Nos. 12, 16, and 17: CCA had to produce responsive documents in its possession because the requests specifically concerned Crochet and were relevant. - Requests for Production Nos. 19 and 20: CCA did not have to produce the requested documents, which concerned faculty housing and student housing at residences other than the Panoramic, because Crochet had not explained their relevance. - Requests for Production Nos. 21–24 and 26–33: For each access barrier specifically identified in the complaint, CCA had to produce responsive documents in its possession. - Request for Production No. 25: The record did not establish whether CCA’s tax returns from 2010 to the present were relevant and proportional to the needs of the case. The parties had to meet and confer and, if necessary, submit another joint letter; they could wait until after the deposition. - Requests for Production Nos. 34 and 36: The court overruled CCA’s objections. CCA had to produce responsive documents in its possession because they concerned notice.

Disposition and Effect

The court ordered CCA to comply by October 9, 2020, and reminded both parties of their continuing duty to supplement discovery responses and disclosures as the case proceeded. This was a discovery order, not a decision on the underlying claims. Judge William Alsup issued the order.

Reviewer note on metadata

The supplied case metadata identifies William Alsup as the judge. The reproduced signature block appears to refer to a United States Magistrate Judge, so the judge designation should be checked against the original docket or filing.