AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message does mention injuries in passing (e.g., 'what injuries did Plaintiff sustain in the collision'), the substantive content of the message is about a procedural civil litigation issue — specifically, whether multiple defendant groups are each entitled to demand separate Defense Medical Examinations (DMEs) under Code of Civil Procedure §2032.220, and how to seek a protective order to limit such examinations. This is a civil (not workers' compensation) discovery procedure topic. The word 'injury' appears only incidentally as part of the factual context, not as the focus of the message. A reader searching for information about 'injury' would not learn anything substantive or answerable from this message about that topic — it is tangentially related at best, with only keyword overlap rather than a direct answer to any question about injury.
"David Kadin" Date: June 24, 2026 6:47:00 PM Subject: Re: Sued Driver and Registered Owner - Do they get two DME's? Reply to list Reply to sender Print List: caala-workproduct Sent by: David Kadin (Reply Privately) Search I recently moved for the issuance of a protective order under somewhat similar circumstances. Below is my briefing. I hope it might be of some use to you. A. Defendants Must Be Collectively Limited to a Single Physical Examination and a Single Psychological Examination of Plaintiff. Three defendant groups. One collision. One plaintiff. Yet under a literal reading of Code of Civil Procedure §2032.220, which states that "any defendant may demand one physical examination," each defendant group could contend it is independently entitled to demand a physical examination and, separately, a mental examination. That result, if permitted, would expose Plaintiff to as many as three physical examinations and three psychological examinations, all arising from the single October 2, 2023, collision. Nothing in the Discovery Act contemplates, let alone sanctions, such a result, and this Court has full authority to prevent it. 1. Good Cause Under Sections 2025.420 and 2032.520. Sections 2025.420 and 2032.520 authorize this Court to issue a protective order limiting section 2032 examinations "for good cause shown." Good cause is overwhelmingly present here. The injury issues in this case are singular and identical across all three defendant groups: what injuries did Plaintiff sustain in the collision, what is the nature and extent of those injuries, and what is the prognosis? Every physical or psychological examination by every defendant will probe precisely the same questions. There is no legitimate discovery purpose served by multiple physicians examining the same injuries from the same collision for the benefit of multiple defendant groups. The only effect of permitting several examinations of the same kind is to multiply the burden on Plaintiff, who must physically present herself for each examination, arrange and pay for transportation each time (she has no driver's license and does not drive), and endure an examination process that, for psychological examinations, typically lasts six to eight hours, without producing any additional discovery value. When the injury issues are identical across defendants-as they unquestionably are here-there is no medical or scientific basis on which multiple independent examinations of the same body by different physicians would yield materially different findings. Each examiner will document the same condition, review the same prior medical records, and reach conclusions addressing the same injuries. The marginal discovery value of a second or third independent examination is, as a practical matter, zero. Against that zero, the burden on Plaintiff is concrete, substantial, and multiplied with each additional examination. 2. Evidence Code Section 723 and the Certainty of Trial Exclusion. That there is good cause for a protective order in this case is powerfully reinforced by Evidence Code §723, which authorizes courts to exclude cumulative expert evidence at trial. The California Supreme Court in Horn v. General Motors Corp. (1976) 17 Cal.3d 359, 370-371, confirmed that courts have broad discretion to exclude cumulative expert evidence, and courts routinely exercise that discretion to limit multiple experts testifying to the same physical condition. (See also, South Bay Chevrolet v. General Motors Acceptance Corp. (1999) 72 Cal.App.4th 861, 905-906; Scalere v. Stenson (1989) 211 Cal.App.3d 1446, 1454.) The purpose of having an expert doctor conduct a section 2032 examination is so the doctor has a basis to give expert opinions at trial. If three separate defendant groups each retain a physician who independently examines Plaintiff regarding the same injuries, each of those physicians becomes a trial expert on the same questions, precisely the cumulative expert witness situation that section 723 contemplates and empowers this Court to exclude. If those witnesses would be excluded at trial, as is highly likely here, the examinations they conducted during discovery produce no admissible testimony. The entire multi-examination process then becomes an exercise in generating inadmissible material at the cost of significant burden to Plaintiff. If a court could exclude cumulative expert medical testimony under section 723, permitting the cumulative examinations that produce that testimony "places more burden upon the adversary than the value of the information warrants." (Calcor, supra, 53 Cal.App.4th at 225.) A discovery procedure whose likely end-product is excludable testimony is precisely the kind of disproportionate and oppressive procedure that protective orders exist to prevent. This Court need not wait until trial to act: it may do so now, under section 2032.520, before Plaintiff is made to endure examinations whose results would be excludable anyway. (Fn.: The foregoing analysis is consistent with secondary authority Weil and Brown, California Practice Guide: Civil Procedure Before Trial (2024), which acknowledges that permitting each co-defendant independently to demand a section 2032 examination may be a "glitch" in the current statute, and confirms that a protective order is clearly appropriate where injury issues are identical across defendants.(¶¶8:1522 through 8:1523.)) 3. The Relief Sought Is Modest and Proportionate. The relief Plaintiff seeks is minimal: one jointly selected physician for one physical examination and one jointly selected examiner for one psychological examination, with defendants coordinating scheduling and sharing costs. All defendants collectively obtain the same information as would be available from independent examinations conducted separately. No defendant would be denied any information about Plaintiff's injuries relevant to its defense. The only thing foreclosed is the multiplication of burden on Plaintiff to produce the same information multiple times to multiple physicians examining the same body for the same collision. B. The Balance of Hardships Strongly Favors Plaintiff. This is not a hypothetical concern. Defendants have already served a Demand for Physical Examination scheduling Plaintiff for an examination on May 13, 2026, without prior consultation with Plaintiff's counsel and without any coordination with the remaining defendant groups. (Kadin Decl., ¶7; Exhibit 2.) Plaintiff objected on the ground that no stipulation existed limiting defendants collectively to a single examination, and the examination went off-calendar. Nothing prevents Defendants or either of the other two defendant groups, from serving a new demand at any time. The hardship on Plaintiff if this motion is denied is substantial. Plaintiff has no driver's license and no independent means of transportation. Each physical examination requires her to arrange and pay for transportation to the examiner's office and back, a round trip that, based on the Encino location selected by Defendants Garrett and Brown, would have cost approximately $45 each way. Psychological examinations impose an even heavier burden: they typically last six to eight hours, before travel time is even considered. Requiring Plaintiff to submit to three sets of physical and psychological examinations across three defendant groups, all examining the same injuries from the same collision is the very form of unwarranted oppression and undue burden that sections 2025.420 and 2032.520 are designed to prevent. -----Original Message----- From: eldabe@erlawyers.com Sent: June 24, 2026 5:00:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Sued Driver and Registered Owner - Do they get two DME's? Sued Driver and Reg Owner - Do they get two Defense Medical Exams DC Counsel from Behar Gibbs Savage Paulson is claiming they get two DMEs bc they have two clients. I can't find an authority to state otherwise. Thoughts? S Edmond El Dabe ELDABE ' RITTER TRIAL LAWYERS P 213-985-1120 F 213-985-1125
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a discovery dispute on a reopen claim — specifically about whether the defense attorney (DA) can take the applicant's deposition and a PQME deposition. While workers' compensation cases inherently involve injuries, this message does not directly explain, define, or substantively address the topic of 'injury' in any meaningful way. The message is cut off and appears to be about a procedural/discovery issue. It only tangentially relates to the concept of injury by virtue of being a workers' comp case. A reader would not learn anything substantive about 'injury' from this message.
I have a very favorable report on a reopen claim. DA wanted to take applicant's deposition and the PQME deposition. They previously took
AI Analysis:
The user's real question is a keyword search for 'injury.' This message only contains a passing mention that a case has been reassigned to Judge Amy Carter Torrance and describes it as a 'significant injury case.' It provides no substantive information about injury — no legal analysis, no procedural guidance, no case strategy, no statutory interpretation, nothing that would help someone learn anything meaningful about injury in a workers' compensation context. The word 'injury' appears merely as a descriptor of a case type, not as the subject of any discussion. This message does not answer or address the real question in any meaningful way.
"Richard Harting" Date: June 24, 2026 6:37:00 PM Subject: Re: Judge Amy Carter Torrance Reply to list Reply to sender Print List: caala-workproduct Sent by: Richard Harting (Reply Privately) Search 411Just reassigned to Judge Amy Carter Torrance on significant injury case. Richard A. Harting, Esq. Harting Simkins & Ryan , LLP 3711 Long Beach Boulevard, Suite 600 Long Beach, California 90807 (562) 981-1010 ■ FAX (562) 981-0101 mailto:Rich@HSRlegal.com http://www.HSRlegal.com Both Richard Harting and Harting Simkins & Ryan LLP intend that exclusively the addressee(s) use this message. This message may contain information that is privileged, confidential and exempt from disclosure under applicable law. Unauthorized disclosure or use of this information is strictly prohibited. If you have received this communication in error, please permanently dispose of the original message and notify Richard Harting immediately at 562-981-1010. Thank you. From: R. Scott Houtz (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, June 24, 2026 3:56 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Need to Serve Secretary of State List: caala-workproduct Sent by: R. Scott Houtz (Reply Privately) Search Hi All: Does someone have an application I can use to get a court order to serve the Secretary of State? TIA. R. Scott Houtz, Esq. (310) 795-7280
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message briefly mentions 'occupational injury coverage' in passing while discussing a UM (uninsured motorist) denial situation and advising about a claim with a provider called BlueStar. While the word 'injury' appears implicitly in the context, the message does not explain, define, analyze, or substantively address any legal question about injury in workers' compensation law. It is a short, case-specific procedural suggestion that merely references an injury-related insurance product without providing any substantive information that would help a reader learn anything meaningful about the topic of injury as it relates to workers' compensation. The message is too tangential and lacks substantive content to be considered relevant.
You can still make a claim with the occupational injury coverage provider, BlueStar, for medical expenses and disability payment.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses an unusual interplay between personal UM (uninsured motorist) coverage and Uber UM coverage for the same vehicle. While UM coverage situations can arise in the context of injuries, this message does not directly explain, answer, or address the concept of 'injury' in any substantive legal sense. The message is a brief subject-line-level description of a specific coverage dispute scenario with no substantive content about injury — its nature, compensability, legal standards, or any other aspect that would help answer a question about injury. It is too tangential and lacks any meaningful content to be considered relevant.
Have an unusual interplay between personal UM and Uber UM coverage for the same vehicle.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message appears to be an empty or incomplete reply from Ullasini Dholakia, containing only a quoted header from a prior message (from Hollie Rutkowski) with no substantive content visible. There is no actual message body that addresses any topic related to injury in workers' compensation. Even if the thread subject ('IW lied NOW WHAT?') might tangentially relate to workers' compensation issues, this specific message provides no substantive information whatsoever that would help answer any question about injury.
On Jun 24, 2026, at 9:31 AM, Hollie Rutkowski (lawnet listserver) <listsender-lawnet@lawnet.caaa.org> wrote:
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a brief recommendation of mediator Natasha Roit, praising her efficiency and effectiveness in settling a case. While the attorney's signature line mentions 'Serious Personal Injury, Wrongful Death, Medical and Legal Malpractice,' this is merely a boilerplate signature and does not provide any substantive information related to injury law, injury claims, injury analysis, or any legal question about injury. The message contains no discussion, explanation, or analysis that would help answer a question about injury. It is entirely about a mediator referral and contains no relevant substantive content.
"Robert Kahn" Date: June 24, 2026 6:49:00 PM Subject: Natasha Roit Reply to list Reply to sender Print Just settled a case with Natasha Roit as the mediator. She really is very good. Better than good. Excellent. She doesn’t waste time. Gets right down to business. Can’t say enough good things about her. Robert Robert A. Kahn, Esq. Trial Lawyer R OBERT K AHN L AW Robert@RobertKahnLaw.com 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 (818) 888-9171 (818) 888-7611 Serious Personal Injury, Wrongful Death, Medical and Legal Malpractice THIS ELECTRONIC MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU ARE NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS TRANSMISSION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR BY TELEPHONE AT (818) 888-9171, AND DESTROY THE ORIGINAL TRANSMISSION AND ITS ATTACHMENTS WITHOUT READING OR SAVING THEM TO DISK. THANK YOU. P Please consider the environment before printing this e-mail
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is about serving the Secretary of State and contains procedural documents (proposed order, declaration, motion for SOS service) related to that topic. The only mention of 'injury' in this message is in the attorney's email signature line describing his practice area as 'Employment & Personal Injury.' This is a purely incidental mention that does not provide any substantive information about injury — it does not explain, discuss, or answer any question related to injury in a workers' compensation or legal context. The message is entirely about service of process on the Secretary of State and is not relevant to the keyword search for 'injury.'
"Benjamine Sasounian, Esq." Date: June 24, 2026 6:22:00 PM Subject: Re: Need to Serve Secretary of State Reply to list Reply to sender Print Attachments: xp - proposed order.docx (48 K) xp - declaration.docx (49 K) xp - mtn for sos service.docx (50 K) See attached. Benjamine Sasounian, Esq. LITIGATION ATTORNEY – EMPLOYMENT & PERSONAL INJURY Address 9454 Wilshire Blvd. Suite 830 Beverly Hills, CA 90212 Phone ( 866) 429-4356 Direct (424) 777-0078 , Ext. 1054 TEXT (424) 499-4279 Fax (424) 467-1662 EmaIl benjamine.sasounian@sedlawgroup.com Web www.sedlawgroup.com www.ladylegal.com CONFIDENTIAL EMAIL TRANSMISSION & WARNING: This message and (any attachments hereto) contains confidential information and is intended only for the individual named. It may also be privileged or otherwise protected by work product immunity or other legal rules. If you are not the intended recipient you should not disseminate, distribute, copy this e-mail, or disclose its contents to anyone. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. Any review, use, distribution or disclosure by others is strictly prohibited. The recipient should check this email and any attachments for the presence of viruses. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission, nor does the sender accept liability for damage caused by any virus transmitted by this email. If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised that SEDAGHAT LAW GROUP, APC and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your potential case. ↩ Please Reply All when responding to this email. ♻ Please consider the environment before printing. From: R. Scott Houtz (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, June 24, 2026 3:56 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Need to Serve Secretary of State List: caala-workproduct Sent by: R. Scott Houtz (Reply Privately) Search Hi All: Does someone have an application I can use to get a court order to serve the Secretary of State? TIA. R. Scott Houtz, Esq. (310) 795-7280
AI Analysis:
This message does not answer the user's question about 'injury.' The thread is entirely about finding a collection attorney with experience handling assets owned by a trust. Joel Selik's response is essentially a self-promotional signature block advertising his legal services, which include 'Personal Injury' as one of many listed practice areas, but this is merely a passing mention in a credentials list — not substantive information about injury-related legal questions. No discussion of injury law, workers' compensation injury claims, injury standards, or any injury-related legal analysis is present. The message provides no information that would help someone seeking answers about injury.
"Joel Selik" Date: June 24, 2026 4:01:00 PM Subject: Re: Collection Attorney Referral Reply to list Reply to sender Print Attachments: image001.png (79 K) List: caala-workproduct Sent by: Joel Selik (Reply Privately) Search Me Joel@SelikLaw.com JOEL SELIK Attorney at Law Offices in Nevada & California 760-479-1515 , 702-243-1930 Accepting Select Cases Throughout California & Nevada Legal Malpractice, Judgment Collection Expert Witness, Mediator/Arbitrator Pro-Hac Vice, Medical & Other Professional Malpractice, Business Litigation, Personal Injury NV LEGAL MALPRACTICE CERTIFIED SPECIALIST and CA LEGAL MALPRACTICE CERTIFIED SPECIALIST by The State Bar of California Board of Legal Specialization Vice-Chair State Bar of Nevada Standing Committee on Ethics and Professional Responsibility Trial Bar News Ethics Column Editor – Consumer Attorneys of San Diego Expert Witness in Malpractice, Ethics, Professional Responsibility, Collection Awarded 2024 Pro Bono Impact of the Year Award Partnership Award 2022 Pro Bono Champion of Justice-Center 2018 Nevada Pro Bono Attorney of the Year On Wednesday, June 24, 2026, 1:28 PM, Douglas Silverstein (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Douglas Silverstein (Reply Privately) Search Looking for recommendations for a collection attorney, including one with experience where the assets are owned by a trust. Thanks! Douglas N. Silverstein, J.D., M.B.A. Kesluk, Silverstein, Jacob & Morrison, P.C. 9255 Sunset Blvd., Suite 411 Los Angeles, CA 90069 Tel: 310-273-3180 Fax: 310-273-6137 dsilverstein@californialaborlawattorney.com www.californialaborlawattorney.com President-Elect Past Chair, Litigation Section Looking for recommendations for a collection attorney, including one with experience where the assets are owned by a trust. Thanks! Douglas N. Silverstein, J.D., M.B.A. Kesluk, Silverstein, Jacob & Morrison, P.C. 9255 Sunset Blvd., Suite 411 Los Angeles, CA 90069 Tel: 310-273-3180 Fax: 310-273-6137 dsilverstein@californialaborlawattorney.com www.californialaborlawattorney.com President-Elect Past Chair, Litigation Section
AI Analysis:
The user's real question is a keyword search for 'injury.' This message contains only a sender name ('Diep Nguyen, Attorney At Law') and a subject line ('Re: Discovery Issue.'). There is no substantive content whatsoever — no discussion of injury, no legal analysis, no case information. The message body is essentially empty and provides no information that would help answer any question related to injury in a workers' compensation context.