Information is discoverable if relevant and unprivileged. Code of Civil Procedure section 2016. To the extent any documents that are responsive to a plaintiff’s requests are privileged or private, the defendant bears the burden of showing good cause for a protective order limiting discovery. See Valley Bank of Nevada v. Superior Court (1975) 15 Cal.3rd 652, 657; see also Citizens of Humanity, LLC v. Costco Wholesale Corp. (2009) Cal.App.4th 1, 13.
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