If one wants to depose a high-level official who seeks a protective order to prohibit the deposition, the court should determine whether there is good cause showing that the official has unique or superior personal knowledge of discoverable information, a California court has said.
In the case of Eleni Gavriiloglou v. Prime Healthcare Management, Inc. et al., the plaintiff filed a complaint against her former employer and its alleged alter egos – Prime Healthcare Management, Inc., Prime Healthcare Management II, Inc., Hospital Business Services, Inc., and Dr. Prem Reddy.
