Travel, Entertainment, and Marketing v. Delino CA2/4

BACKGROUND

Travel, Entertainment, and Marketing, LLC (Team) sued its former employee, Brian Delino, and his company, BigDaddyFormals, LLC (collectively, Delino), alleging Delino misappropriated Team’s business, customers, and prospective clients. Delino filed a cross-complaint, alleging Team violated various provisions of the Labor Code when he was a Team’s employee, and, once he left, Team tortiously interfered with his business. In April 2023, Team served Delino with requests for production of documents and special interrogatories. Delino’s responses to the document requests consisted largely of boilerplate objections (e.g., the requests are overbroad, not reasonably particularized, and seek confidential trade secret information). Delino responded to certain special interrogatories, and objected to others (such as an interrogatory seeking the

2 name of his first client) on the purported grounds of trade secret privilege and third-party privacy rights. Team also noticed the deposition of Brian Delino, which included a request to produce documents. In response, Delino’s counsel objected to these document requests with similar boilerplate objections, including that the requests…