Magallanes

BACKGROUND

1. The Lawsuit and Discovery Dispute As alleged in her complaint, while attending school in 2017, Magallanes (then seven years old) fell and struck her head on an asphalt playground. Through her mother and guardian ad litem, Magallanes sued the District for negligence, negligent supervision, and dangerous condition of public property, alleging inter alia that the school asphalt caused Magallanes to trip and fall.

2 In April 2017, Magallanes and her mother sought legal representation from the Law Offices of Gary Berkovich. In connection with its representation of Magallanes, the office generated approximately 20 pages of intake documents. One of the documents memorialized a description of the incident, as provided by Magallanes or her mother, including a statement that Magallanes’s friend had pushed the child, causing her to fall on an uneven floor. The Law Offices of Gary Berkovich were replaced by Blair & Ramirez as counsel for Magallanes. Between June and September 2019, a legal assistant for Blair & Ramirez emailed three of Magallanes’s expert witnesses Dropbox links to access “Medical Records,” “Academic Records,” “Responses to Discovery,” and “All Documents…