Cooley

I. Introduction

18 The parties’ Joint Discovery Motion is presently before the Court. See Doc. No. 34 19 (the “Joint Motion”). The parties initially filed a version of the Joint Motion that omitted 20 the evidentiary exhibits relevant to resolving the issues before the Court. Doc. No. 33. The 21 substance of both Motions is the same: defendant is moving to compel production of 22 plaintiff’s draft autobiography. The Court addresses them as a single request for relief that 23 shall, as explained in this Order, be GRANTED IN PART.

II. Factual Background

25 This is a personal injury case, one of thousands of products liability cases filed 26 against defendants C.R. Bard, Inc. and Bard Peripheral Vascular, Inc. (collectively “Bard”) 27 based on Bard’s development and sale of retrievable inferior vena cava (“IVC”) filters. See 28 generally Doc. No. 1 ¶¶ 9-59. Plaintiff’s doctor implanted Bard’s first generation IVC filter, the Recovery filter, in plaintiff in 2005. Id. ¶ 60. In November 2020, plaintiff discovered the filter had fractured. See id. At present, plaintiff alleges fragments of the filter have lodged themselves in her heart, lung, and spine. See id. …