Gropen v. Superior Court of San Diego County (2023)

Disability accommodations under Rule 1.100 may be requested orally, and are not forfeited by failing to raise the accommodation in a motion; Failure to comply with local rules re accommodations is not a valid basis to deny accommodation; Disabled party not required to give notice to opposing counsel that he was bringing a support person to his deposition; After first deposition was canceled and opposition moved for protective order excluding support person, and disabled party requested support person's presence as an accommodation, trial court abused its discretion by denying request for accommodation as untimely when second deposition had not been scheduled