California’s Discovery Act does not authorize a court to compel a plaintiff to undergo a vocational rehabilitation examination by the defendant’s vocational expert even when the plaintiff claims lost wages saying he is unable to work due to injuries suffered in the accident.  California courts may not order discovery other than that authorized by statute.  The Discovery Act allows medical and mental examinations, but not vocational rehabilitation examinations. 

California Court of Appeal, Sixth District (Bamattre-Manoukian, J.); March 1, 2017; 2017 WL 786464