Alfa Consult SA v. TCI International, Inc.

District Court, N.D. California·Decided November 9, 2023·No. 5:21-cv-00812·Unknown

Opinion

1 2 3 6 7 ALFA CONSULT SA, Case No. 21-cv-00812-BLF

8 Plaintiff, ORDER GRANTING IN PART AND 9 v. DENYING IN PART MOTIONS IN LIMINE FILED BY ALFA CONSULT 10 TCI INTERNATIONAL, INC., SA AND TCI INTERNATIONAL, INC. 11 Defendant. Re: ECF Nos. 109, 110, 111, 112

12 13 On November 2, 2023, the Court held a pretrial conference in this action, during which it 14 issued oral rulings on Plaintiff Alfa Consult SA’s (“Alfa”) Motion in Limine No. 1 and Defendant 15 TCI International, Inc.’s (“TCI”) Motions in Limine Nos. 1–3. The Court here expands upon those 16 oral rulings. 18 In its sole motion in limine, Alfa moves to exclude all evidence of or reference to the 19 proceedings Alfa brought in Iraq to contest the Iraqi Communications Media Commission’s 20 (“CMC”) award to the Al Zaman Group (“AZG”) of a spectrum monitoring system project 21 (“CMC Project”). See Alfa MIL 1, at 1, ECF No. 111. Alfa notes that the Iraqi proceedings at 22 issue include (1) Alfa’s formal objection to the CMC’s award of the project to AZG; and (2) 23 Alfa’s litigation against the CMC in Iraq challenging its award to AZG of the project, which 24 resulted in two judgments by Iraqi courts—including Iraq’s highest court—upholding the CMC’s 25 decision to exclude Alfa from bidding on the CMC Project. See id.; see also Opp’n to Alfa MIL 26 1, at 2, ECF No. 121. 27 Alfa argues that the Court should exclude evidence related to the Iraqi proceedings on the 1 probative value of the evidence is substantially outweighed by the dangers of unfair prejudice to 2 Alfa, confusing the issues, and wasting time, see id. at Rule 403; and that any Iraqi court orders, 3 findings, and judgments constitute inadmissible hearsay, see id. at Rule 802. See Alfa MIL 1, at 4 3–5. TCI counters that evidence of Alfa’s formal objection to the CMC and its unsuccessful 5 litigation against the CMC in Iraq—including the Iraqi courts’ judgments upholding the CMC’s 6 decision to exclude Alfa—is relevant to the issues of causation and damages; that any prejudicial 7 effect can be reasonably mitigated by the Court; and that the evidence is admissible for the non- 8 hearsay purpose of establishing the legal effect of the Iraqi judgments on Alfa’s disqualification 9 from the 2018 CMC Project and Alfa’s legal status with the CMC. See Opp’n to Alfa MIL 1, at 10 2–5. The chief item of discussion during oral argument on this motion in limine was the 11 admissibility of the Iraqi courts’ judgments against Alfa in the Iraqi litigation. 12 1. Relevance 13 As the Court stated during the parties’ oral argument on this motion, the legal effect of the 14 Iraqi courts’ judgments on Alfa’s ability to be considered as a bidder for the 2018 CMC Project is 15 highly relevant to the elements of causation and damages. “Evidence is relevant if: (a) it has any 16 tendency to make a fact more or less probable than it would be without the evidence; and (b) the 17 fact is of consequence in determining the action.” Fed. R. Evid. 401. The CMC’s decision to 18 disqualify Alfa from the 2018 CMC Project—as upheld by the Iraqi courts—is evidence of an 19 intervening causal event, and is therefore relevant under Rule 401. See Daubert v. Merrell Dow 20 Pharms., Inc., 509 U.S. 579, 587 (1993) (noting Rule 401’s “liberal” standard for relevance). 21 2. Hearsay 22 The Court agrees with Alfa that any discussion of the facts and reasoning supporting the 23 Iraqi courts’ judgment constitutes inadmissible hearsay. See United States v. Sine, 493 F.3d 1021, 24 1036 (9th Cir. 2017) (“A court judgment is hearsay ‘to the extent that it is offered to prove the 25 truth of the matters asserted in the judgment.’”) (quoting United States v. Boulware, 384 F.3d 794, 26 806 (9th Cir. 2004)). However, TCI asserts that it does not seek to offer the Iraqi judgments for 27 the truth of the matters asserted therein, but rather to establish the legal effect of the judgments. 1 the matters asserted within, is not hearsay. See Fed. R. Evid. 801(c)(2). 2 3. Rule 403 Balancing 3 The Court agrees with Alfa that the Iraqi judgments themselves, if admitted, would be 4 unfairly prejudicial, likely to confuse the jury, and a waste of time, such that these dangers would 5 substantially outweigh the probative value of the judgments. See Fed. R. Evid. 403. The 6 judgments are multi-page documents containing facts and reasoning that the jury might consider 7 for their truth as evidence in the present case, in spite of any limiting instruction the Court might 8 provide. See, e.g., Grace v. Apple, Inc., No. 17-cv-00551, 2020 WL 227404, at *2 (N.D. Cal. Jan. 9 15, 2020) (“Indeed, a ‘jury is likely to give a prior verdict against the same defendant more weight 10 than it warrants. The admission of a prior verdict creates the possibility that the jury will defer to 11 the earlier result and thus will, effectively, decide a case on evidence not before it.’”) (citation 12 omitted). However, evidence of the mere fact of the existence of the Iraqi judgments upholding 13 the CMC’s decision to disqualify Alfa from bidding on the 2018 CMC Project is not of the sort 14 that might play on a juror’s sympathies or inflame any passions, confuse the issues, waste time, or 15 otherwise tend to have an adverse effect on Alfa beyond tending to prove facts relevant to the 16 issues of causation and damages. See, e.g., In re Pac. Fertility Ctr. Litig., No. __, 2021 WL 17 1054374, at *5 (N.D. Cal. Mar. 19, 2021) (“[T]hat evidence is potentially damaging is not itself a 18 basis to exclude it. Under Federal Rule of Evidence 403, the test is whether it is more prejudicial 19 than probative.”) (citations omitted). 20 4. Conclusion 21 Based on the reasoning above, the Court will grant in part and deny in part Alfa’s motion 22 in limine to exclude evidence of proceedings it instituted in Iraq related to the CMC’s award of the 23 2018 CMC Project to AZG. Evidence of the existence of the Iraqi judgments—and potentially the 24 face pages of the judgment documents, depending on their contents—will not be excluded; i.e., the 25 Court will deny the motion with respect to the judgment itself. The Court will otherwise grant the 26 motion, so that evidence consisting of the text of the Iraqi judgments, for example, will be 27 excluded. The Court urges the parties to meet and confer and add a stipulated fact regarding this 1 ameliorate any remaining concerns regarding prejudice. 3 TCI filed three motions in limine. See ECF Nos. 109, 110, 112. Alfa opposed all three 4 motions. See ECF Nos. 116–18. The Court considers each of TCI’s motions in turn. 5 A. TCI’s Motion in Limine No. 1 to Exclude Evidence Concerning Alleged Unlawful Influence 6 In its first motion in limine, TCI moves to exclude certain exhibits included on Alfa’s 7 exhibit list—namely, Exhibits 30–32, 34–37, 39–40, 42–43, 45–47, 83–86, 95, 98, and 135—that 8 TCI asserts will be offered in support of the position that TCI and/or AZG allegedly engaged in 9 unlawful influence of the CMC, received confidential information from the CMC, or otherwise 10 engaged in improper conduct to cause Alfa’s disqualification or elimination from the 2018 CMC 11 Project or overall blacklisting. See TCI MIL 1, at 1, ECF No. 109; Decl. of Gregory C. Ulmer ¶ 2, 12 ECF No. 109-1.

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