Aumann Auctions Inc v. Fletcher

CourtDistrict Court, C.D. Illinois
DecidedFebruary 12, 2021
Docket3:17-cv-03156
StatusUnknown

This text of Aumann Auctions Inc v. Fletcher (Aumann Auctions Inc v. Fletcher) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aumann Auctions Inc v. Fletcher, (C.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS, SPRINGFIELD DIVISION

AUMANN AUCTIONS, INC., ) ) Plaintiff, ) ) v. ) Case No. 17-cv-3156 ) CONRAD FLETCHER, ) ) Defendant. )

OPINION TOM SCHANZLE-HASKINS, U.S. MAGISTRATE JUDGE: This matter comes before the Court on Defendant Conrad Fletcher’s Motion to Bar Opinion Testimony (d/e 54) (Motion). For the reasons set forth below, the Motion is ALLOWED. BACKGROUND This is a breach of contract case. Plaintiff Aumann Auctions, Inc. (the Company) alleges that Defendant Conrad Fletcher breached a contract to authorize the Company to sell certain items at auction, including antique automobiles. As set forth in more detail in this Court’s Opinion ruling on Fletcher’s Motion for Summary Judgment (d/e 53) (Summary Judgment Opinion), Fletcher owned a large collection of antique automobiles, tractors, automotive and road related signs, and other memorabilia (the Collection). Fletcher kept most of the Collection in two large outbuildings at his residence in Golden, Colorado (Residence). Some of his antique

automobiles in the Collection were in Arizona. In late spring or early winter 2016, Fletcher decided to move to Arizona. In January 2017, Fletcher decided to conduct an auction to sell some or all of his personal property,

including items in the Collection, before he moved to Arizona. See Summary Judgment Opinion), at 1-3. Fletcher selected the Company as a possible auctioneer to conduct the proposed auction. Kurt Aumann is the principle of the Company. The

Company is his family’s auction business and Aumann has worked for the Company for 58 years and has run the Company for 15 years. He has conducted over 100 antique automobile auctions in the past ten years. See

Motion for Summary Judgment (d/e 53), Exhibit 4, Deposition of Kurt Aumann (Aumann Deposition), at 4-5. On March 30, 2017, Aumann went to the Residence and conducted a walkthrough of the two large outbuildings to see the Collection. Aumann

made some handwritten notes listing certain items as he went through the outbuildings (List). He also took some photographs. He did not inspect any item in detail, and he did not make a detailed inventory of the items

that would be sold at auction. Additionally, he did not inspect any of the items to determine whether they were operational. He anticipated that a crew from the Company would come back at a later date to catalogue the

items to be sold at auction. See Summary Judgment Opinion, at 4-5. In May 2017, Fletcher canceled the planned visit by the Company’s crew to catalogue the items for the auction.

On June 8, 2017, Fletcher canceled the Auction. On that date Fletcher signed an agreement with a company called Maddogs Performance (Maddogs) to sell eight antique automobiles on consignment (Maddogs Contract). The Maddogs Contract listed the prices for the sale of

each automobile. Fletcher set those prices and the listed prices totaled $1,063,000.00. Maddogs did not sell any of the automobiles placed on consignment under the Maddogs Contract. All of the automobiles were

returned to Fletcher. See Summary Judgment Opinion, at 6-13. The Company then filed this action for breach of contract. This Court initially directed the parties to disclose expert witnesses by May 19, 2019. Scheduling Order entered September 24, 2018 (d/e 17) ¶ 3.

The Court subsequently extended the Company’s deadline to disclose expert witnesses to September 3, 2020 and Fletcher’s deadline to October 5, 2020. Text Order entered April 3, 2020. The Company did not disclose

any expert witnesses by September 3, 2020. On October 5, 2020, Fletcher disclosed his expert witnesses. The next day, on October 6, 2020, the Company served an untimely expert witness disclosure. The Company

disclosed its principle Aumann as an expert on the value of the automobiles and other items that were allegedly to be sold at auction under the parties’ contract. Fletcher had previously deposed Aumann as a fact witness on

July 8, 2020. ANALYSIS Fletcher moves to bar Aumann from providing expert testimony because his disclosure was untimely and because his opinions should be

barred under Daubert v. Merrill Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). The Company’s disclosure of Aumann as an expert witness was

untimely. The Company may only use Aumann as an expert witness if it can demonstrate that the failure to disclose Aumann in a timely manner was substantially justified or harmless. Fed. R. Civ. P. 37(c)(1); Musser v. Gentiva Health Services, 356 F.3d 751, 758 (7th Cir. 2004) (exclusion is

automatic and mandatory unless tardy party shows the late disclosure was justified or harmless). The Company offers no justification for its late disclosure other than counsel mistakenly believed the disclosures were due on a date later than September 3, 2020. The Company, therefore, must show that the late disclosure was harmless.

In assessing the harm caused by untimely disclosure, this Court considers: (1) the prejudice or surprise to the party against whom the evidence is offered; (2) the ability of the party to cure the prejudice; (3) the

likelihood of disruption to the trial; and (4) the bad faith or willfulness involved in not disclosing the evidence at an earlier date. Westefer v. Snyder, 422 F.3d 570, 584 n.21 (7th Cir. 2005). The one-month delay in disclosure would cause prejudice to Fletcher. If Aumann is allowed to

testify as an expert witness, Fletcher must take Aumann’s deposition again, Fletcher must be allowed time to disclose a rebuttal expert, and Fletcher must pay the additional expense of retaining a rebuttal expert.

In addition, the trial would likely be delayed if Aumann offered expert opinion testimony. The parties must file motions in limine by April 19, 2021, 15 days before the final pretrial conference set for May 4, 2021. Scheduling Order entered September 24, 2018 (d/e 17) ¶ 8; Minute Entry

entered April 3, 2020. Fletcher would need to depose Aumann to discover Aumann’s expert opinions and find a rebuttal expert; the expert would need time to prepare a rebuttal report; and Aumann would need to depose the

rebuttal expert. The parties would not be likely to complete all these tasks in time to prepare and file motions in limine regarding Aumann’s expert opinions by April 19, 2021, and so, the trial would likely be delayed. This

case was filed in 2017. The Court finds that the untimely disclosure of Aumann was not harmless. Aumann argues his Rule 26(a)(1) Initial Disclosures stated Aumann

would testify about, among other facts, “damages sustained as a result of Defendant’s breach”. This reference to “damages” in the Rule 26(a)(1) Initial Disclosures is not a sufficient disclosure for expert testimony. Rule 26(a)(2) contains the requirement for disclosure of expert testimony. Rule

26(a)(2)(A) states that in addition to the disclosures in Rule 26(a)(1), a party must disclose the identity of any witness it may use at trial to present expert testimony under Rules 702, 703, or 705 of the Federal Rules of

Evidence. For an expert witness not required to file a written report, the expert disclosures must include a summary of the subject matter on which the expert is expected to present expert testimony and a summary of the facts and opinions on which the witness is expected to testify. Rule

26(a)(2)(A) and (C).

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