Bradley v. Evanston Insurance Company

District Court, E.D. Louisiana·Decided February 11, 2025·No. 2:24-cv-00361·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

IVANOLA BRADLEY CIVIL ACTION VERSUS NO: 24-361 EVANSTON INSURANCE COMPANY SECTION: “R” (4) ORDER Before the Court is Plaintiff’s Motion for Protective Order and Motion to Quash (R. Doc. 36), seeking to quash three subpoenas to Plaintiff’s witnesses. Plaintiff also seeks a protective order staying further discovery and prohibiting the Defendant’s depositions of the Plaintiff and three witnesses. R. Doc. 36 at 1. The Motion is opposed. R. Doc. 40. The Motion was heard on February 5, 2025. I. Background A. Factual Background This litigation arises from property damage at 468 Jackson Avenue, New Orleans LA (“Property”) that was allegedly sustained on August 29, 2021, due to Hurricane Ida. R. Doc. 1-1 at 5. Plaintiff Ivanola Bradley (“Plaintiff”) had an insurance policy with Defendant Evanston Insurance Company (“Defendant”). R. Doc. 1 at 6. Although she filed a claim for the storm loss, Plaintiff alleges that the carrier failed to tender sufficient funds to cover the repair costs. R. Doc. 1-1 at 6. Plaintiff originally filed this lawsuit in state court, raising claims for breach of contract and bad faith. R. Doc. 1 at 8. Defendant removed the case based on diversity and asserts that Plaintiff is not an insured under the Policy and therefore has no right of action. Id. at 1. R. Doc. 9 at 4. The Defendant concedes that the Policy has been renewed several years after the original insured, Edmond Comeaux, died in 2016. Id. On July 17, 2024, the Court granted Defendant’s Motion to Opt Out of the Court’s Hurricane Ida Case Management Order, finding that the issue of whether Plaintiff’s claims are futile should be resolved before proceeding with the next phase of the Court’s Streamlined Settlement Program. R. Doc. 20 at 4.

B. Subject Motion The subject Motion seeks to quash Defendant’s subpoenas for records issued to her independent public adjuster, her engineering expert, and her insurance agent. R. Doc. 36-1 at 1-2. Plaintiff also seeks a protective order to stay discovery and prevent the depositions of these witnesses and herself. Id. at 2, 8. Plaintiff contends that Defendant strategically delayed discovery until the last minute, and that the subpoenas and depositions at issue are costly and not appropriate under the CMO. Id. Plaintiff also contends that her deposition poses an undue burden because it would require her to travel from her home in Lake Charles to be deposed in New Orleans, even though the insured Property is in New Orleans. Id. Defendant opposes the Motion, contending that Plaintiff has not provided any legal

grounds to quash or modify the subpoenas because they are narrowly tailored, relevant, and necessary for Defendant to pursue its claims and defenses in this matter. R. Doc. 40 at 4. Defendant further contends that she has not provided any “particular and specific demonstration of fact” that should prevent them from deposing the Plaintiff or her trial witnesses. Id. Defendant also alleges that Plaintiff identified the witnesses at issue in her January 9, 2025, discovery responses, and that Defendant is entitled to conduct discovery into their investigations, knowledge, and opinions in this matter. Id. at 3-4. II. Standard of Review Federal Rule of Civil Procedure 26(b)(1) sets the scope of discovery to include “any non- privileged matter that is relevant to any party’s claim or defense[.]” FED. R. CIV. P. 26(b)(1). Rule 26(b)(1) further specifies that “[i]nformation within this scope of discovery need not be admissible

in evidence to be discovered.” Id. Rule 26(b)(1) also specifies that discovery must be “proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Id. Federal Rules of Civil Procedure Rule 45 governs the procedure for obtaining discovery from non-parties. Under Rule 45, a non-party served with a subpoena duces tecum may object by sending written objections to the issuing party by the earlier of fourteen days from service or fourteen days before the return date. Fed. R. Civ. P. 45(d)(2)(B). Subsequently, “[o]n timely motion, the court for the district where compliance is required must quash or modify a subpoena

that fails to allow a reasonable time to comply…or subjects a person to undue burden.” Fed. R. Civ. P. 45(d)(3)(A). Federal Rules of Civil Procedure Rule 26(c) gives the Court broad authority and discretion to determine when and to what degree to which a protective order is warranted. FED. R. CIV. P. 26(c). Seattle Times Co. v. Rinehart, 467 U.S. 20, 36 (1984) (“the unique character of the discovery process requires that the trial court have substantial latitude to fashion protective orders”). In re Leblanc, 559 Fed. Appx. 389, 392- 93 (5th Cir. 2014). Rule 26(c) further provides that “the court may for good cause, issue and order to protect a party or person from annoyance embarrassment, oppression or undue burden or expense. FED. R. CIV. P. 26(c). On the merits and scope of the protective order, the burden is upon the movant to show the necessity of a protective order. In re Terra, 134 F.3d 302, 306 (5th Cir. 1988). To show this necessity, the movant must lay out a “particular and specific demonstration of fact” rather than “stereotype and conclusory statements.” David v. Signal Int’l LLC, No. 08-cv-1220, 2014 WL

2581319, at *1 (E.D. La May 14, 2014) (Morgan, S.). Furthermore, “the alleged harm must be significant, not a mere trifle.” David, No. 08-1220 at *1. III. Analysis A. Motion for Protective Order Plaintiff seeks a Protective Order to stay discovery and prevent the Defendant from deposing her independent adjuster, engineering expert, insurance agent, and herself. R. Doc. 36-1 at 8-9. Plaintiff contends that the depositions are not appropriate because Defendant has delayed its discovery efforts to the last minute. Id. Plaintiff further contends that additional discovery would be costly and is not appropriate under the Court’s CMO, which stays all discovery except the limited expedited discovery described in the Court’s order. Id. See R. Doc. 3 at 3. Plaintiff also

contends that she would have to travel from her home in Lake Charles to be deposed in New Orleans, which poses a significant burden on her. R. Doc. 36 at 8. Therefore, Plaintiff requests that the Court prevent the Defendant’s depositions and order the parties to return to the CMO. Id. Defendant contends that it has complied with the Court’s Scheduling Order, and that Plaintiff has failed to show good cause for a protective order prohibiting its requested discovery in this matter. R. Doc. 40. Defendant also notes that Plaintiff did not make any timely request for the Court to reconsider its Order on Defendant’s Motion to Opt Out and agreed to the deadlines in this matter at a Scheduling Conference with the Court on September 5, 2024. Id. at 2. Defendant further contends that Plaintiff is seeking to use a three-hour commute as grounds from preventing Defendant from deposing her at all. R. Doc.

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