Brower v. McDonald's Corporation

CourtDistrict Court, D. Nevada
DecidedNovember 16, 2021
Docket2:19-cv-02099
StatusUnknown

This text of Brower v. McDonald's Corporation (Brower v. McDonald's Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brower v. McDonald's Corporation, (D. Nev. 2021).

Opinion

4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * * 7 Donna Brower, Case No. 2:19-cv-02099-GMN-BNW 8 Plaintiff, 9 ORDER v. 10 McDonald’s Corporation, 11 Defendant. 12 13 Before the Court are two motions. First, Plaintiff filed a motion to compel a Rule 30(b)(6) 14 deposition and to request sanctions. ECF No. 54. Defendant opposed the motion at ECF No. 57 15 (which is sealed), and Plaintiff replied at ECF No. 62. Next, Defendant filed a motion to seal. 16 ECF No. 56. Plaintiff opposed this motion. ECF No. 61. Defendant replied. ECF No. 63. 17 I. Motion to Compel and Request for Sanctions 18 In Plaintiff’s complaint, she accuses McDonald’s of violating state and federal workplace 19 protection laws. 20 Plaintiff deposed a Rule 30(b)(6) witness, Mr. Smith. Plaintiff argues that Mr. Smith was 21 unable to fully respond to Topic No. 1. Specifically, Plaintiff contends that Mr. Smith could not 22 (1) provide the date the decision was made to eliminate the McOpCo Operations Consultant 23 position, (2) identify the persons who made the decision, and (3) provide the effective date by 24 which the position had to be eliminated. Instead, Plaintiff argues that Mr. Smith provided a time 25 frame as to when the decision was made, provided vague references as to the persons responsible 26 for making the decision, and had no information as to the date by which the position had to be 27 1 eliminated. Plaintiff argues that Mr. Smith should have been better prepared, reviewed documents 2 in preparation for the deposition, and talked to relevant individuals. 3 Plaintiff also requests that defense counsel be precluded from lodging an attorney-client 4 privilege objection (at any future deposition) when she asks Mr. Smith about his discussions with 5 Mr. De La Cruz. 6 Accordingly, Plaintiff requests that Mr. Smith be compelled to answer these questions and 7 for Defendant to be sanctioned under Fed. R. Civ. P. 37(a), including by having the Court award 8 costs and fees for the one-hour deposition, bringing this motion, the deposition transcript, and all 9 expenses connected to the new Rule 30(b)(6) deposition. To the extent Defendant asserts it does 10 not have this information, Plaintiff requests an adverse inference instruction be read to the jury as 11 a sanction for spoliation. 12 Defendant responds by stating that it has complied with its obligations under Fed. R. Civ. 13 P. 30(b)(6) by having two different witnesses answer questions related to Topic No. 1. Specifically, 14 Mr. Smith testified to the date the decision was made to eliminate the position (July 2018) and the 15 persons who made the decision (McDonald’s leadership team). As to the persons that made the 16 decision, Defendant argues that Topic No. 1 did not request a list of natural persons who may have 17 been responsible for the decision. In addition, Defendant argues that Mr. De La Cruz testified as to 18 the date by which the position had to be eliminated (August 15, 2018). As such, Defendant 19 represents it has provided all the information it has relating to the topic, including all documents. 20 Thus, Defendant requests that the motion be denied in its entirety. 21 Plaintiff replies by reiterating many of the arguments made in her moving papers and 22 expanding on the need for an adverse inference instruction due to spoliation. 23 A. Analysis 24 Federal Rule of Civil Procedure 30(b)(6) imposes burdens on both the discovering party 25 and the designating party. The party seeking discovery through a Rule 30(b)(6) deposition is 26 required to describe “with reasonable particularity the matters on which examination is 27 requested.” Fed. R. Civ. P. 30(b)(6). Once served with the deposition notice under Rule 30(b)(6), 1 subject matter of the noticed topics. Marker v. Union Fid. Life Ins. Co., 125 F.R.D. 121 2 (M.D.N.C. 1989). The testimony of a Rule 30(b)(6) designee “represents the knowledge of the 3 corporation, not of the individual deponents.” United States v. Taylor, 166 F.R.D. 356, 361 4 (M.D.N.C. 1996). A Rule 30(b)(6) designee is not required to have personal knowledge on the 5 designated subject matter. Sprint Commc’ns Co., L.P. v. Theglobe.com, Inc., 236 F.R.D. 524, 528 6 (D. Kan. 2006). The duty to produce a prepared witness on designated topics extends to matters 7 not only within the personal knowledge of the witness but on matters reasonably known by the 8 responding party. Alexander v. F.B.I., 186 F.R.D. 137, 141 (D.D.C. 1998). But “Rule 30(b)(6) 9 need not be subjected to a ‘memory contest.’” Id. at 143. 10 Topic No. 1 seeks “[t]he date, effective date and who made the decision to cut a McOpCo 11 Operations Consultant position in Las Vegas in 2018.” Here, Plaintiff agrees that both Mr. Smith 12 and Mr. De La Cruz were designated as Rule 30(b)(6) witnesses to provide answers to Topic No. 13 1. Thus whether Mr. Smith himself was able to answer all the questions is not the proper 14 question; the question is whether Mr. Smith and Mr. De La Cruz were properly prepared to 15 provide answers to Topic No. 1. The Court finds that between the two witnesses, proper 16 responses were provided as to Topic No. 1. 17 As to the date Defendant decided to eliminate the position, Mr. De La Cruz testified it was 18 “mid-July . . . maybe the 16th of July . . . .” ECF No. 57-1 at 47-48. Mr. Smith testified that the 19 decision to eliminate the position was not made at “the year-end 2007” meeting or at the end of 20 April 2018. ECF 57-2 at 14. He stated “July would be about the time that that decision would 21 have been made. It makes sense that the decision would have been made in July.” Id. at 14-15. He 22 did not know the specific date. Id. at 15. Between these two witnesses, they properly answered 23 the first part of the question in Topic No. 1. 24 As to the date on which the decision became effective, Mr. De La Cruz testified that the 25 position had to be eliminated by August 15th. Id. at 155. Mr. De La Cruz properly answered this 26 part of Topic No. 1. 27 As to those responsible for making the decision, Mr. Smith testified that “there’s no 1 When asked who comprised the team, he stated “Palo . . . the finance people . . . Laura 2 Granger . . . .” Id. at 27. He did not know Palo’s last name but explained he was the president of 3 McOpCo, could not recall the names of the people in finance who would made this decision, and 4 explained that Laura Granger was the HR Director. Id. at 28. The Court understands this is not the 5 answer that Plaintiff sought and that this information does not get to the heart of the question— 6 who are the individuals responsible for making this decision.1 But counsel for Defendant 7 represents she has spoken to Mr. Pena, Ms. Granger, and others who do not have a specific 8 memory regarding the reduction. In addition, counsel for Defendant represents that all documents 9 on this matter have been produced and that no other witness has any additional information about 10 this topic. The Court agrees with Defendant’s proposition that it cannot produce or testify to 11 information it does not have. 12 In addition, while the Court agrees that the Rule 30(b)(6) witnesses should review 13 documents as part of their preparation, as Plaintiff argues, Defendant represents there are no other 14 documents to review on this topic and that she has spoken to those who may have had additional 15 information to provide. Thus, while Mr. Smith should have reviewed all documents prior to 16 testifying, it would not have made a difference in this case.

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Brower v. McDonald's Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brower-v-mcdonalds-corporation-nvd-2021.