Burlington School District v. Monsanto Co.

CourtDistrict Court, D. Vermont
DecidedMay 17, 2024
Docket2:22-cv-00215
StatusUnknown

This text of Burlington School District v. Monsanto Co. (Burlington School District v. Monsanto Co.) is published on Counsel Stack Legal Research, covering District Court, D. Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Burlington School District v. Monsanto Co., (D. Vt. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF VERMONT

BURLINGTON SCHOOL DISTRICT, ) ) Plaintiff, ) ) v. ) Case No. 2:22-cv-215 ) MONSANTO CO., SOLUTIA, INC., ) and PHARMACIA LLC, ) ) Defendants. )

OPINION AND ORDER

The Burlington School District (“BSD”) commenced this action after discovering polychlorinated biphenyls (“PCBs”) at Burlington High School. Defendants Monsanto Co., Solutia, Inc., and Pharmacia LLC are allegedly successors to the old Monsanto company, which was the primary manufacturer of PCBs in the United States for several decades, including when Burlington High School was built. The Complaint alleges that Monsanto failed to alert BSD to the dangers posed by the presence of PCBs in school buildings, testing revealed dangerous levels of PCBs on the school campus, and Defendants are now liable for the cost of razing and rebuilding the school. Pending before the Court are Pharmacia’s motions to quash portions of BSD’s Rule 30(b)(6) notice and for a protective order with respect to certain topics set forth in the notice. For the reasons set forth below, the motions are granted in part and denied in part. Background BSD has noticed the deposition of Pharmacia’s Rule 30(b)(6) representative. Attached to the notice is a list of 32 topics

that BSD expects the deponent to address. Pharmacia’s motion to quash asserts both general and specific objections to those anticipated topics. Pharmacia objects generally to any questioning that goes beyond its knowledge of Monsanto’s manufacture, distribution, and sale of PCBs from 1935 to 1977. Pharmacia submits that Monsanto ceased manufacturing PCBs in 1977, and that any knowledge or communications since that time are irrelevant to BSD’s claim that Monsanto caused PCBs to be incorporated into Burlington High School in the 1960s. Pharmacia also objects to questioning regarding its “present-day” knowledge of PCB issues at Burlington High School, arguing that disclosing such

“present-day” knowledge would require it to prematurely reveal expert opinions and/or delve into its litigation work product. Pharmacia further asks the Court to strike BSD’s requests for information about its communications with Pfizer, Inc., Bayer AG, Monsanto Company, Eastman Chemical Co. and/or Solutia. Each of those companies bears a corporate relationship to the former Monsanto. Pharmacia argues that BSD’s proposal “ignores” expert disclosure rules and may also invade Pharmacia’s privileged communications, work product privileges, and protections under the common interest doctrine. Finally, Pharmacia objects to BSD’s proposed questions

about the retention of lobbyists, former employees, scientists, or other consultants concerning the portrayal of PCBs to the media, public, or any regulator. Pharmacia contends that any such persons were retained for the purpose of responding to PCB litigation or in anticipation of litigation, and that BSD is not entitled to premature disclosure of either its testifying experts or its consulting experts. BSD opposes Pharmacia’s motions, arguing that its proposed topics are appropriate and lawful. With respect to Pharmacia’s request to limit the inquiry to the period between 1935 and 1977, BSD notes that Pharmacia disputes whether, under today’s understanding of the science, the PCB levels at Burlington High

School pose a public health threat. With regard to lobbyists, scientists, or other consultants, BSD alleges that those persons were retained to lobby Congress for liability protection and were not hired in anticipation of litigation as contemplated by the Federal Rules of Civil Procedure. Finally, particularly with respect to privilege, BSD submits that appropriate objections may be made at the time of the deposition, including instructing the witness not to answer the question, and that the witness can decline to answer questions if, for example, the question seeks knowledge that is held exclusively by a retained expert. The Court addresses these various arguments in more detail below.

Discussion I. Request for a Temporal Restriction Several of Pharmacia’s objections, particularly with regard to temporal restrictions, argue that information beyond a certain time period is irrelevant. “Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). Information “is relevant if: ‘(a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the action.’” Vaigasi v. Solow Mgmt. Corp., No. 11-CV-5088, 2016 WL 616386, at *11 (S.D.N.Y.

Feb. 16, 2016) (quoting Fed. R. Evid. 401). “The party seeking the discovery must make a prima facie showing that the discovery sought is more than merely a fishing expedition.” Evans v. Calise, No. 92-CV-8430, 1994 WL 185696, at *1 (S.D.N.Y. May 12, 1994); see also Mandell v. The Maxon Co., Inc., No. 06-CV-460, 2007 WL 3022552, at *1 (S.D.N.Y. Oct. 16, 2007) (“[T]he party seeking discovery bears the burden of initially showing relevance.”). In the discovery phase of a case, the concept of relevance is “liberally construed.” Daval Steel Prods. v. M/V Fakredine, 951 F.2d 1357, 1367 (2d Cir. 1991) (citing Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978)). Pharmacia asks the Court to limit the Rule 30(b)(6)

deposition to the company’s understanding about PCBs between 1935 and 1977. BSD submits the Pharmacia’s current understanding of the impacts of PCBs is relevant given apparent disputes about screening methods and toxicity levels. In its reply, Pharmacia agrees that its “position on current PCB science is relevant and discoverable,” but objects that such issues are more appropriately presented to an expert witness: “Questions about a chemical’s toxicity – and its effects at a particular property — are expert questions and should be addressed by experts.” ECF No. 77 at 2. Pursuant to Rule 30(b)(6), a party may name a corporation as a deponent and describe with reasonable particularity the

matters on which that party wishes the corporation to testify. Fed. R. Civ. P. 30(b)(6). A corporation receiving such a notice must designate a person or persons to testify on its behalf, and the persons so designated must “testify as to matters known or reasonably available” to the corporation. Id.; Eid v. Koninklijke Luchtvaart Maatschappij N.V., 310 F.R.D. 226, 229 (S.D.N.Y. 2015) (“Rule 30(b)(6) witnesses are expected to prepare by gathering corporate knowledge.”). “[I]n testifying as to matters within [a company’s] corporate knowledge ..., [a Rule 30(b)(6) deponent] cannot make comments that would otherwise require expert qualifications.” Brazos River Auth. v. GE Ionics. Inc., 469 F.3d 416, 434-35 (5th Cir. 2006).

The Court agrees with Pharmacia that the Rule 30(b)(6) witness need not be prepared to testify about current scientific understandings about PCB volatility, toxicity, and the like, insofar as that information will be explained by experts. The motions to quash and for a protective order on that issue are therefore granted. With respect to the more general issue of temporal limitation, the Court will not bar questions pertaining to matters within the corporation’s knowledge after 1977.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Brazos River Authority v. GE Ionics, Inc.
469 F.3d 416 (Fifth Circuit, 2006)
Oppenheimer Fund, Inc. v. Sanders
437 U.S. 340 (Supreme Court, 1978)
United States v. Martin Schwimmer
892 F.2d 237 (Second Circuit, 1989)
Eid v. Koninklijke Luchtvaart Maatschappij N.V.
310 F.R.D. 226 (S.D. New York, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Burlington School District v. Monsanto Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/burlington-school-district-v-monsanto-co-vtd-2024.