EFN West Palm Motor Sales, LLC v. Hyundai Motor America

District Court, S.D. Florida·Decided August 15, 2022·No. 9:21-cv-80348·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 21-80348-Civ-CANNON/MATTHEWMAN

EFN WEST PALM MOTOR SALES, LLC d/b/a NAPLETON’S WEST PALM BEACH HYUNDAI, et al.,

Plaintiffs,

vs.

HYUNDAI MOTOR AMERICA CORPORATION,

Defendant. /

ORDER GRANTING HMA’S MOTION FOR LEAVE TO SERVE SUPPLEMENT TO EXPERT REPORT OF JIM SMITH, P.E. [DE 196]

THIS CAUSE is before the Court upon Defendant, Hyundai Motor America Corporation’s (“HMA”) Motion for Leave to Serve Supplement to Expert Report of Jim Smith, P.E. (“Motion”) [DE 196]. This matter was referred to the Undersigned by the Honorable Aileen M. Cannon, United States District Judge. [DEs 19, 42, 43]. Plaintiffs, EFN West Palm Motor Sales, LLC d/b/a Napleton’s West Palm Beach Hyundai and North Palm Hyundai, LLC d/b/a Napleton’s North Palm Hyundai (collectively, “Plaintiffs”), have filed a response [DE 200], and HMA has filed a reply [DE 213]. The Court heard oral argument on the Motion at a hearing held via Zoom VTC on August 11, 2022. I. Background HMA is seeking leave to supplement the expert report of Jim Smith, P.E., which was served on March 11, 2022, “simply to include Mr. Smith’s further analysis of previously produced data in support of his previously disclosed opinions.” [DE 196 at 1]. HMA argues that the 17 additional pages, consisting largely of charts, contained in the supplement do not change Smith’s previously disclosed opinion; rather, the “additional analysis of the recall claim data reflected in the charts simply further supports Mr. Smith’s original opinion.” Id. at 2, 4. Smith has not yet been deposed, and his deposition is set for August 17, 2022. Id. HMA has also agreed to reschedule the deposition

of Plaintiffs’ expert until after Smith’s deposition. Id. Thus, according to HMA, granting the Motion would not prejudice Plaintiffs. Id. at 3. HMA next contends that, even if Rule 26(e)(2) does not apply here, Rule 37 permits a party to use information that was not disclosed by the expert disclosure deadline if the failure to disclose said information was substantially justified or harmless. Id. at 3. In response, Plaintiffs explain that all expert reports were to be filed by March 11, 2022. [DE 200 at 2]. On June 30, 2022, HMA provided Plaintiffs with an 80-page report that contained an additional 18 pages of material and “added damages calculations that were not present in the original report. The two new findings relate to the amount of damages suffered by HMA, an opinion that was not included in the original report.” Id. Plaintiffs assert that HMA’s attempt to

supplement the expert report in “no way complies” with Rule 26(e)(2) because HMA has not shown that the original report was incomplete or incorrect, that the information was not otherwise known, and that it would not prejudice Plaintiffs. Id. at 3–4. Plaintiffs also contend that Rule 37 does not permit untimely supplementation that is not otherwise permissible under Rule 26. Id. at 4. Plaintiffs maintain that HMA has not established that the failure to disclose was substantially justified or harmless. Id. at 5. Finally, Plaintiffs explain that their rebuttal expert, Mr. Lange, is an engineer, not a statistician or a valuation expert. Id. at 6. According to Plaintiffs, when selecting their rebuttal expert to Smith, Plaintiffs were not on notice that this sort of rebuttal would be necessary and “it is too late in the game for the Plaintiffs to attempt to run down the basis for these figures and try to get an expert to rebut them.” Id. In reply, HMA explains that the “supplement to Mr. Smith’s report (found at pages 53-70) uses the same previously produced recall claim data to further illustrate (primarily in chart form)

that EFN’s recall claims are much higher than the rates of other dealers.” [DE 213 at 2]. HMA asserts that “Smith’s opinion—both as to the fraud and the magnitude of the fraud—is critical to HMA’s defense of its terminations.” Id. at 3. HMA also emphasizes that the “additional analysis of the recall claim data in Mr. Smith’s supplemental report is simply additional support for his opinion that the recall claim data evidences EFN’s large-scale fraud.” Id. Next, HMA points out that Smith’s original report also “contained comparisons of EFN’s engine replacements and seized engine replacements to the engine replacements and seized engine replacements of other dealers nationally and in Florida,” Plaintiffs chose not to hire a statistician at that time, and Smith himself is not a statistician. Id. HMA additionally argues that there is no real prejudice to Plaintiffs here given the deadlines in this case and the fact that Smith has not yet been deposed. Id. at 4.

II. Applicable Law Federal Rule of Civil Procedure 26(a) requires experts to disclose a written report containing “a complete statement of all opinions [they] will express and the basis and reasons for them.” Fed. R. Civ. P 26(a)(2)(B)(i). “Because the expert witness discovery rules are designed to allow both sides in a case to prepare their cases adequately and to prevent surprise . . . compliance with the requirements of Rule 26 is not merely aspirational.” Cooper v. S. Co., 390 F.3d 695, 728 (11th Cir. 2004) (internal citations omitted). Federal Rule of Civil Procedure 37(c)(1) instructs that where “a party fails to provide information . . . as required by Rule 26(a) or (e), the party is not allowed to use that information or witness . . . unless the failure was substantially justified or harmless.” See, e.g., Potish v. R.J. Reynolds Tobacco Co., 15-cv-81171, 2017 WL 5952892, at *2– 4 (S.D. Fla. Nov. 30, 2017); Managed Care Sols., Inc. v. Essent Healthcare, Inc., 09-cv-60351, 2010 WL 1837724, at *3 (S.D. Fla. May 3, 2010). Courts have broad discretion to exclude untimely-disclosed expert reports, even ones

designated as “supplemental” reports. Id.; see also, e.g., Cook v. Royal Caribbean Cruises, No. 11-cv-20732, 2012 WL 2319089 (S.D. Fla. June 15, 2012); Goodbys Creek, LLC v. Arch Ins. Co., No. 07-cv-0947, 2009 WL 1139575, at *2 (M.D. Fla. Apr. 27, 2009). The purpose of the rules governing expert disclosure is to safeguard against surprise. United States v. Marder, 318 F.R.D. 186, 192 (S.D. Fla. 2016); Apple Inc. v. Corellium, LLC, No. 19-81160-CV, 2021 WL 2940264, at *2 (S.D. Fla. July 13, 2021). III. Analysis The Court has carefully considered the relevant law, the Motion, response, reply, and the argument of the parties’ counsel at the August 11, 2022 hearing. HMA’s expert disclosure deadline was March 11, 2022. At the August 11, 2022 hearing, HMA argued that Rule 26(e) does not apply

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EFN West Palm Motor Sales, LLC v. Hyundai Motor America, (S.D. Fla. 2022).

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