Fan v. Jiang

CourtDistrict Court, D. Nevada
DecidedJanuary 13, 2023
Docket3:21-cv-00458
StatusUnknown

This text of Fan v. Jiang (Fan v. Jiang) 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
Fan v. Jiang, (D. Nev. 2023).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 * * *

4 FEI FEI FAN, Case No. 3:21-CV-00458-ART-CLB

5 Plaintiff, ORDER GRANTING MOTION TO COMPEL AND DENYING MOTION FOR 6 v. SPOLIATION SANCTIONS

7 YAN YAO JIANG, et al., [ECF Nos. 40, 41]

8 Defendants.

9 10 This case involves a civil action filed by Plaintiff Fei Fei Fan (“Fan”) against 11 Defendants Yan Yao Jiang (“Jiang”) and Wei Wu (“Wu”) (collectively referred to as 12 “Defendants”). Currently pending before the Court is Defendants’ motion to compel and 13 motion for spoliation sanctions. (ECF Nos. 40, 41.) Fan responded, (ECF Nos. 47, 48), 14 and Defendants replied. (ECF Nos. 49, 50.) For the reasons stated below, Defendants’ 15 motion to compel, (ECF No. 40), is granted, and the motion for spoliation sanctions, 16 (ECF No. 41), is denied. 17 I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY 18 A. Factual Background 19 Fan filed a complaint against Defendants on October 25, 2021, alleging claims 20 for sex trafficking, forced labor, and trafficking in servitude against Jiang, and intentional 21 infliction of emotional distress (“IIED”), trespassing, and assault claims against Wu. 22 (ECF No. 1.) The complaint alleges that Jiang recruited Fan from China to study at the 23 University of Nevada, Reno (“UNR”), where Jiang is a professor. (Id.) Fan alleges, 24 among many other claims, that Jiang used his position to force Fan to have sex with 25 him without her consent. (Id.) Fan alleges that she believed that if she withheld sex from 26 Jiang, Fan would suffer harm and damage on her visa, schooling prospects, stipend, 27 degree, and employment. (Id. at 14.) Fan also alleges claims against Wu, Jiang’s wife. 1 an ongoing threat by Fan to hurt and humiliate Defendants. (ECF No. 40 at 2.) 2 B. Discovery Process 3 On May 12, 2022, the Court held a case management conference (“CMC”) with 4 the parties. (ECF No. 29.) Following the CMC, the Court entered a scheduling order, 5 requiring discovery to be completed by April 7, 2023. (ECF No. 31.) Defendants sent 6 their first discovery requests in July of 2022. (ECF No. 40 at 2.) On August 16, 2022, the 7 Court conducted another CMC. (ECF No. 36.) The Court noted counsel for Fan, Mr. 8 Cann, failed to comply with the Court’s order and file a case management report prior to 9 the CMC. (Id.) The Court advised Mr. Cann that the Court expects orders of the Court to 10 be followed and failure to do so in the future may result in sanctions. (Id.)1 The Court 11 and counsel additionally discussed the issue of outstanding responsive documents from 12 Fan as to Wu and the issue of spoliation of evidence as outlined in the Defendants’ 13 case management reports. (Id. at 2.) Regarding the spoliation issue, the Court directed 14 that Fan locate and retrieve the information that was deleted in 2020. (Id.) 15 On August 25, 2022, the parties participated in a telephonic meet-and-confer. 16 (ECF No. 40 at 3.) During the call, Defendants raised concerns with Fan’s responses to 17 the discovery requests and Fan agreed to provide follow-up responses in one week. 18 (Id.) Defendants sent an email to Fan on the same day outlining what the group 19 discussed during the call, including specific discovery issues. (ECF Nos. 40-11, 40-12.) 20 On September 1, 2022, Fan asked for another week to provide the documents, a 21 request she reiterated on September 9, 2022. (ECF Nos. 40-13, 40-14.) This was 22 repeated on September 16, 2022. (ECF No. 40-14.) 23 On September 19, 2022, Wu emailed to ask for the requested documents as no 24 discovery had been provided since the meet-and-confer. (Id.) On September 29, 2022, 25 Wu sent another email stating that, if no discovery was provided within five business 26 1 The Court will offer no further warnings to Mr. Cann regarding the expectation 27 that he follows orders of the Court. Mr. Cann’s next failure to follow an order of the Court will result in an order to show cause why he should not be sanctioned. 1 days, or by October 6, 2022, Wu would be filing a motion to compel. (Id.) On the same 2 day, Jiang sent a similar email. (ECF No. 40-15.) Fan did not respond until October 21, 3 2022, when she provided a brief update and promised that the revised responses would 4 be provided by Wednesday, October 26, 2022. (ECF No. 40-17 at 3.) Wu responded 5 that she would wait until Monday morning for the responses and that if none were 6 forthcoming, she would file a motion to compel. (Id. at 3.) On October 21, 2022, Fan 7 replied that she could meet the Monday deadline. (Id at 2.) On Monday, October 24, 8 2022, Fan emailed to say she could not comply with the morning deadline but would 9 provide the documents by 5:00 p.m. (Id.) Defendants then filed the instant motion to 10 compel and motion for spoliation sanctions on October 24, 2022. (ECF Nos. 40, 41.) 11 II. LEGAL STANDARD 12 “[B]road discretion is vested in the trial court to permit or deny discovery.” Hallett 13 v. Morgan, 296 F.3d 732, 751 (9th Cir. 2002). The “scope of discovery” encompasses 14 “any nonprivileged matter that is relevant to any party's claim or defense and 15 proportional to the needs of the case[.]” Fed. R. Civ. P. 26(b)(1). In analyzing 16 proportionality, the Court must consider the need for the information sought based upon 17 “the importance of the issues at stake in the action, the amount in controversy, the 18 parties' relative access to relevant information, the parties' resources, the importance of 19 discovery in resolving the issues, and whether the burden or expense of the proposed 20 discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). Relevance is to be 21 construed broadly to include “any matter that bears on, or that reasonably could lead to 22 other matter that could bear on” any party's claim or defense. Oppenheimer Fund, Inc. 23 v. Sanders, 437 U.S. 340, 351 (1978) (citation omitted). 24 When a party fails to provide discovery and the parties' attempts to resolve the 25 dispute without Court intervention are unsuccessful, the opposing party may seek an 26 order compelling that discovery. Fed. R. Civ. P. 37(a). However, the party moving for an 27 order to compel discovery bears the initial burden of informing the court: (1) which 1 are disputed; (3) why he believes the response is deficient; (4) why defendants’ 2 objections are not justified; and (5) why the information he seeks through discovery is 3 relevant to the prosecution of this action. Harris v. Kernan, No. 2:17-cv-0680-TLN-KJN- 4 P, 2019 WL 4274010, at *1 (E.D. Cal. Sept. 10, 2019); see also Ellis v. Cambra, No. 5 1:02-cv-05646-AWI-SMS-PC, 2008 WL 860523, at *4 (E.D. Cal. 2008) (“Plaintiff must 6 inform the court which discovery requests are the subject of his motion to compel, and, 7 for each disputed response, inform the court why the information sought is relevant and 8 why defendant's objections are not justified.”). 9 Thereafter, the party seeking to avoid discovery bears the burden of showing why 10 that discovery should not be permitted. Blankenship v. Hearst Corp., 519 F.2d 418, 429 11 (9th Cir. 1975). The party resisting discovery “‘must specifically detail the reasons why 12 each request is irrelevant’ [or otherwise objectionable,] and may not rely on boilerplate, 13 generalized, conclusory, or speculative arguments.” F.T.C. v.

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Fan v. Jiang, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fan-v-jiang-nvd-2023.