Flowers-Carter v. Braun Corporation

District Court, D. Arizona·Decided June 10, 2020·No. 2:18-cv-03836·Unknown

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Latricia Flowers-Carter, et al., No. CV-18-03836-PHX-DWL

10 Plaintiffs, ORDER

11 v.

12 Braun Corporation,

13 Defendant. 14 15 On May 11, 2020, the Court issued a 30-page order that granted in part, and denied 16 in part, Plaintiffs’ motion to compel Braun to produce six categories of discovery material 17 and to sanction Braun for discovery misconduct. (Doc. 165.) Among other things, this 18 order (1) recounted the many discovery disputes that have arisen throughout the course of 19 this case (id. at 10-18); (2) held that Plaintiffs’ motion to compel “could be denied outright” 20 because Plaintiffs failed to submit a meet-and-confer certification, as required by Rule 21 37(a)(1) and LRCiv 7.2(j) (id. at 18-20); (3) stated that the Court would, in its discretion, 22 overlook Plaintiffs’ non-compliance as to two of the categories at issue—certain emails 23 withheld by Braun based on the “common interest doctrine” and other documents withheld 24 by Braun based on the attorney-client privilege—because it was clear, based on earlier 25 hearings, that the parties had exhausted their meet-and-confer efforts regarding those 26 documents (id. at 20-21); (4) granted Plaintiffs’ motion to compel as to the first category, 27 because Braun had not established the applicability of the common interest doctrine (id. at 28 21-24); (5) denied Plaintiffs’ motion to compel as to the second category (id. at 24-26); 1 and (6) authorized Plaintiffs, as a sanction for Braun’s shifting disclosures concerning a 2 key issue (the vehicle replacement offer), to depose an additional witness at Braun’s 3 expense (id. at 26-30). 4 Both sides have now filed what are effectively motions for partial reconsideration 5 of the May 11, 2020 order. (Docs. 166, 168.)1 For the following reasons, both motions 6 will be denied. 7 I. Braun’s Motion for Clarification (Doc. 166) 8 As noted, one of the categories of discovery material addressed in the May 11, 2020 9 order was a set of 17 emails—all communications between agents of Braun and agents of 10 non-party United Access (“UA”)—that Braun had refused to produce pursuant to the 11 common interest doctrine. All 17 emails were identified by Braun on a document entitled 12 “Common Interest Privilege Log.” (Doc. 166-1.) In response to Plaintiffs’ motion to 13 compel, Braun broadly asserted that all of the emails identified on this log were immune 14 from disclosure because they constituted “Braun’s communications with UA” that “were 15 made for the limited purpose of facilitating the rendition of legal services relating to UA’s 16 response to Plaintiffs’ Subpoena for Braun’s documents.” (Doc. 154 at 15.) In the May 17 11, 2020 order, the Court concluded that Braun’s invocation of the common interest 18 doctrine “fails for the threshold reason that it has not demonstrated that the UA 19 representatives with whom its lawyers were communicating were themselves lawyers or 20 represented by lawyers at the time of the communication,” which “is a prerequisite to the 21 application of the doctrine.” (Doc. 165 at 23.) 22 On May 20, 2020, Braun filed a “motion for clarification.” (Doc. 166.) Specifically, 23 Braun seeks to advance an alternative reason why it should be allowed to continue 24 withholding one of the 17 emails. That email was identified on the “Common Interest 25 Privilege Log” as an August 15, 2019 email from Braun’s outside counsel to five other 26 Braun representatives (in-house counsel and outside counsel) and one UA employee, Rich 27 1 Plaintiffs have also filed a motion to reopen discovery for the purpose of pursuing 28 two additional depositions. (Doc. 171.) That motion is not yet fully briefed, so it would be premature to address it now. 1 Venhaus. (Doc. 166-1 at 3 [“Tab 4”].) Braun argues it should be allowed to continue 2 withholding that email because, although an employee of UA was “inadvertently copied” 3 onto the recipient line, the email was intended to be sent only to other Braun employees 4 and agents and is therefore protected by the attorney-client privilege and the work-product 5 doctrine. (Doc. 166 at 2 n.2 [“Braun’s counsel . . . inadvertently copied a United Access 6 employee on this email, but the contents of [the] communication expressly state that he 7 intended to exclude United Access for the purpose of maintaining the attorney client 8 privilege.”].) 9 On May 21, 2020, the Court issued an order calling for additional briefing. (Doc. 10 167.) Among other things, this order questioned whether Braun’s claim of inadvertent 11 disclosure was consistent with the position that Braun had taken when attempting to defend 12 the applicability of the common interest doctrine. (Id. at 2 [“Braun has not explained why 13 it offered one factual description of the August 15, 2019 email in its response to the motion 14 to compel (i.e., an email intentionally sent to UA in an attempt to promote the parties’ 15 common legal interest) yet now seeks to offer an entirely different and contradictory 16 description of the email in its motion for clarification (i.e., an email accidentally sent to 17 UA due to an ‘inadvertent’ typing error by Braun’s counsel). This abrupt change is 18 disturbing.”].) 19 On May 27, 2020, Plaintiffs filed a response to Braun’s motion. (Doc. 169.) 20 Plaintiffs contend that (1) Braun waived any claim of privilege by disclosing the email to 21 a third party (from UA) and then failing to undertake any effort to claw back the inadvertent 22 disclosure; (2) by rejecting Braun’s arguments concerning the applicability of the common 23 interest doctrine, the Court necessarily also found that the email wasn’t privileged; and (3) 24 because Braun’s “new argument was available to it at the time it briefed its response to 25 Plaintiffs’ motion,” Braun “cannot assert it now through its mislabeled motion for 26 reconsideration.” (Id.) 27 On June 5, 2020, Braun filed a reply. (Doc. 173.) Braun begins by arguing that it 28 has not waived or forfeited its privilege claim because (1) it specifically denoted, in its 1 “Common Interest Privilege Log,” that it believed the August 15, 2019 was covered by the 2 attorney-client privilege, and (2) although it didn’t brief the applicability of the privilege 3 in its response to the motion to compel, there was no reason to do so—Plaintiffs’ motion 4 only challenged the applicability of the common interest doctrine. (Id. at 1-3.) Braun also 5 attempts to address the concern set forth in the Court’s May 21, 2020 order, arguing that it 6 has not taken inconsistent positions because it “did not specifically address Item No. 4 in 7 its Response” to the motion to compel and thus “did not specifically describe Item No. 4 8 as ‘intentionally sent to UA . . . to promote the parties’ common legal interests.’” (Id. at 9 2-3.) Next, under the heading “Inadvertent disclosure does not automatically waive 10 privilege,” Braun argues it did not “purposely intend[] to waive the privilege” because “it 11 never intended to send the email to a third party beyond the reach of the privilege 12 relationship. Braun did not claw back the email, as Braun reasonably believed the email 13 was privileged pursuant to the attorney–client privilege and common-interest doctrine.” 14 (Id. at 3-4.) Finally, Braun argues that the May 11, 2020 ruling concerning the 15 inapplicability of the common interest doctrine has no bearing on the distinct issue of 16 whether the August 15, 2019 email is privileged. (Id. at 4-5.) 17 Braun’s motion will be denied for two independent reasons. First, although Braun 18 attempts to characterize its motion as a request for clarification, it is no such thing.

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