Focal Point Films, LLC v. Sandhu

CourtDistrict Court, N.D. California
DecidedSeptember 28, 2020
Docket3:19-cv-02898
StatusUnknown

This text of Focal Point Films, LLC v. Sandhu (Focal Point Films, LLC v. Sandhu) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Focal Point Films, LLC v. Sandhu, (N.D. Cal. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 FOCAL POINT FILMS, LLC, 7 Case No. 19-cv-02898-JCS Plaintiff, 8 ORDER RE: v. 9 1. GIBEL’S MOTION TO ARJOT SANDHU, EXCLUDE/STRIKE EXPERT 10 TESTIMONY OF SANDHU Defendant. EXPERTS SARAH (SALLY) 11 RUBIN AND SARA RINKE (Dkt. No. 73) 12 2. GIBEL’S MOTION TO 13 PRECLUDE EVIDENCE OF DAMAGES RELATING TO 14 SANDHU’S CLAIM FOR UNJUST ENRICHMENT AND 15 FOR PARTIAL SUMMARY JUDGMENT ON THAT CLAIM 16 (Dkt. No. 74)

17 3. SANDHU’S DAUBERT MOTION TO EXCLUDE THE 18 TESTIMONY OF VIVIAN KLEIMAN (Dkt. No. 75) 19

21 I. INTRODUCTION 22 In this action Plaintiffs and Counterdefendants Focal Point Films and Bryan Gibel 23 (collectively, “Gibel”) and Defendant and Counterclaimant Arjot Sandhu (“Sandhu”) seek a 24 declaratory judgment under the Copyright Act, 28 U.S.C. § 2201, with respect to the authorship of 25 an as-of-yet unfinished documentary film entitled Sign My Name to Freedom (“the Film”). In 26 addition, Sandhu asserts a counterclaim for unjust enrichment. Presently before the Court are the 27 following motions: 1) Gibel’s Motion To Exclude/Strike Expert Testimony Of Sandhu Experts 1 Evidence of Damages Relating to Sandhu’s Claim for Unjust Enrichment and for Partial 2 Summary Judgment on that Claim (“Gibel’s Summary Judgment Motion”); and 3) Sandhu’s 3 Daubert Motion to Exclude the Testimony of Vivian Kleiman (“Sandhu’s Daubert Motion”). 4 The Court will also address the question of bifurcation, which it asked the parties to brief at the 5 previous case management conference. A hearing on the motions was held on September 25, 6 2020 at 9:30 a.m. The Court’s rulings are set forth below.1 7 II. GIBEL’S SUMMARY JUDGMENT MOTION 8 A. Background 9 In his summary judgment motion, Gibel asks the Court to dismiss Sandhu’s unjust 10 enrichment claim on the basis that Sandhu did not timely disclose the underlying theory for that 11 claim, namely, that she is entitled to compensation for the reasonable value of her work on the 12 Film. He further contends the claim must be dismissed because to the extent Sandhu asserts the 13 unjust enrichment claim in order to recover her share of the profits on the Film, it is undisputed 14 that no profits have been earned on the Film. He relies on Rule 37(c) of the Federal Rules of Civil 15 Procedure in support of the first argument and Rule 56 in support of the second argument. Sandhu 16 does not dispute that the Film has not generated any profits and stipulated at oral argument that 17 she is not seeking to recover her share of profits under the unjust enrichment claim. She contends, 18 however, that her disclosures were adequate and timely with respect to the theory that she is 19 entitled compensation for her work on the Film. The Court agrees and therefore DENIES Gibel’s 20 Summary Judgment Motion. 21 B. Legal Standards 22 Under Federal Rule of Civil Procedure 26(a)(1)(A), a party must “provide to the other 23 parties . . . a computation of each category of damages claimed by the disclosing party—who must 24 also make available for inspection or copying as under Rule 34 the documents or other evidentiary 25 material, . . . on which each computation is based. . . .” Fed. R. Civ. P. 26(a)(1)(A)(iii). In 26 addition, Rule 26(e)(1)(A) requires that: 27 A party who has made a disclosure under Rule 26(a) ... must 1 supplement or correct its disclosure or response ... in a timely manner if the party learns that in some material respect the disclosure or 2 response is incomplete or incorrect, and if the additional or corrective information has not otherwise been made known to the other parties 3 during the discovery process or in writing. 4 Fed. R. Civ. P. 26(e)(1)(A). 5 Federal Rule of Civil Procedure 37(c)(1) “‘forbid[s] the use at trial of any information 6 required to be disclosed by Rule 26(a) that is not properly disclosed.’” R & R Sails, Inc. v. Ins. Co. 7 of Pa., 673 F.3d 1240, 1246 (9th Cir. 2012) (quoting Yeti by Molly, Ltd. v. Deckers Outdoor 8 Corp., 259 F.3d 1101, 1106 (9th Cir. 2001)). Rule 37(c)(1) provides: 9 If a party fails to provide information or identify a witness as required by Rule 26(a) or (e), the party is not allowed to use that information 10 or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless. In addition 11 to or instead of this sanction, the court, on motion and after giving an opportunity to be heard: 12 (A) may order payment of the reasonable expenses, including 13 attorney’s fees, caused by the failure; 14 (B) may inform the jury of the party’s failure; and 15 (C) may impose other appropriate sanctions, including any of the orders listed in Rule 37(b)(2)(A)(i)-(vi). 16 17 Fed. R. Civ. P. 37(c)(1). “[L]ower courts are entrusted with ‘particularly wide latitude’ in 18 exercising this discretion to impose sanctions under Rule 37(c).” Silvagni v. Wal-Mart Stores, Inc., 19 320 F.R.D. 237, 242 (D. Nev. 2017) (quoting Yeti by Molly, 259 F.3d at 1106). The party facing 20 sanctions bears the burden of proving that its failure to disclose the required information was 21 substantially justified or is harmless. R & R Sails, 673 F.3d at 1246 (citing Torres v. City of L.A., 22 548 F.3d 1197, 1213 (9th Cir. 2008)). 23 C. Discussion 24 Gibel argues that preclusion sanctions should be imposed as to Sandhu’s unjust enrichment 25 claim to the extent she seeks to recover the value of her work on the Film because “[s]he did not 26 allege this theory of damages in her initial counterclaim or amended counterclaim, nor did she 27 disclose it in her initial disclosures or even her amended initial disclosures, served after the close 1 discovery, in an expert report, that Sandhu, for the first time, indicated that she intended to seek 2 damages at trial based on the time value of her work, in addition to an accounting or disgorgement 3 of profits as a co-author.” Id. The record does not support Gibel’s argument however. 4 First, it has been clear at least since Sandhu filed her Amended Answer and Counterclaims, 5 Docket No. 20 (“Amended Answer”), that in asserting her unjust enrichment counterclaim she was 6 seeking to recover compensation for her work on the Film. See Amended Answer at ¶ 62 (alleging 7 as part of her unjust enrichment counterclaim that “Sandhu did not receive compensation for her 8 services as an author, producer, cinematographer, director, editor, photographer, or promoter of 9 the Film as would be typical for a work-for-hire employee”); ¶ 63 (alleging as part of her unjust 10 enrichment counterclaim that Gibel “retain[ed] the benefit of Ms. Sandhu’s work—including sole 11 access to footage Ms. Sandhu shot and the website she created—without having compensated her 12 for the reasonable value of her contributions”); Prayer, ¶ 3 (seeking compensatory damages). 13 Sandhu reiterated that she was seeking compensatory damages in her case management conference 14 statements. See Docket No.

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Focal Point Films, LLC v. Sandhu, Counsel Stack Legal Research, https://law.counselstack.com/opinion/focal-point-films-llc-v-sandhu-cand-2020.