Foguth v. Discover Bank

CourtDistrict Court, E.D. Michigan
DecidedMarch 4, 2025
Docket2:25-cv-10274
StatusUnknown

This text of Foguth v. Discover Bank (Foguth v. Discover Bank) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foguth v. Discover Bank, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JAMES A. FOGUTH, ALAN W. Case No. 25-10274 FOGUTH, Plaintiffs, Matthew F. Leitman v. United States District Judge

DISCOVER BANK, Curtis Ivy, Jr. Defendants. United States Magistrate Judge ____________________________/

ORDER REGARDING PLAINTIFFS’ MOTIONS (ECF Nos. 17, 18, 19)

On February 14, 2025, the Court filed an Order that (1) denied an extension of time to respond to Defendant’s pending motion, and (2) struck discovery requests Plaintiffs’ filed on the docket. (ECF No. 10). On behalf of himself and his son, Plaintiff James A. Foguth has since filed (1) a response to the Court’s Order which includes a request for additional time to respond to Defendant’s pending motion to compel arbitration or, in the alternative, to dismiss, (ECF No. 17); (2) a motion for relief due to emotional distress and request for appointed counsel, (ECF No. 18); and (3) a request for the undersigned’s recusal, (ECF No. 19). As far as Plaintiffs’ response to this Court’s Order seeks vacatur of that Order, the Court will treat his filing as a motion for reconsideration. Likewise, the Court will treat Plaintiffs’ request for the undersigned’s recusal as a motion. That said, the Court kindly reminds Plaintiffs that if they seek some form of relief from the Court, those requests should be styled as a motion and comply with Local Rules 5.1 and 7.1.1

I. Plaintiffs’ Motion for Reconsideration (ECF No. 17) Plaintiff primarily seeks vacatur of this Court’s Order that struck Plaintiffs’ discovery requests from the docket under Local Rule 26.2(a). Underscoring his

right to conduct discovery, Plaintiff James A. Foguth cites a number of legal authorities including the Federal Rules of Civil Procedure, various provisions of the United States Constitution, and non-binding Michigan Court Rules. (ECF No. 17, PageID.332-33).

As Plaintiffs seek vacatur of an Order striking discovery requests, Local Rule 7.1(h)(2) controls this Court’s analysis as Plaintiffs’ request is for reconsideration on a non-final order. The Local Rule first states that “[m]otions for

reconsideration of non-final orders are disfavored.” E.D. Mich. LR 7.1(h)(2). The Rule permits reconsideration “only upon the following grounds”: (A) The court made a mistake, correcting the mistake changes the outcome of the prior decision, and the mistake was based on the record and law before the court at the time of its prior decision;

(B) An intervening change in controlling law warrants a different outcome;

1 For Plaintiffs’ convenience, the Court has linked the Local Rules here: United States District Court for the Eastern District of Michigan, https://perma.cc/84QX-HLKR (last visited Mar. 3, 2025). (C) New facts warrant a different outcome and the new facts could not have been discovered with reasonable diligence before the prior decision.

E.D. Mich. 7.1(h)(2)(A)-(C). Considering Plaintiffs’ claim that the Court made a mistake striking their discovery request and they ground that claim in several sources of law that have not changed since the Court’s Order, Plaintiffs’ request for reconsideration rests on Local Rule 7.1(h)(2)(A). “[M]otions for reconsideration are not an opportunity to re-argue a case, present new arguments, or otherwise relitigate issues that the court previously considered.” Bowles v. Macomb Cmty. Coll., 2022 WL 1469515, at *1 (E.D. Mich.

May 10, 2022); see also Saltmarshall v. VHS Child. Hosp. of Michigan, Inc., 402 F. Supp. 3d 389, 393 (E.D. Mich. 2019). Under Local Rule 7.1(h)(2)(A), the movant must show that the Court made a mistake based on the record and law before it

when it made the ruling. As Plaintiffs’ do not make this showing, their motion for reconsideration is DENIED. Notwithstanding the various legal authority Plaintiffs cite, the Court agrees with their broader argument that they have the right to conduct discovery. The

issue was simply how Plaintiffs sought to do so. The Local Rules for the Eastern District of Michigan do not permit parties to file discovery requests with the Court; rather, discovery requests must be sent directly to the other party—not the Court.

Local Rule 26.2, titled “Filing Discovery Material,” reads as follows: (a) A party or other person may not file discovery material specified in [Federal Rule of Civil Procedure] 5(d)(1) and certificates of service for such discovery material except:

(1) when it provides factual support for a motion, response, or reply. The party or other person relying on the material must file only the germane portion of it as an exhibit or attachment to the motion, response, reply.

(2) when it is read or otherwise used during a trial or other proceeding. The party or other person relying on the material must file it at the conclusion of the trial or other proceeding in which it was used or at a later time that the court permits.

(3) on order of the court.

(4) if discovery material not previously filed is needed for an appeal, the party or other person with custody of the discovery material must file it either by stipulation or court order.

E.D. Mich. LR. 26.2(a)(1)-(3). Federal Rule of Civil Procedure 5(d)(1)(A) also states that “the following discovery requests and responses must not be filed until they are used in the proceeding or the court orders filing: depositions, interrogatories, requests for documents or tangible things or to permit entry onto land, and requests for admission.” Thus, under the Federal Rules of Civil Procedure and this Court’s Local Rules, parties cannot file discovery requests for depositions, interrogatories, requests for documents, or requests for admission unless one of the above exceptions apply. The filing the Court struck included discovery requests for a deposition, production of documents and information, and an admission. (ECF No. 8). Unless an exception applies, these types of discovery requests cannot be filed with the Court.

No such exception applied at the time the Court struck Plaintiffs’ discovery requests. The requests were not connected to a pending motion, response, or reply. Though Plaintiffs’ motion for remand is pending along with Defendant’s motion to

compel arbitration or, in the alternative, to dismiss, the discovery requests did not refer to those motions. No trial or proceeding had occurred at the time of the Court’s decision, so the second exception did not apply. The Court had not ordered any discovery to be filed, and there is no appeal in this case. As none of the

exceptions applied, the Court was required to strike the discovery requests under the Federal Rules of Civil Procedure and the Local Rules of this Court. Removing improperly filed discovery requests from the docket is routine in

this Court. See Kuerbitz v. Bouchard, No. 2:24-CV-10774, 2024 WL 4279508, at *1 (E.D. Mich. Sept. 24, 2024) (“[T]he Eastern District of Michigan Local Rules state that a party may not file discovery material specified in Fed. R. Civ. P. 5(d)(1) . . . .”) (internal quotation omitted); Olivares v. Performance Contracting Grp., No.

22-10574, 2022 WL 18860465, at *3 (E.D. Mich.

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