Future Field Solutions, LLC v. Van Norstrand

District Court, D. Maryland·Decided September 8, 2025·No. 1:23-cv-01301·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

FUTURE FIELD SOLUTIONS, LLC, et al., *

Plaintiffs/Counter-Defendants, *

v. * Case No. 1:23-cv-01301-DKC

ERIK VAN NORSTRAND, *

Defendant/Counter-Plaintiff. *

* * * * * * * * * * * * * * * *

MEMORANDUM OPINION AND ORDER REGARDING DEFENDANT/COUNTER- PLAINTIFF’S MOTION FOR DISCOVERY SANCTIONS Before the Court is Defendant/Counter-Plaintiff Van Norstrand’s Motion for Sanctions against the Future Field Solutions, LLC (“Future Field”) Plaintiffs/Counter-Defendants (“Plaintiffs”) and PeriArchon, LLC (“PeriArchon”), their Counter-Co-Defendant for certain alleged discovery failures and infractions. (ECF No. 240). The Court has also reviewed Plaintiffs’ Opposition1 (ECF No. 250), adopted by PeriArchon (ECF No. 253), Defendant’s Reply (ECF No. 258), and the Sur-Reply by Plaintiffs/PeriArchon requested by this Court. (ECF No. 267). The Court finds that no hearing is necessary. As set forth more fully below, Defendant’s Motion (ECF No. 240) is DENIED, with one caveat regarding the alleged unauthorized recording of Defendant’s May 2025 deposition.

1 Plaintiffs filed one opposition responding to both the instant Motion for Sanctions and a separately filed Motion to Strike their dispositive motion (ECF No. 241). In this opinion, the Court only addresses the Motion for Sanctions. I. Background

The current lawsuit arises from a dispute among former members of Future Field that had its genesis when Defendant Van Norstrand was removed as a Future Field member. Among other things, the parties dispute both the value of Defendant’s interest in Future Field, and whether certain business assets and opportunities were wrongfully diverted by the remaining Future Field members to a new entity, PeriArchon, of which at least one member of Future Field, Plaintiff Reese, has a controlling interest. On June 28, 2023, the matter was referred to the undersigned by U.S. District Judge Deborah Chasanow for discovery and all related scheduling. (ECF No. 35).

In the instant motion, Defendant raises several areas of concern, all of which he contends should lead to the imposition of discovery sanctions against Plaintiffs/PeriArchon pursuant to Rule 37 of the Federal Rules of Civil Procedure. First, Defendant argues that the scope of his May 2025 deposition went beyond that established by this Court’s previous orders and was unnecessarily hostile and harassing of Defendant. (ECF No. 240 at 9-13).2 Second, Defendant argues that one of the individual Plaintiffs, Plaintiff Reese, made an unauthorized recording of his deposition and also made an “off the record” threat during a deposition break. Id. at 13-14. Third, Defendant argues that his opponents withheld information by failing to produce documents in discovery that they nonetheless rely upon in their recently filed dispositive motions and failed to provide

Defendant with access to his laptop, the partial contents of which Plaintiffs/PeriArchon also cite in their dispositive motion, in violation of previous orders of this Court. Id. at 14-21. For their part, Plaintiffs and PeriArchon maintain that all deposition questioning was appropriately within the scope previously ordered by the Court, and that no unauthorized recording

2 When the Court cites to a filing, it uses the page numbering assigned by the CM/ECF system rather than any page numbering supplied in the document. took place. (ECF No. 250 at 23-17; 39-41). Further, they assert that any “new” documents produced were either previously produced, already in Defendant’s possession, or produced pursuant to their duty to supplement under Rules 26(a) and 26(e) based on new or contradictory information raised by Defendant at his May 2025 deposition. Id. at 27-36. They also argue that

access to the laptop was available to Defendant at any time during the discovery period, yet he chose not to pursue it and did not otherwise bring it to the Court’s attention. Id. at 37-39. Accordingly, they content that no sanctions are appropriate. II. Analysis A. Legal Standard

The Federal Rules of Civil Procedure set forth both the tools available to the parties in conducting discovery and the expectations as to how those tools will be deployed and responded to. The Rules also recognize that discovery is dynamic, and that the scope of relevant information may change as the case evolves (e.g., amendments of pleadings, presentation of new facts, damages calculations), and with it the responsibilities of the parties to make sure that their discovery responses remain complete.3 Rule 26(a) for example recognizes that as more information is gathered in discovery or as theories of liability or damages change or evolve, a party may need to supplement a previous expert report to account for additional or different opinions an

expert may form as a result. Fed. R. Civ. Proc. 26(a)(2)(E). Similarly, Rule 26(e) obliges a party to timely supplement previous discovery responses as necessary with additional or corrective information. Fed. R. Civ. Proc. 26(e)(1).

3 It is also not uncommon for a party to uncover additional responsive information previously overlooked, or even sometimes not yet in existence at the time of the party’s original responses. There can be tension however between a party complying with its continuing duty to supplement and the timeliness of that supplementation. Rule 37(c) empowers a Court to consider sanctions for the failure to supplement in a timely fashion, unless such failure was “substantially justified or is harmless,” including the ability to exclude such evidence offered in support of (or in

rebuttal to) a dispositive motion among other sanctions. Fed. R. Civ. Proc. 37(c)(1). In the Fourth Circuit, five factors are considered in determining whether a non-disclosing party’s failure to disclose was substantially justified or harmless: (1) the surprise to the party against whom the evidence would be offered; (2) the ability of that party to cure the surprise; (3) the extent to which allowing the evidence would disrupt the trial; (4) the importance of the evidence; and (5) the non- disclosing party’s explanation for its failure to disclose the evidence. Southern States Rack and Fixture, Inc. v. Sherwin-Williams Co., 318 F3d 592, 597 (4th Cir. 2003). The party who failed to timely disclose bears the burden of proving that the failure was substantially justified or harmless. Allegis Group, Inc. v. Bero, 689 F.Supp.3d 81, 111 (D. Md. 2023) (citing Bresler v. Wilmington Trust Co., 855 F.3d 178, 190 (4th Cir. 2017)).

Rule 37 also allows for the imposition of sanctions where the moving party demonstrates that the opposing party failed to obey a court’s discovery orders. Fed. R. Civ. Proc. 37(b)(2); see also Victor Stanley, Inc. v. Creative Pipe, Inc., 269 F.R.D. 497, 519-20 (D. Md. 2010) (explaining that a court’s power to sanction pursuant Rule 37(b)(2) is broad). If a violation is demonstrated, a court considers four factors in determining whether to impose a sanction for such violations: (1) whether the non-complying party acted in bad faith; (2) the amount of prejudice that

noncompliance caused the adversary; (3) the need for deterrence of the particular sort of noncompliance; and (4) whether less drastic sanctions would be effective. Southern States, supra at 597. B. Permissible Scope of Deposition and Deposition Behavior

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