Grano v. Sodexo, Inc.

District Court, S.D. California·Decided December 10, 2020·No. 3:18-cv-01818·Unknown

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 Case Nos.: 18cv1818-TWR(BLM) 10 VINCENT GRANO, et al.,

11 Plaintiffs, ORDER GRANTING IN PART PLAINTIFFS’ MOTION TO DETERMINE 12 v. SUFFICIENCY OF CARGILL’S RESPONSES TO PLAINTIFFS’ SECOND 13 SODEXO MANAGEMENT, INC., et al., REQUESTS FOR ADMISSION 14 Defendants. [ECF NO. 240] 15 ____________________________________ 16 AND RELATED CASES 17 18 Currently before the Court is Plaintiffs’ November 4, 2020 Motion to Determine Sufficiency 19 of Cargill’s Responses to Plaintiffs’ Second Requests for Admission [ECF No. 240-1 (“Mot.”)], 20 Defendant Cargill Meat Solutions Corp.’s November 18, 2020 opposition to the motion [ECF No. 21 245 (“Oppo.”)], and Plaintiffs’ November 24, 2020 reply [ECF No. 250 (“Reply”)]. For the 22 reasons set forth below, Plaintiffs’ motion is GRANTED IN PART. 23 DISCOVERY RELATED BACKGROUND 24 On September 10, 2020, Plaintiffs served their Second Requests for Admission (“RFA”) 25 on Defendant Cargill. ECF No. 240-2, Declaration of R. Drew Falkenstein in Support of Plaintiffs’ 26 Motion to Determine Sufficiency of Cargill’s Responses to Plaintiffs’ Second Requests for 27 Admission (“Falkenstein Decl.”) at ¶ 2, Exh. A. 28 On October 12, 2020, Defendant Cargill served its responses to the RFAs. Id. at ¶ 3, Exh. 1 B. That same day, Plaintiffs’ counsel sent Cargill an initial meet and confer email to which 2 Cargill’s counsel responded. Id. at ¶ 4a, Exh. C. On October 13, 2020, Plaintiffs’ counsel sent 3 as second meet and confer letter to Cargill addressing his substantive concerns with Cargill’s 4 responses, requesting that Cargill supplement or revise its responses, and requesting a 5 telephonic meet and confer. Id. at ¶ 4b, Exh. D. Cargill’s counsel responded on October 16, 6 2020 and the parties held an unsuccessful telephonic meet and confer that same day. Id. at ¶¶ 7 4c and 4d, Exh. E. 8 On October 19, 2020, counsel for Defendant Cargill, Ms. Bullard and Mr. Bylund, and 9 counsel for Plaintiffs, Mr. Falkenstein, jointly contacted the Court regarding the discovery dispute 10 concerning the RFAs. ECF No. 229. In regard to the dispute, the Court issued a briefing 11 schedule. Id. In accordance with that schedule, the parties timely filed their motion, opposition, 12 and reply. Id.; see also Mot., Oppo., and Reply. 13 LEGAL STANDARD 14 “A party may serve on any other party a written request to admit, for purposes of the 15 pending action only, the truth of any matters within the scope of Rule 26(b)(1) relating to: (A) 16 facts, the application of law to fact, or opinions about either; and (B) the genuineness of any 17 described documents.” Federal Rule of Civil Procedure (“Fed. R. Civ. P.”) 36(a)(1). “Each matter 18 must be separately stated.” Fed. R. Civ. P. 36(a)(2). A responding party must admit a matter, 19 specifically deny a matter, or state in detail why they cannot truthfully admit or deny it. Fed. R. 20 Civ. P. 36(a)(4). If a matter is denied, the “denial must fairly respond to the substance of the 21 matter; and when good faith requires that a party qualify an answer or deny only a part of a 22 matter, the answer must specify the part admitted and qualify or deny the rest.” Id. A 23 responding party may object to a request if they state the ground for the objection. Fed. R. Civ. 24 P. 36(a)(5). The requesting party may then seek a decision from the court determining the 25 sufficiency of an answer or objection. Fed. R. Civ. P. 36(a)(6). The court must order that an 26 answer be served unless it finds an objection justified. Id. “On finding that an answer does not 27 comply with this rule, the court may order either that the matter is admitted or that an amended 28 answer be served.” Id. An order deeming matters admitted is a “severe sanction.” Black 1 Mountain Equities, Inc. v. Players Network, Inc., 2020 WL 2097600, at *10 (S.D. Cal., May 1, 2 2020) (citing Asea, Inc. v. S. Pac. Transp. Co., 669 F.2d 1242, 1247 (9th Cir. 1981) (vacating 3 district court's order deeming RFAs admitted because it was a “severe sanction” that required a 4 showing “that a party has intentionally disregarded the obligations imposed by Rule 36(a)” and 5 the district court did not state a basis for finding “that the [defendant] did not make reasonable 6 inquiry or that the information readily obtainable was sufficient to allow them to admit or deny 7 the particular requests”). The Ninth Circuit has observed that “courts generally order an 8 amended answer rather than deem the matter admitted.” Id. at *10 (citing Asea, Inc., 669 F.2d 9 at 1246). 10 PARTIES’ POSITIONS 11 Plaintiffs seek an order from the Court striking Cargill’s objections and answers to 12 Plaintiffs’ Second RFAs Nos. 14-21 and requiring Cargill to answer each RFA as written. Mot. at 13 5. Plaintiffs argue that Cargill’s responses to the RFAs are deficient because they 14 (1) employ boilerplate, inappropriate objections to specifically defined terms, (2) ignore specifically defined terms, (3) substitute specifically defined terms 15 out and, in narrative fashion, premise denials on different terms that 16 inappropriately introduce concepts that Plaintiffs specifically sought to avoid, and (4) explicitly premise each denial on its stated objections. 17 18 Id. Specifically, in responding to its RFAs, Cargill improperly removed the term “elimination 19 step”1 and substituted it with “a narrative discussion of ‘lethality treatment,’ which is a defined 20 term at 9 C.F.R § 430.1.”2 Mot. at 3. Plaintiffs note that the term lethality treatment introduces

21 1 Plaintiffs define the term as: 22 Elimination-step includes any treatment applied to, or action taken with respect 23 to, any raw beef components that you utilized to produce the subject ground beef products, or to the finished subject ground beef products themselves, to eliminate 24 (i.e., reduce to zero) any viable pathogens via thermal, chemical, biological, 25 or mechanical process. The term “elimination-step” includes specifically, but not exclusively, irradiation. 26 Falkenstein Decl. at Exh. A. 27 2 Lethality treatment is “[a] process, including the application of an antimicrobial agent, that 28 1 concepts that they intentionally sought to avoid in the wording of their RFAs and permits Cargill 2 to avoid responding to the questions Plaintiffs want to ask. Id. Plaintiffs also argue that Fed. 3 R. Civ. P. 36 does not permit Cargill to rewrite Plaintiffs’ specifically defined term and 4 fundamentally alter the meaning of the request. Id. at 4. Fed. R. Civ. P. 36(a)(4) required 5 Cargill to admit or specifically deny each RFA or state in detail why it could not, which it failed 6 to do, instead relying on improper boilerplate objections. Id. at 5. Plaintiffs argue that Cargill’s 7 objections to the term “subject ground beef products” were improper given that it refers 8 “definitively and without question” to the ground beef patties Cargill produced.3 Id. at 5-6. 9 Plaintiffs further argue that additional objections to the RFAs raised in Cargill’s October 16, 2020 10 meet and confer letter do not excuse Cargill from truthfully admitting or denying the RFAs at 11 issue. Id. at 7.

Free access — add to your briefcase to read the full text and ask questions with AI

Grano v. Sodexo, Inc., (S.D. Cal. 2020).

Grano v. Sodexo, Inc. (Grano v. Sodexo, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related