In re Carvana Co Securities Litigation

CourtDistrict Court, D. Arizona
DecidedAugust 13, 2025
Docket2:22-cv-02126
StatusUnknown

This text of In re Carvana Co Securities Litigation (In re Carvana Co Securities Litigation) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Carvana Co Securities Litigation, (D. Ariz. 2025).

Opinion

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

9 United Association National Pension Fund, No. CV-22-02126-PHX-MTL et al., 10 ORDER Plaintiffs, 11 v. 12 Carvana Company, et al., 13 Defendants. 14 15 Pending before the Court is the Parties’ “Joint Discovery Motion” regarding the 16 twelve confidential witnesses (“CWs”) cited in the Amended Consolidated Complaint 17 (“ACC”) for Violations of the Federal Securities Laws. (Doc. 171 at 2.) For the reasons 18 explained below, the motion is granted in part and denied in part. 19 I. Background. 20 In support of the allegations in the ACC, Plaintiffs cite the statements of “[s]everal 21 former [Carvana] employees [(confidential witnesses or CWs)] [who] provided 22 information demonstrating that Defendants’ Class Period statements were false and 23 misleading, that Defendants knew or recklessly disregarded the falsity or misleading 24 nature of their statements, and that Defendants engaged in a scheme to defraud 25 investors.” (Doc. 71 at 19.) In Plaintiffs’ words, “The information provided by the CWs 26 supports a strong inference that the Exchange Act Defendants acted with scienter.” (Id.)1 27 Defendants seek the CWs’ identities and factual statements made “regarding

28 1 The “Exchange Act Defendants” are Carvana, Garcia, Jr., Garcia, Sr., and Jenkins. (Doc. 71 at 13-14.) 1 Plaintiffs’ claims.” (Doc. 171 at 2.) They seek an order compelling Plaintiffs “to answer 2 Carvana Defendants’ Interrogatory No. 4 and produce documents in response to Mr. 3 Garcia Sr.’s RFP 8.” (Id.)2 Plaintiffs characterize this inquiry as an invasion into “core 4 attorney work product.” (Id. at 3.) 5 a. The Parties’ Arguments. 6 i. Defendants. 7 Defendants argue the information sought is “necessary to verify CWs’ 8 allegations,” and that courts, including those in the Ninth Circuit, have “consistently 9 rejected” such claims of work product. (Doc. 171 at 2.) Defendants characterize CW 10 identities, statements, and documents as facts. (Id. at 2-3.) They note that Plaintiffs’ 11 insistence now that no CW evidence will be relied upon at class certification or trial is a 12 “convenient about-face [that] only highlights the need to test the veracity of the 13 Complaint’s CW allegations.” (Id. at 3.) Defendants further argue that Plaintiffs waived 14 any claim of work product by relying on “the CWs to make out their claims, and 15 Defendants’ need outweighs any minimal work product protection[.]” (Id.) (citations 16 omitted). 17 ii. Plaintiffs. 18 Plaintiffs argue that “[t]he identities of those with whom counsel elected to speak 19 as part of their investigation,” including counsels’ notes, memoranda, and 20 communications regarding those conversations “lie at the very heart of the work product 21 doctrine . . . as such materials reveal counsel’s mental impressions, legal theories, and 22 strategic decisions about which facts and witnesses are most important.” (Doc. 171 at 3- 23 4.) They allege Defendants intend to conduct an “improper post hoc investigation into the 24 sourcing of a complaint’s allegations.” (Doc. 171 at 3.) Plaintiffs argue further they did 25 not waive work product protections by relying upon CW evidence “because the [Private

26 2 The Carvana Defendants’ Interrogatory 4 states as follows: “Identify the name and, if known, contact information for each Confidential Witness, including specifying which 27 number You assigned to each CW.” (Doc. 171-1 at 10.) Garcia Sr.’s RFP 8 requests “[a]ll DOCUMENTS and COMMUNICATIONS reflecting any statements made by, or 28 information provided by, any Confidential Witness pertaining in any way to GARCIA SENIOR.” (Doc. 171-3 at 10.) 1 Securities Litigation Reform Act (“PSLRA”)] compels plaintiffs to disclose the factual 2 basis for their allegations,” and Plaintiffs do not intend to rely on CW evidence at class 3 certification or trial. (Id. at 4.) Plaintiffs assert that Defendants’ inquiries amount to “a 4 Fed. R. Civ. P. 11 fishing expedition.” (Id. at 5.) 5 II. Discussion. 6 “The work-product rule is not a privilege but a qualified immunity protecting from 7 discovery documents and tangible things prepared by a party or his representative in 8 anticipation of litigation.” Admiral Ins. Co. v. U.S. Dist. Ct. for Dist. of Arizona, 881 F.2d 9 1486, 1494 (9th Cir. 1989) (citations omitted). To qualify for work-product protection, 10 documents must: (1) be “prepared in anticipation of litigation or for trial” and (2) be 11 prepared “by or for another party or by or for that other party’s representative.” In re 12 Grand Jury Subpoena, Mark Torf/Torf Envtl. Mgmt., 357 F.3d 900, 907 (2003); Fed. R. 13 Civ. P. 26(b)(3). For a document serving purposes separate or independent from the 14 litigation, i.e., a “dual purpose” document, 15 [A] document should be deemed prepared “in anticipation of litigation” and thus eligible for work product protection under 16 Rule 26(b)(3) if in light of the nature of the document and the factual situation in the particular case, the document can be 17 fairly said to have been prepared or obtained because of the prospect of litigation. 18 19 In re Grand Jury Subpoena, 357 F.3d at 907 (cleaned up). 20 This standard “considers the totality of the circumstances and affords protection 21 when it can fairly be said that the document was created because of anticipated litigation, 22 and would not have been created in substantially similar form but for the prospect of that 23 litigation.” Id. (emphasis added). The party asserting the protection of the work-product 24 doctrine has the burden of demonstrating that the at-issue documents are work-product. 25 Hernandez v. Tanninen, 604 F.3d 1095, 1102 (9th Cir. 2010) (recognizing burden is on 26 party invoking work-product doctrine). 27 This Court agrees with Defendants that CW identities are not work product—they 28 are facts. (Doc. 171 at 2.) CWs are witnesses whose information Plaintiffs relied upon to 1 plead their claims. (Doc. 71 at 19-41.) They have information relevant to Defendants’ 2 scienter, or lack thereof. (See id.) Defendants are entitled to relevant, non-privileged 3 information. See Fed. R. Civ. P. 26(b)(1) (“Parties may obtain discovery regarding any 4 nonprivileged matter that is relevant to any party’s claim or defense and proportional to 5 the needs of the case . . . .”); see Fed. R. Evid. 401. 6 Relying upon Grae v. Corr. Corp. of Am., Plaintiffs contend that CW identities 7 “lie at the very heart of the work product doctrine.” (Doc. 171 at 3-4, citing 326 F.R.D. 8 482, 487-88 (M.D. Tenn. 2018)). Indeed, the Middle District of Tennessee concluded in 9 Grae that a CW’s identity is protected work product. 326 F.R.D. at 487. The Court 10 reasoned that, because “[Plaintiff] assembled a wide array of information about 11 [Defendant’s] internal practices, [ ]business model, and [ ]public statements” in drafting 12 the complaint, and that Plaintiff’s counsel “presumably made innumerable decisions 13 about what information to include and how to convey that information” in meeting the 14 heightened pleading standards of the [PSLRA], that revealing the CW’s identity would 15 necessarily open “some window into the decision-making process of [Plaintiff’s] counsel 16 in drafting the [ ]Complaint.” Id. at 488. The Court rejected Defendant’s argument the 17 CW’s identity “would not reveal anything meaningful about [Plaintiff’s] litigation 18 strategy[,] . . .

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In re Carvana Co Securities Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-carvana-co-securities-litigation-azd-2025.