Knight Specialty Insurance Company v. Insa, Inc.

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 20, 2025
Docket4:24-cv-00465
StatusUnknown

This text of Knight Specialty Insurance Company v. Insa, Inc. (Knight Specialty Insurance Company v. Insa, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Knight Specialty Insurance Company v. Insa, Inc., (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA KNIGHT SPECIALTY INSURANCE No. 4:24-CV-00465 COMPANY, (Chief Judge Brann) Plaintiff,

INSA, INC., Defendant. WNSAING, Third Party Plaintiff,

QUADSCORE INSURANCE SERVICES, Third Party Defendant. MEMORANDUM OPINION May 20, 2025 I. BACKGROUND On August 23, 2023 a fire occurred at Insa, Inc.’s (“Insa”) marijuana cultivation facility; Knight Specialty Insurance Company (“Knight Specialty’) had previously issued a Commercial Property policy for this facility.! On March 18,

Compl., Doc. 1 § 1, 2, 9, 17.

2024, Knight Specialty commenced a declaratory judgment action against Insa,2 prompting Insa to file counterclaims against Knight Specialty and a third-party

complaint against Quadscore Insurance Services.3 Presently before the Court is Insa’s February 17, 2025 Motion to Compel Discovery.4 That motion is now ripe for disposition. The Court denies the motion in part and reserves judgment on the

remaining issues pending its in camera review of certain documents. II. STANDARD “Federal courts have broad discretion to determine the scope of discovery and to manage the discovery process.”5 “Federal Rule of Civil Procedure 37 governs

motions to compel discovery, and “[t]he scope of what type of discovery may be compelled under Rule 37 is defined, in turn, by”6 by Federal Rule of Civil Procedure 26, which provides:

Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information

2 Id. ¶¶ 30-39. 3 Third-Party Compl., Doc. 11; Answer with Counterclaim, Doc. 12. 4 Motion to Compel, Doc. 30. 5 Schiavone v. Luzerne Cty., 343 F.R.D. 34, 37 (M.D. Pa. 2023) (Mehalchick, C.M.J.) (citing Wisniewski v. Johns-Manville Corp., 812 F.2d 81, 90 (3d Cir. 1987)). 6 Schiavone, 343 F.R.D. at 37 (quoting Brewer v. Berks Cty. Sheriff, No. 13-5763, 2015 U.S. Dist. LEXIS 193191, 2015 WL 13620425, at *2 (E.D. Pa. Oct. 5, 2015)). within this scope of discovery need not be admissible in evidence to be discoverable.7 “The party seeking the discovery has the burden of clearly showing the relevancy of the information sought.”8 “If the moving party meets this initial burden,

the burden then shifts to the opposing party to demonstrate that the requested discovery (i) does not fall within the scope of discovery contemplated by Rule 26(b)(1) or (ii) is not sufficiently relevant to justify the burden of producing the information.”9

III. DISCUSSION At the outset, I note that Insa failed to follow the appropriate procedures when filing this motion. Federal Rule of Civil Procedure 16(b)(3)(B)(v) provides that a

“scheduling order may: . . . (v) direct that before moving for an order relating to discovery, the movant must request a conference with the court.”10 That is precisely what the Court’s September 25, 2024 Case Management Order has done.11 Despite this clear instruction, Insa immediately filed its Motion to Compel on February 17,

2025.

7 FED. R. CIV. P. 26. 8 Caver v. City of Trenton, 192 F.R.D. 154, 159 (D.N.J. 2000). 9 Atkinson v. Luitpold Pharms., Inc., 414 F. Supp. 3d 742, 744 (E.D. Pa. 2019). 10 FED. R. CIV. P. 16. 11 Case Management Ord., Doc. 29 (“If a discovery dispute arises, counsel shall electronically docket a letter apprising the Court of the dispute’s general contours. Upon receipt of that letter, the Court may schedule a conference if necessary. No discovery motions may be filed without express permission of the Court.”). This directive is not merely an arcane procedural requirement. These discovery conferences are “an efficient way to resolve most discovery disputes

without the delay and burdens attending a formal motion . . . .”12 This serves the dual purpose of preserving limited judicial resources and avoiding costly delays in the litigation. By directly filing its motion, Insa unnecessarily prolonged the time

required to resolve these disputes, as exemplified by Knight Specialty’s various concessions in its brief in opposition. Be that as it may, the Court will now resolve the Motion to Compel. A. Resolved Discovery Issues

1. Requests for Admission Numbers 1, 2, 3, 4, and 5 The disputes involving Requests for Admission Numbers 1, 2, 3, 4, and 5 have been resolved as Knight Specialty has agreed to provide these responses “at its earliest opportunity.”13

2. Requests for Production Numbers 13, 14, 15, and 16 Regarding Requests for Production Numbers 13, 14, 15, and 16, Knight Specialty agreed to produce these documents to the extent that it possesses

responsive documents subject to a confidentiality agreement. As such, the parties will be directed to file a stipulated confidentiality agreement. In its Reply Brief, Insa

12 FED. R. CIV. P. 16 advisory committee’s note (2015). 13 Brief in Opposition, Doc. 31 at 4. takes issue with “this caveat” of possession.14 Insa asserts this “provide[s] cover in the case that the handling adjuster cannot find” the documents at issue after asserting

that the responsive contracts “are clearly in Knight Specialty’s possession.”15 But Knight Specialty’s response adequately assures the Court it intends to cooperate with this request, and Insa’s seemingly unfounded concerns cannot overcome Knight

Specialty’s obligation to fulfill its representations to the Court. 3. Request for Production Number 20 In response to Request for Production Number 20, Knight Specialty asserts that it “does not have any documents responsive to the request seeking documents

which establish, show, and/or relate to Knight Specialty’s definition of the term ‘smoke detectors.’”16 Insa contends that “there is no evidence that Knight Specialty has undertaken any search of its documents beyond what is maintained in the claim

file” and that “[i]t will have coverage communications regarding the definition of ‘smoke detectors’ as this is a dispute that has undoubtedly arisen in previous claims.”17 Without any explanation from Insa as to why the Court should doubt Knight Specialty’s representation beyond mere speculation, I deny the Motion to

Compel as to this request for production.

14 Rely Brief, Doc. 32 at 2. 15 Id. 16 Doc. 31 at 6. 17 Doc. 32 at 2. 4. Request for Production Number 22 Request for Production Number 22 concerns “[d]ocuments and

communications that relate to the change from QS CP 10 01 06 22 in the 2022-2023 Policy to the QS CP 10 01 10 22 in the Policy at issue in this dispute.”18 Knight Specialty has indicated that Quadscore, “as the Managing General Agent,

underwrote the Knight Specialty Policy” and this request “is better directed to Quadscore, which is a party to this litigation.”19 Knight Specialty further asserts it “does not otherwise have documents responsive to this request.”20 After acknowledging that Quadscore’s possession of these documents would

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Knight Specialty Insurance Company v. Insa, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/knight-specialty-insurance-company-v-insa-inc-pamd-2025.