Kovalenko v. Kirkland & Ellis LLP

CourtDistrict Court, N.D. California
DecidedFebruary 16, 2024
Docket4:22-cv-05990
StatusUnknown

This text of Kovalenko v. Kirkland & Ellis LLP (Kovalenko v. Kirkland & Ellis LLP) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kovalenko v. Kirkland & Ellis LLP, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ZOYA KOVALENKO, Case No. 22-cv-05990-HSG (TSH)

8 Plaintiff, DISCOVERY ORDER 9 v. Re: Dkt. No. 113 10 KIRKLAND & ELLIS LLP, et al., 11 Defendants.

12 13 I. INTRODUCTION 14 This dispute arises out of Rule 45 subpoenas Defendant Kirkland & Ellis LLP (“K&E”) 15 issued to non-parties Fish & Richardson P.C. (“Fish”) and Paul Hastings LLP (“Paul Hastings”). 16 Plaintiff Zoya Kovalenko moves for an order quashing the subpoenas in their entirety and for a 17 protective order prohibiting the discovery sought. ECF No. 113. Defendants oppose the motion 18 to quash. ECF No. 122. Plaintiff filed a reply. ECF No. 123. The Court held a telephonic 19 hearing on February 15, 2024, and now issues this order. 20 II. BACKGROUND 21 The case arises out of Kovalenko’s employment as an associate at K&E from November 22 16, 2020, to September 28, 2021. ECF No. 94 at 3. In her First Amended Complaint (“FAC”), 23 Kovalenko alleges sex discrimination, including wrongful termination, under Title VII, the 24 California Fair Employment and Housing Act (“FEHA”), and the Federal Equal Pay Act; 25 retaliation under Title VII and FEHA; sex-based harassment constituting a hostile work 26 environment arising under Title VII; failure to prevent arising under FEHA; intentional infliction 27 of emotional distress; and defamation. See ECF No. 94 [FAC]. K&E has not filed an answer to 1 No. 102. On May 5, 2023, prior to serving Plaintiff with any written discovery requests, K&E 2 served Kovalenko with notices of intent to issue subpoenas to two law firms for which Kovalenko 3 had previously worked. ECF No. 113-1 (Decl. of Zoya Kovalenko) ¶¶ 4, 8, 10; ECF No. 122 at 4. 4 Kovalenko was employed in Fish’s Atlanta office as a summer associate in 2015 and as a patent 5 litigation associate from September 2016 to April 2018; she then worked as an IP litigation 6 associate in Paul Hastings’ Washington, D.C., office from May 2018 to November 2020. ECF 7 No. 122-2 at 3. 8 On May 15, 2023, Plaintiff wrote to K&E’s counsel to object to the subpoenas and to 9 request that they meet and confer. Kovalenko Decl. ¶ 12; ECF No. 122 at 5. After meeting and 10 conferring on May 31, 2023, the parties reached an impasse. Kovalenko Decl. ¶ 13; ECF No. 122 11 at 5. K&E served the subpoenas on Fish and Paul Hastings on July 13, 2023. ECF No. 122 at 5. 12 The parties submitted a joint discovery letter brief on July 24. ECF No. 83. After holding a 13 hearing on July 27, in which Plaintiff advised she intended to move for a protective order and to 14 quash the subpoenas, the Court stayed the subpoenas pending further order of the Court. ECF No. 15 88. K&E served Plaintiff with separate written discovery requests on August 8, 2023. ECF No. 16 122-1, Decl. of Kate Juvinall ¶ 10. 17 The subpoenas to Fish and Paul Hastings each include six identical requests for 18 documents, which fall into three broad categories: 1) personnel, compensation, and benefits 19 documents; 2) medical and disability-related documents; and 3) complaint and investigation files, 20 grievance files, and litigation documents involving Plaintiff. Kovalenko argues that the subpoenas 21 are unduly burdensome, are an unwarranted fishing expedition and irrelevant to Kovalenko’s 22 claims or to any defenses, that they violate her right to privacy under federal law, seek privileged 23 and protected materials, and that K&E served the subpoenas to harass and annoy Kovalenko. ECF 24 No. 113 at 3–4, 6–7, 16, 20. 25 There is currently no stipulated protective order in place. Defendants say they are willing 26 to keep documents produced by Fish and Paul Hastings confidential until the Court enters a 27 stipulated protective order, at which point Plaintiff can designate documents as confidential, III. LEGAL STANDARD 1 Federal Rule of Civil Procedure 26 provides that a party may obtain discovery “regarding 2 any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the 3 needs of the case[.]” Fed. R. Civ. P. 26(b)(1). Factors to consider include “the importance of the 4 issues at stake in the action, the amount in controversy, the parties’ relative access to relevant 5 information, the parties’ resources, the importance of the discovery in resolving the issues, and 6 whether the burden or expense of the proposed discovery outweighs its likely benefit.” Id. 7 Discovery need not be admissible in evidence to be discoverable. Id. However, “[t]he parties and 8 the court have a collective responsibility to consider the proportionality of all discovery and 9 consider it in resolving discovery disputes.” Fed. R. Civ. P. 26 advisory committee notes (2015 10 amendments). Thus, there is “a shared responsibility on all the parties to consider the factors 11 bearing on proportionality before propounding discovery requests, issuing responses and 12 objections, or raising discovery disputes before the courts.” Salazar v. McDonald’s Corp., 2016 13 WL 736213, at *2 (N.D. Cal. Feb. 25, 2016); Goes Int’l, AB v. Dodur Ltd., 2016 WL 427369, at 14 *4 (N.D. Cal. Feb. 4, 2016) (citing advisory committee notes for proposition that parties share a 15 “collective responsibility” to consider proportionality and requiring that “[b]oth parties . . . tailor 16 their efforts to the needs of th[e] case”). A court must also limit discovery if it is unreasonably 17 duplicative, or if it can be obtained from a source that is more convenient or less burdensome. 18 Fed. R. Civ. P. 26(b)(2)(C). 19 Rule 26(c) “confers broad discretion on the trial court to decide when a protective order is 20 appropriate and what degree of protection is required.” Seattle Times Co. v. Rhinehart, 467 U.S. 21 20, 36 (1984). “The court may, for good cause, issue an order to protect a party or person from 22 annoyance, embarrassment, oppression, or undue burden or expense,” including by (1) prohibiting 23 disclosure or discovery; (2) conditioning disclosure or discovery on specified terms; (3) 24 prescribing a discovery method other than the one selected by the party seeking discovery; or (4) 25 limiting the scope of disclosure or discovery to certain matters. Fed. R. Civ. P. 26(c)(1). 26 Federal Rule of Civil Procedure 45 governs motions to quash or modify a subpoena, and 27 provides that a court must modify or quash a subpoena that, inter alia, “fails to allow a reasonable 1 time to comply,” “requires a person to comply beyond the geographical limits specified in Rule 2 45(c),” “requires disclosure of privileged or other protected matter, if no exception or waiver 3 applies,” or “subjects a person to undue burden.” Fed. R. Civ. P. 45(d)(3)(A)(i–iv). “On a motion 4 to quash a subpoena, the moving party has the burden of persuasion under Rule 45[(d)](3), but the 5 party issuing the subpoena must demonstrate that the discovery sought is relevant.” Ow v. United 6 States, No. 17-0733-SK, 2018 WL 6267839, at *1 (quoting Chevron Corp. v. Donziger, No. 12- 7 mc-80237, 2013 WL 4536808, at *4 (N.D. Cal. Aug. 22, 2013)).1 8 IV. DISCUSSION 9 A. Plaintiff has standing to quash the subpoenas served on Fish and Paul Hastings.

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Seattle Times Co. v. Rhinehart
467 U.S. 20 (Supreme Court, 1984)

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Kovalenko v. Kirkland & Ellis LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kovalenko-v-kirkland-ellis-llp-cand-2024.