Kumar v. Nationwide Mutual Ins. Co.

CourtDistrict Court, E.D. California
DecidedJanuary 19, 2024
Docket2:23-cv-02312
StatusUnknown

This text of Kumar v. Nationwide Mutual Ins. Co. (Kumar v. Nationwide Mutual Ins. Co.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kumar v. Nationwide Mutual Ins. Co., (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 NALINI KUMAR and ALLEN SINGH, No. 2:23-cv-02312 DAD AC 12 Plaintiffs, 13 v. ORDER 14 NATIONWIDE MUTUAL INSURANCE COMPANY and DOES 1-10, 15 Defendants. 16 17 18 This matter is before the court on two separate discovery motions. First, plaintiffs move 19 to compel defendant to produce (1) documents in response to a request for production and (2) a 20 company witness to testify about its financial condition in response to a Rule 30(b)(6) subpoena. 21 ECF No. 84 (joint statement at ECF No. 91). Second, the defendant moves to compel compliance 22 with a third-party subpoena. ECF No. 93 (opposition at ECF No. 95, reply at ECF No. 96). 23 These discovery motions were referred to the magistrate judge pursuant to E.D. Cal. R. 302(c)(1). 24 Each motion was taken under submission and heard on the papers. ECF Nos. 87, 94. 25 I. Relevant Background 26 Plaintiffs purchased an insurance policy from Nationwide to insure against risk of loss to 27 their dwelling property. ECF No. 1 at 2. On or about July 4, 2020, the property was destroyed by 28 a fire, and plaintiffs filed a claim for insurance coverage. Id. at 3. Plaintiffs allege that they 1 satisfied all conditions under the policy for payment of the claim. Id. at 3-5. The resulting 2 interactions between the parties lead plaintiffs to bring this case seeking legal relief for 3 defendant’s alleged breach of contractual duty to pay a covered claim, insurance bad faith, 4 negligent failure to obtain insurance coverage, and negligent misrepresentation. Id. at 13-20. 5 Plaintiffs seek monetary recovery, including punitive damages. Id. at 20. 6 II. Timeliness of Defendant’s Motion 7 Plaintiffs originally filed this case in the Northern District of California, and it was 8 transferred to this court on October 12, 2023. ECF Nos. 1, 78. Prior to transfer, the Northern 9 District set a case schedule that provided a December 1, 2023 date for close of fact discovery. 10 ECF No. 55 at 2. Following the transfer, an initial status conference was set before District Judge 11 Dale A. Drozd but was subsequently vacated and is currently set to take place before the 12 undersigned on March 3, 2024. ECF Nos. 88, 89. Thus, as of the drafting of this order, fact 13 discovery is closed and can only be re-opened by an order of the court. In its moving papers, 14 defendant acknowledges that fact discovery closed on December 1, 2023. ECF No. 93 at 2. 15 Defendant filed its motion to compel on November 29, 2023 and, in accordance with 16 Local Rule 230(a), noticed the motion to be heard on January 10, 2024. ECF No. 93. Per the 17 practices of the Eastern District of California, a motion set to be heard after the discovery 18 deadline is untimely. Pretrial scheduling orders issued in this district regularly contain language 19 specifying that discovery must be “completed” by the deadline, and that “completed’ means that 20 all discovery shall have been conducted so that all depositions have been taken and any disputes 21 relative to discovery shall have been resolved by appropriate order if necessary and, where 22 discovery has been ordered, the order has been obeyed. However, no such pretrial scheduling 23 order was issued in this case, and there is no Local Rule in this district clearly stating whether a 24 discovery motion must be heard before the discovery cutoff, or simply filed before the discovery 25 cutoff. 26 Defendant points the court to the Northern District of California’s Civil Local Rule 37-3, 27 which states that the deadline to move to compel is seven days after the discovery cutoff. See 28 Zeleny v. Newsom, No. 17-CV-07357-RS (TSH), 2020 WL 6585793, *2, 2020 U.S. Dist. LEXIS 1 210458, *6 (N.D. Cal. Nov. 10, 2020). The undersigned notes although this is not the rule or 2 practice in this court, and will not be the rule in this case going forward, because of the unique 3 circumstances of this case, the impact of the discovery deadline was unclear. Thus, the court will 4 consider defendant’s motion as timely filed. The court turns to the merits of each motion. 5 III. Motions to Compel 6 A. Standard on Motion to Compel 7 The scope of discovery in federal cases is governed by Federal Rule of Civil Procedure 8 26(b)(1). The current Rule states: 9 Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged 10 matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of 11 the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, 12 the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely 13 benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable. 14 15 Fed. R. Civ. P. 26(b)(1). Evidence is relevant if: (a) it has any tendency to make a fact more or 16 less probable than it would be without the evidence; and (b) the fact is of consequence in 17 determining the action. Fed. R. Evid. 401. Relevancy to the subject matter of the litigation “has 18 been construed broadly to encompass any matter that bears on, or that reasonably could lead to 19 other matter that could bear on, any issue that is or may be in the case.” Oppenheimer Fund, Inc. 20 v. Sanders, 437 U.S. 340, 351 (1978). Relevance, however, does not establish discoverability; in 21 2015, a proportionality requirement was added to Rule 26. Under the amended Rule 26, 22 relevance alone will not justify discovery; discovery must also be proportional to the needs of the 23 case. 24 A party seeking to compel discovery has the initial burden to establish that its request is 25 proper under Rule 26(b)(1). If the request is proper, the party resisting discovery has the burden 26 of showing why discovery was denied; they must clarify and support their objections. 27 Blankenship v. Hearst Corp., 519 F.2d 418, 429 (9th Cir.1975). General or boilerplate objections, 28 without explanation, are not prohibited but are insufficient as a sole basis for an objection or 1 privilege claim. Burlington Northern & Santa Fe Ry. v. United States Dist. Court, 408 F.3d 1142, 2 1149 (9th Cir.2005). 3 B. Plaintiff’s Motion to Compel 4 Plaintiff seeks to compel discovery with respect to two issues. First, plaintiff seeks to 5 compel a further response to a request for production and request for an additional deposition 6 regarding Nationwide’s practice of conducting missed opportunity reviews. ECF No. 91 at 7. 7 The request and response are as follows: 8 PLAINTIFFS’ DOCUMENT REQUEST NO. 40: 9 DOCUMENTS pertaining to YOUR practice of conducting “Missed Opportunity Reviews” of claims under policies of insurance issued 10 by YOU. 11 NATIONWIDE’S RESPONSE TO REQUEST NO. 12 Nationwide incorporates by reference each of the General Objections stated herein. Nationwide further objects to this request on the 13 grounds that it is overbroad, vague, and ambiguous as to time period and meaning, and is therefore unduly burdensome.

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Kumar v. Nationwide Mutual Ins. Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kumar-v-nationwide-mutual-ins-co-caed-2024.