LD v. United Behavioral Health

CourtDistrict Court, N.D. California
DecidedSeptember 21, 2022
Docket4:20-cv-02254
StatusUnknown

This text of LD v. United Behavioral Health (LD v. United Behavioral Health) 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
LD v. United Behavioral Health, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 LD, et al., 7 Case No. 20-cv-02254-YGR (JCS) Plaintiffs, 8 ORDER GRANTING PLAINTIFFS’ v. MOTION FOR SANCTIONS AGAINST 9 UNITED DEFENDANTS PURSUANT UNITED BEHAVIORAL HEALTH, et al., TO FED.R.CIV.P. 37 10 Defendants. Re: Dkt. No. 165 11

12 13 I. INTRODUCTION 14 This Order addresses only Plaintiffs’ request for sanctions against the United Defendants 15 in their Motion to Compel and for Sanctions Pursuant to Fed.R.Civ.P. 37 (“Motion”). The 16 remaining issues raised in the Motion, seeking relief with respect to Defendant MultiPlan, will be 17 addressed in a separate Order. The Court held a hearing on September 20, 2022 addressing 18 Plaintiffs’ request, which is GRANTED. 19 II. BACKGROUND 20 In the Motion, Plaintiffs ask the Court to prohibit United from using 21,812 documents, 21 104 audio records and an Excel spreadsheet listing 2,021 new class member claims, on the basis 22 that these materials were produced after the July 15, 2022 fact discovery cut-off in attempt to 23 sandbag Plaintiffs just before the deadline for filing their class certification motion and deprive 24 them of the opportunity to address the late-produced materials in depositions. United counters that 25 it produced these materials after the deadline merely to supplement its previous productions and 26 therefore was substantially justified in producing these materials when it did, and that Plaintiffs 27 were not prejudiced by the late production. 1 discovery, including verification of benefits (“VOB”) call recordings, for a sample of class 2 members selected by Plaintiffs – initially 87 individuals but eventually negotiated down to 25 3 individuals – and United’s decision to create its own sample of class members, purportedly 4 because United realized at some point that Plaintiffs’ sample was not randomly selected. 5 The parties paint widely different pictures of the events that preceded United’s late 6 productions. Because the imposition of sanctions depends, in part, on whether United’s conduct 7 was justified and whether it acted in good faith, which are fact-intensive inquiries, the Court 8 provides below a timeline of the parties’ communications and discovery conduct related to the two 9 samples (hereinafter, “Plaintiffs’ Sample” and “United’s Sample”). The Court notes that the record 10 does not contain every relevant document and communication exchanged during discovery and 11 therefore, it has relied to some extent on the second-hand accounts in the parties’ briefs and 12 communications, at least as to the underlying facts that appear to be undisputed. Where there 13 appear to be disputes about what actually occurred, the Court has attempted to flag those disputes. 14 November 19, 2021: According to United, on this date it made its first production of 15 claims data, which included documents responsive to certain requests in Plaintiffs’ First, Second 16 and Third Sets of requests for documents. Blas Decl. ¶ 10 & Ex. 1 [Dkt. 174-1, 174-2] (November 17 19, 2021 letter from United re production). In a letter that accompanied the production, United’s 18 counsel indicated that United was unsure if Plaintiffs’ claims included claims that had been 19 subject to fee negotiation, stating, “For purposes of this production, we are also including claim 20 lines subject to Viant fee negotiation, even though Plaintiffs have not clearly indicated whether 21 these claim lines and amounts are at issue in the case, because we understand from your request 22 that you want these claim lines to be produced.” Id. 23 January 3, 2022: According to United, on this date, “after meeting and conferring with 24 Plaintiffs, United Defendants made a supplemental production to include additional data fields that 25 were not in their initial production.” Blas Decl. ¶ 10 [Dkt. 174-1]. 26 January 27, 2022: According to United, on this date, Plaintiffs served requests for 27 production of call recordings for 87 sample patients. United Opp. at 4 [Dkt. 174]. This was 1 Plaintiffs’ Sample. 2 February 14, 2022: According to United, on this date it told Plaintiffs in a meet and 3 confer that it would be extremely difficult to locate the VOB audio recordings. [Dkt. 159-5] (June 4 1, 2022 meet and confer letter from United’s counsel to Plaintiffs’ counsel). 5 February 28, 2022: United’s counsel sent Plaintiffs’ counsel an email again telling 6 Plaintiffs that it would be extremely difficult to locate the audio recordings Plaintiffs had 7 requested. Reply, Ex. E [Dkt. 175-5] (email from United’s counsel to Plaintiffs’ counsel). In the 8 same email, United told Plaintiffs it needed specific information to track down the audio 9 recordings, stating: “As previously discussed (and as our client confirmed following our Feb 14 10 meet and confer), we need the date/time and incoming phone number (and the customer service 11 agent’s name and customer service agent’s MS ID should be provided as well, if available) to 12 search for any call recordings that may exist. As we also discussed, it is burdensome and time- 13 consuming to search for these records, so please get us this specific information as soon as 14 possible—regarding 25 specific phone calls that we can prioritize in our searches—so that we can 15 investigate what is available and could potentially be produced.” Id. 16 March 25, 2022: According to United, it again told Plaintiffs in a meet and confer that it 17 would be very difficult to locate the audio recordings for Plaintiffs’ Sample. [Dkt 159-5] (June 1, 18 2022 meet and confer letter from United’s counsel to Plaintiffs’ counsel). 19 April 20, 2022: Plaintiffs agreed to reduce their sample in connection with their audio 20 recording request to 25 patients and provided United with a chart identifying the 25 sample 21 members. United Opp. at 4 [Dkt. 174].1 Also on this date, Plaintiffs’ counsel sent United an email 22 with an attachment containing information to help locate the audio recordings, apparently in 23 response to United’s previous requests, including in the February 28, 2022 email discussed above. 24 Blas Dec., Ex. 2 [Dkt. 174-3] (April 20, 2022 email from Plaintiffs’ counsel to United’s counsel). 25 Plaintiffs’ counsel said in the email that “[t]he information that is there has not been easy to obtain 26 and we wanted to provide you with what we do have to move this process forward.” Id. 27 1 Plaintiffs’ counsel also suggested in the email that United might not need all of the information it 2 had requested to locate the recordings, stating: “In other litigation involving United, we have 3 found that it was not necessary to have the time of the call as long as we had the date. Even if that 4 were to pull some recordings for those other than the identified patients, the number would still be 5 limited and manageable and, most likely, would be of another putative class member in any 6 event.” Id. 7 April 26, 2022: Plaintiffs’ counsel sent United’s counsel another email, again attempting 8 to comply with United’s request for specific information to help locate the audio recordings. Blas 9 Decl., Ex. 3 [Dkt. 174-4] (April 26, 2022 email from Plaintiffs’ counsel to United’s counsel). In 10 this email, Plaintiffs’ counsel stated, “As we discussed earlier, getting the information that we sent 11 was difficult. Please let us know if this is problematic and we are happy to work with you to figure 12 something out.” Id. 13 May 4, 2022: Plaintiffs served their Sixth Request for Production (“RFP”) on United, 14 seeking complete administrative record, including claims and plan information, for each of the 25 15 sample class members selected by Plaintiffs. [Dkt. 165-3] (Sixth RFP).

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LD v. United Behavioral Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ld-v-united-behavioral-health-cand-2022.