LD v. United Behavioral Health

District Court, N.D. California·Decided October 3, 2022·No. 4:20-cv-02254·Unknown

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 v. ORDER RE MOTION TO COMPEL 9 (MULTIPLAN) UNITED BEHAVIORAL HEALTH, et al., 10 Re: Dkt. No. 165 Defendants. 11

12 13 I. INTRODUCTION 14 In its September 21, 2022 Order [dkt. 192], the Court ruled on Plaintiffs’ request for 15 preclusion sanctions against the United Defendants in their Motion to Compel and for Sanctions 16 Pursuant to Fed.R.Civ.P. 37 (“Motion”). In this Order, the Court addresses the remaining issues 17 raised in the Motion, which relate to the adequacy and timeliness of Defendant MultiPlan’s 18 privilege log, which was produced to Plaintiffs on July 22, 2022. The Court held a hearing on 19 September 30, 2022 to address these issues. Its rulings and guidance are set forth below. 20 II. BACKGROUND 21 The discovery disputes addressed in this Order were first raised in the parties’ July 31, 22 2022 joint discovery letter [dkt. 159], which also addressed discovery disputes with the United 23 Defendants. In its August 4, 2022 Order [dkt. 161], the Court found that a number of the issues 24 raised in the letter were untimely and that Plaintiffs had not shown good cause for the delay. This 25 included Plaintiffs’ challenge to a clawback demand by MultiPlan at a July 14, 2022 deposition.1 26 1 Based on its consideration of the papers filed in connection with the instant Motion, the Court 27 RECONSIDERS its prior holding as to the timeliness of Plaintiffs’ challenge to MultiPlan’s 1 On the other hand, the Court found that there was good cause for the delay as to, inter alia, 2 Plaintiffs’ challenge to the adequacy of MultiPlan’s privilege log. The Court therefore ordered 3 full briefing on that dispute, ordering Plaintiffs to file a motion to compel by August 11, 2022. 4 In the meantime, on August 5, 2022, the Court issued an order containing rulings and 5 guidance in connections with a similar challenge to privilege logs produced by the United 6 Defendants, which was first raised in a joint discovery letter filed on July 1, 2022 and was the 7 subject of Plaintiffs’ July 8, 2022 motion to compel [dkt. 144]. Plaintiffs and United have been 8 meeting and conferring in connection with their privilege dispute since the issuance of the August 9 5, 2022 Order in an effort to narrow or resolve their privilege disputes. 10 In the Motion, Plaintiffs assert the late production of MultiPlan’s privilege log – a week 11 after the July 15, 2022 discovery cut-off and many months after MultiPlan’s first production of 12 documents, in March 2022 – should be found to have resulted in waiver of any privilege or work 13 product protections claimed by MultiPlan under the test set forth in Burlington N. & Santa Fe Ry. 14 Co. v. U.S. Dist. Court for Dist. of Mont., 408 F.3d 1142, 1149 (9th Cir. 2005). Motion at 7-11. 15 Plaintiffs argue, in the alternative, that MultiPlan’s privilege log does not contain sufficient 16 information from which to establish that the withheld documents are privileged and in some cases, 17 suggests MultiPlan has improperly withheld documents that are primarily for a business purpose 18 or are subject to the fiduciary exception to attorney-client privilege.2 Id. at 11-16. Plaintiffs 19 further contend that MultiPlan’s assertions of protection under the work product doctrine also fail 20 as MultiPlan has not provided facts showing that these documents were prepared specifically in 21 anticipation of litigation. Id. at 16-17. 22 In its Opposition, MultiPlan rejects Plaintiffs’ assertion that it has waived privilege and 23 work product protection under Burlington due to its delay in producing its privilege log. 24

25 documents for the first time on the privilege log that was provided to Plaintiffs on July 22, 2022. Therefore, the Court’s finding that there was good cause to consider the arguments related to the 26 late privilege log generally also applies to the clawback documents. The Court’s rulings and guidance herein thus does not exclude those documents. 27 2 The Court addressed the primary purpose doctrine and the fiduciary exception to attorney client 1 MultiPlan Opposition at 3-7. It further contends it has adequately supported its claims of privilege 2 and work product protection, both in its privilege log and based on a declaration by Marjorie 3 Wilde, Senior Counsel for MultiPlan, filed in support of MultiPlan’s Opposition. Id. at 7-10. 4 MultiPlan argues that the primary purpose doctrine does not apply to the documents it has 5 withheld and that as to the documents withheld as work product, “it is apparent from the 6 documents themselves (as well as from the Declaration of Ms. Wilde), that they were created for 7 or in anticipation of litigation.” Id. at 7. Furthermore, MultiPlan asserts, work product protection 8 applies to anticipated litigation regardless of “whether the litigation is judicial or administrative in 9 nature.” Id. As to the fiduciary exception, MultiPlan argues that it is not applicable because the 10 Second Amended Complaint does not contain specific allegations indicating that MultiPlan is an 11 ERISA fiduciary. Id. at 8. 12 III. ANALYSIS 13 A. Legal Standards 14 A party asserting privilege must “describe the nature of the documents . . . in a manner 15 that, without revealing information itself privileged or protected, will enable other parties to assess 16 the claim.” Fed. R. Civ. P. 26(b); see also Burlington N. & Santa Fe Ry. Co. v. U.S. Dist. Court 17 for Dist. of Mont., 408 F.3d 1142, 1148 (9th Cir. 2005) (a party claiming privilege must “provide 18 sufficient information to enable other parties to evaluate the applicability of the claimed privilege 19 or protection”). Typically, this is done using a privilege log that identifies “(a) the attorney and 20 client involved, (b) the nature of the document, (c) all persons or entities shown on the document 21 to have received or sent the document, (d) all persons or entities known to have been furnished the 22 document or informed of its substance, and (e) the date the document was generated, prepared, or 23 dated.” In re Grand Jury Investigation, 974 F.2d 1068, 1071 (9th Cir. 1992). However, a party 24 may also substantiate a claim of privilege by other means, including declarations that “establish 25 the purpose of the communication or the specific role of the sender and each individual recipient.” 26 Apple Inc. v. Samsung Elecs. Co., 306 F.R.D. 234, 237 (N.D. Cal. 2015). 27 Under Rule 34 of the Federal Rules of Civil Procedure, a party has 30 days from service to 1 Circuit has held that the 30-day time limit for responding to document requests serves as a 2 “default guideline” for service of a privilege log or other disclosure that satisfies the requirements 3 of Rule 26(b)(5)(A). Burlington N. & Santa Fe Ry. Co. v. U.S. Dist. Ct. for Dist. of Mont., 408 4 F.3d 1142, 1149 (9th Cir. 2005). In Burlington, the court explained that the 30-day guideline does 5 not establish a “a per se waiver rule that deems a privilege waived if a privilege log is not 6 produced within Rule 34’s 30-day time limit.” Id.

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