Ligeri v. Parker

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 BENJAMIN JOSEPH LIGERI, CASE NO. C25-0829-KKE 8

Plaintiffs, ORDER GRANTING DEFENDANTS’ 9 v. MOTION TO STAY DISCOVERY AND VACATE EARLY CASE DEADLINES 10 NATALIE PARKER, et al.,

11 Defendants.

12 Plaintiff Benjamin Joseph Ligeri, representing himself, filed this action in May 2025 13 claiming that Defendants (employees of and lawyers representing Amazon.com, Inc.) presented 14 false evidence to unfairly force him to arbitrate claims arising from the termination of certain third- 15 party selling accounts. See generally Dkt. Nos. 1, 7. On June 23, 2025, the Court entered an order 16 setting early case deadlines for the parties’ conference in accordance with Federal Rule of Civil 17 Procedure 26(f) (due July 14, 2025), the parties’ exchange of initial disclosures (due July 28, 18 2025), and the joint status report (due August 4, 2025). Dkt. No. 15. Defendants subsequently 19 filed a motion for expedited dismissal under Washington’s Uniform Public Expression Protection 20 Act along with a motion to stay discovery and vacate the early case deadlines, pending resolution 21 of the motion to dismiss. Dkt. Nos. 18–19. 22 Although Ligeri’s subsequent amendment of his complaint mooted Defendants’ motion to 23 dismiss, Defendants intend to re-file their motion to dismiss the amended complaint. See Dkt. No. 24 1 26 at 3. Thus, Defendants continue to request that the Court vacate the early case deadlines and 2 stay discovery because they characterize this action as based on unfounded conspiracy theories 3 and filed in order to abuse the legal system. See id. at 2. Defendants contend that staying discovery

4 will conserve judicial resources and avoid any burden on Defendants to respond to retaliatory 5 discovery requests while their forthcoming dispositive motion is pending. Id. at 2, 4. 6 Courts may enter protective orders to limit or prohibit discovery for good cause. See Fed. 7 R. Civ. P. 26(c). Good cause for a protective order can include the filing of a dispositive motion, 8 although that situation does not automatically require a discovery stay. See Morien v. Munich 9 Reinsurance Am., Inc., 270 F.R.D. 65, 66–67 (D. Conn. 2010). When determining whether to stay 10 discovery while a dispositive motion is pending, courts consider whether the defendant has “made 11 a strong showing that the plaintiff’s claim is unmeritorious; the breadth of discovery and the burden 12 of responding to it; and the risk of unfair prejudice to the party opposing the stay.” Id. at 67

13 (cleaned up). 14 As to the first consideration, the Court has reviewed Defendants’ mooted motion to dismiss 15 and finds that it presents multiple potential grounds for an expedited dismissal of Ligeri’s claims 16 as a strategic lawsuit against public participation. See Dkt. No. 19. Although that motion is now 17 moot, the Court agrees with Defendants that the core of Ligeri’s claims has not changed since he 18 amended the complaint. See Dkt. No. 26 at 3. Thus, the Court finds that the first factor weighs in 19 favor of a brief stay of discovery while Defendants’ forthcoming motion to dismiss is pending. 20 As to the second consideration, Defendants have explained how they expect discovery in 21 this case will be particularly burdensome because it will likely implicate issues of privilege. See 22 Dkt. No. 18 at 13.

23 And as to the third consideration, no unfair harm will result from a brief stay. Although 24 Ligeri filed an opposition to Defendants’ motion to stay discovery, he did not identify any unfair 1 prejudice that would result from a brief stay of discovery while the Court resolves Defendants’ 2 dispositive motion. Dkt. No. 21. Particularly because Ligeri has filed a motion for partial 3 summary judgment (Dkt. No. 25), it appears that a brief stay of discovery would not prejudice

4 Ligeri at this time. 5 On balance, the Court finds that the circumstances here warrant an exercise of discretion 6 to stay discovery until Defendants’ forthcoming motion to dismiss is resolved. See Chavous v. 7 Dist. of Columbia Fin. Resp. & Mgmt. Assistance Auth., 201 F.R.D. 1, 2 (D.D.C. 2001) (“A stay 8 of discovery pending the determination of a dispositive motion ‘is an eminently logical means to 9 prevent wasting the time and effort of all concerned, and to make the most efficient use of judicial 10 resources.’” (quoting Coastal States Gas Corp. v. Dep’t of Energy, 84 F.R.D. 278, 282 (D. Del. 11 1979))). 12 Accordingly, the Court therefore GRANTS Defendants’ motion to stay discovery and

13 vacate the initial case deadlines. Dkt. No. 18. Discovery is stayed until resolution of Defendants’ 14 forthcoming dispositive motion, and the order setting early case deadlines (Dkt. No. 15) is 15 VACATED. 16 Dated this 4th day of August, 2025. 17 A 18 Kymberly K. Evanson 19 United States District Judge

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