Lowe v. Haaland

CourtDistrict Court, E.D. California
DecidedJune 18, 2025
Docket2:24-cv-01689
StatusUnknown

This text of Lowe v. Haaland (Lowe v. Haaland) 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
Lowe v. Haaland, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 CASEY LOWE, No. 2:24-cv-01689-DMC 12 Plaintiff, 13 v. ORDER 14 DEBRA A. HAALAND, 15 Defendant. 16 17 Plaintiff, who proceeds pro se, brings this civil action. Pursuant to the written 18 consent of all parties, this case is before the undersigned as the presiding judge for all purposes, 19 including entry of final judgment. See 28 U.S.C. § 636(c); see also ECF No. 10 (minute order 20 reassigning action). Pending before the Court is Plaintiff’s motion to compel. See ECF No. 19. 21 22 I. BACKGROUND 23 Initial disclosures were due by October 16, 2024 and non-expert discovery closes 24 November 7, 2025. See ECF No. 17. Parties participated in an informal discovery conference on 25 February 18, 2025. See ECF No. 18. There, parties agreed to meet and confer and conduct 26 informal conferences between themselves before filing motions to compel. Plaintiff filed the 27 motion to compel on May 2, 2025. See ECF No. 19. Generally, Defendant contends that this 28 motion is premature because Plaintiff did not attempt to resolve the issue with Defendant before 1 filing this motion. See ECF No. 20, pg. 4. Additionally, Defendant shared that the “attorney 2 previously assigned to this matter elected in about mid-April 2025 to participate in the Deferred 3 Resignation Program. The matter has now been reassigned but the remaining attorneys have 4 been impacted by the DRP and has again delayed response.” Id. 5 Plaintiff asserts a number of objections to specific responses to Plaintiff’s 6 discovery requests, discussed in detail below. Plaintiff contends that Defendant has acted in bad 7 faith throughout discovery by “abus[ing] Plaintiff’s good will by breaking specific commitments 8 to Plaintiff, doubling down on demonstrably provable falsehoods, burdening Plaintiff with a 9 deficient document production, and making a mockery of the meet and confer process.” ECF No. 10 20, pg. 33. To remedy this, Plaintiff requests attorneys fees of $4,725 for the 18.9 hours Plaintiff 11 spent “in meeting and conferring (including the IDC), drafting a ten-page meet and confer letter, 12 researching and drafting the instant motion and joint statement, preparing for the subsequent 13 hearing, as well as drafting dozens of correspondences to Defendant, most of which were 14 ignored.” Id. Plaintiff additionally requests sanctions pursuant to Rule 37. Defendant contends 15 that Plaintiff filed this motion prematurely and fails to show any further response should be 16 compelled. See id. 17 A. Availability of Attorney’s Fees for Pro Se Litigants 18 Plaintiff contends that awarding attorney’s fees to pro se litigants is within the 19 court’s inherent power, citing two Eastern District orders in support. See ECF No. 20, pg. 32 20 (2:24-cv-1689-DMC) (citing Jacobs v. Scribner, No. 1:06-cv-01280-AWI-GSA-PC, 2011 U.S. 21 Dist. LEXIS 4297, at *2-3 (E.D. Cal. Jan. 11, 2011) and Timberland v. Mascarenas, No. 1:16-cv- 22 00922-, 2020 U.S. Dist. LEXIS 47228, at *7-8 (E.D. Cal. Mar. 18, 2020). In Timberland, the 23 Court found that 24 with respect to pro se litigants, including those that are licensed attorneys, the 25 general rule is that attorneys’ fees are not a payable ‘expense’ under Rule 37 ‘as there is no direct financial cost or charge associated with the expenditure of one's 26 own time’ . . . the ‘reasonable expenses’ awardable under Rule 37 do include, however, ‘actual costs incurred as a result of misconduct.’ 27 Id. (quoting Pickholtz v. Rainbow Techs., Inc., 284 F.3d 1365, 1375 (Fed. Cir. 28 2002). 1 Thus, Plaintiff is not entitled to attorney’s fees and the undersigned will deny 2 Plaintiff’s request to award attorney’s fees. 3 B. Format Dispute 4 Plaintiff contends that when Defendant produced responsive documents on April 5 23, 2025, the production

6 consisted of nearly 12,000 pages with no coherent organization whatsoever. [See Exhibit 17]. Defendant did not provide an index, nor did Defendant organize the 7 documents into folders corresponding to the request numbers. [See Exhibit 17]. On the contrary, all of the documents were placed in only two folders, both of which 8 were labelled as responsive to Request for Production (“RFP”) No. 13, despite the vast majority of those documents’ content indicating that they were not responsive 9 to RFP No. 13. [See Exhibit 17]. In fact, many of the documents Defendant produced do not seem 10 responsive to any of Plaintiff’s requests. [See Exhibit 17]. That production included seven copies of the same 13-page document, as well as numerous files 11 that were password protected for reasons unknown, among other deficiencies. [See Exhibit 17]. Plaintiff reached out to Defendant’s counsel three times to request 12 those passwords, and to notify him of the above-referenced deficiencies. [See Exhibit 12 and Exhibit 17]. Unfortunately, opposing counsel chose to ignore those 13 communications. [See Exhibit 12 and Exhibit 17]. Therefore, Plaintiff granted multiple good faith extensions, and patiently 14 awaited Defendant’s document production for over four months, only to be rewarded with a deficient production containing documents that were not provided 15 in any reasonably useable form.

16 ECF No. 20, pg. 3. 17 The Court will not accommodate any disputes between parties that can easily be 18 resolved if handled with professionalism and cooperation. Neither side is obligated to do work for 19 the other in terms of labeling and organizing files, but the baseline expectation is to produce all 20 non-privileged responsive documents in the form they are kept and of course, parties must 21 provide the necessary passwords to access the documents. Deviation from these baseline 22 expectations will not be tolerated and may result in sanctions going forward.

23 C. Footnotes 24 Plaintiff contends that, in a number of their responses, Defendant deleted the 25 footnotes Plaintiff had in the original requests and then, Defendant responded claiming that the 26 Interrogatory lacked context necessary for Defendant to respond. See ECF No. 20, pgs. 10-14; 27 18-19 and 23. This is asserted for Interrogatory Nos. 5, 6, 7, and 15. See id. Defendant did not 28 1 admit to this but, most of their supplemental responses raise other concerns or respond to the 2 interrogatory. See id. at 11-12, 14 and 19. Similarly, Plaintiff asserts that Defendant deleted a 3 footnote when responding to Interrogatory No. 11 and then claimed that the interrogatory 4 “assumes facts not in evidence,” when, according to Plaintiff, the citation provided the evidence 5 Defendant needed. Id. at 18-19. Plaintiff contends that “quite frankly, intentionally deleting a 6 citation to specific evidence supporting an interrogatory, and then claiming, ‘there is no evidence’ 7 supporting that interrogatory is so unconscionable in Plaintiff’s estimation, that it constitutes a 8 fraud upon the court.” Id. at 19. 9 Typically, when crafting interrogatories, the question should be complete on its’ 10 own and an interrogatory should not rely on footnotes. Plaintiff is advised that breaking the 11 requests down into multiple steps, each request referring and building off one another, is best 12 practice to ensure your requests are clear in and of themselves. There is nothing to indicate that 13 the removal of the footnotes was intentional, or not otherwise resolved in subsequent 14 supplemental responses, as any such removal was apparently done by Defendant’s prior counsel. 15 Thus, the undersigned does not find this conduct amounts to bad faith nor would sanctions be 16 appropriate given the change of counsel. 17 D.

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Lowe v. Haaland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lowe-v-haaland-caed-2025.