Lowe v. Haaland

District Court, E.D. California·Decided June 18, 2025·No. 2:24-cv-01689·Unknown

Opinion

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

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 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 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 to RFP No. 13. [See Exhibit 17]. In fact, many of the documents Defendant produced do not seem 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 that were password protected for reasons unknown, among other deficiencies. [See Exhibit 17]. Plaintiff reached out to Defendant’s counsel three times to request those passwords, and to notify him of the above-referenced deficiencies. [See Exhibit 12 and Exhibit 17]. Unfortunately, opposing counsel chose to ignore those communications. [See Exhibit 12 and Exhibit 17]. Therefore, Plaintiff granted multiple good faith extensions, and patiently awaited Defendant’s document production for over four months, only to be rewarded with a deficient production containing documents that were not provided in any reasonably useable form.

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

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

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Lowe v. Haaland, (E.D. Cal. 2025).

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