McCleary v. QCHC of Tennessee, PLLC

District Court, E.D. Tennessee·Decided September 4, 2025·No. 3:23-cv-00385·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

ESTATE OF JOSHUA S. MCCLEARY, ) B/N/K OMARII MCCLEARY, Son and ) Personal Representative of the Estate ) ) Plaintiff, ) ) v. ) No. 3:23-CV-385-CLC-DCP ) QCHC OF TENNESSEE, PLLC, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This case is before the undersigned pursuant to 28 U.S.C. § 636, the Rules of this Court, and Standing Order 13-02. Now before the Court is Plaintiff’s Motion for Sanctions Against Brent Plemons and Monroe County for Plemons’[s] Failure to Appear at His Deposition and Monroe County’s Failure to Supplement Discovery [Doc. 119].1 Defendant Monroe County, Tennessee, and Brent Plemons (collectively, “Defendants”) filed a response in opposition [Doc. 126]. Plaintiff filed a reply [Doc. 129]. The motion is ripe for adjudication. See E.D. Tenn. L.R. 7.1(a). For the reasons set forth below, the Court GRANTS IN PART AND DENIES IN PART the motion [Doc. 119]. I. BACKGROUND According to Plaintiff, Attorney K. Knight III (“Attorney Knight”) represents Monroe County, Tennessee (“Monroe County”), and the individual defendants, including Defendant Plemons [Doc. 119 p. 2]. “On May 23, 2025, Plaintiff’s counsel coordinated with defense counsel

1 The parties dispute whether Defendant Plemons has been sued in his individual or official capacity [See Docs. 144, 161, 178]. regarding deposition scheduling, [and Attorney] Knight confirmed that he and his clients, including Defendant Plemons, were available for depositions on June 9, 2025” [Id.]. Plaintiff states that on the same day, May 23, 2025, he “served a Rule 30 notice setting the deposition of Defendant Plemons for June 9, 2025” [Id.]. Plaintiff asserts that “[o]n the afternoon of June 6,

2025, three days before the scheduled deposition, [defense] counsel advised Plaintiff that Defendant Plemons had not responded to repeated efforts to contact him and that his current address and phone number were unknown” [Id. at 3]. Defendant Plemons did not appear for the June 9 deposition [id.], and Plaintiff filed the instant motion seeking terminating sanctions under Rule 37(d) and the Court’s inherent authority against Defendants [id. at 3–4]. Further, Plaintiff states that Defendant Monroe County failed to disclose that Defendant Plemons is no longer its employee [Id. at 6]. He claims that he “relied on the reasonable assumption that Monroe County, through its counsel, had access to and control over its former employee for litigation purposes” [Id.]. Because Defendant Monroe County did not supplement its disclosures under Rule 26(e), Plaintiff states that he was “prevented . . . from pursuing alternate means to secure [Defendant

Plemons’s] deposition before the close of discovery” [Id. at 7]. Defendants responded in opposition to the motion [Doc. 126]. They acknowledge that Defendant Plemons did not attend his deposition on June 9, 2025 [Id. at 1]. Defendants state that “[Defendant] Plemons worked for Monroe County as a sheriff’s deputy until his resignation in March 2024. He then worked private sector jobs[] but is presently and at the time of his previously- scheduled deposition was unemployed” [Id.]. Defendants submit that Attorney Knight “lost contact with [Defendant] Plemons after he left the employe[ment] of Monroe County, Tennessee” [Id.]. They assert that Defendant Plemons’s telephone number had changed and that his email address was inoperable and that no one employed with Monroe County “knew how to get in touch with [him]” [Id.]. Attorney Knight attempted to get into contact with Defendant Plemons when Attorney Knight told Plaintiff’s counsel he was available for depositions on June 9, 2025 [Id. at 2]. Attorney Knight was not able to get in touch with Defendant Plemons and told Plaintiff’s counsel of his inability to do so [Id.]. During the evening of June 9, 2025, Defendant Plemons

contacted Attorney Knight and “stat[ed] he was just notified that he may have been asked to give a deposition previously” [Id. (footnote omitted)]. The following day—the day after Plaintiff filed his motion—Attorney Knight informed Plaintiff’s counsel about Defendant Plemons’s contact with him [Id.]. The parties proceeded with Defendant Plemons’s deposition on June 28, 2025, along with two other witnesses [Id.]. Defendants state: [Defense] counsel and [Defendant] Plemons lost contact as a result of significant personal issues of [Defendant] Plemons including, but not limited to a severe motor vehicle accident which resulted in hospitalization. Simply put, [Defendant] Plemons did not appear at his June 9, 2025[,] deposition as he was unaware that it was to be taken at that time and date. [Defense counsel] had lost contact during the applicable time period with [Defendant] Plemons and therefore could not obtain his presence on that date.

[Id.].

Defendants claim that “not much was learned from [Defendant] Plemons’[s] deposition” [Id. at 3]. Other than booking Joshua McCleary, Defendants state that Defendant Plemons had no other contact with him and that “the intake documents that [Defendant] Plemons generated have already been produced to Plaintiff’s counsel” [Id.]. Defendants state that “[Defendant] Plemons did testify that he informed another Defendant, Ashley Brown, of [Joshua] McCleary’s condition,” but that she is “already a Defendant in the lawsuit” [Id.]. They acknowledge that “it is incumbent upon [defense counsel] and [Defendant] Plemons to remain in contact in the face of Plaintiff’s criticism, [but] not [Monroe County]” [Id.]. But regardless, they state that the deposition proceeded on June 28, 2025, and they request that the motion be denied [Id. at 3–4]. Plaintiff filed a reply, stating that “Defendant Plemons has offered no explanation for his failure to remain informed of this litigation or to remain in contact with [c]ounsel” and that “[Defendant] Monroe County offers no explanation of its efforts to maintain contact with Defendant Plem[]ons, despite not updating [its] discovery responses to disclose that he had left

employment” [Doc. 129 p. 1]. Plaintiff characterizes Defendant Plemons’s deposition testimony as “eye opening,” explaining that it “directly contravenes specific factual and legal positions taken by Monroe County” [Id.; see also id. at 2–3]. While Plaintiff acknowledges he took Defendant Plemons’s deposition on June 28, 2025, he states that he had “noticed the depositions of Defendants in chronological order relative to their interactions with [Joshua McCleary]” [Id. at 3]. And he claims that he could have used Defendant Plemons’s deposition testimony to impeach Defendant Ashley Brown on what occurred because she “testified that she was never informed by any correctional staff of the presence or existence of [Joshua] McCleary” [Id.]. Plaintiff states that his counsel sent emails to Attorney Knight on June 16 and June 28, 2025, in an attempt to resolve the instant motion [Id. at 3–4]. According to Plaintiff, “[n]either of

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