Mike's Novelties, Inc. v. PIV Enterprises, Inc.

CourtDistrict Court, E.D. California
DecidedMay 12, 2025
Docket1:23-cv-01309
StatusUnknown

This text of Mike's Novelties, Inc. v. PIV Enterprises, Inc. (Mike's Novelties, Inc. v. PIV Enterprises, Inc.) 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
Mike's Novelties, Inc. v. PIV Enterprises, Inc., (E.D. Cal. 2025).

Opinion

7 UNITED STATES DISTRICT COURT 8 9 EASTERN DISTRICT OF CALIFORNIA 10 MIKE’S NOVELTIES, INC., Case No. 1:23-cv-01309-JLT-SAB 11 Plaintiff, ORDER RE JOINT STATEMENT OF 12 DISCOVERY DISAGREEMENT v. 13 (ECF Nos. 33, 35) PIV ENTERPRISES, INC., 14 TWENTY-ONE DAY DEADLINE Defendant. 15 16 Currently before the Court is the parties’ Joint Statement of Discovery Disagreement, 17 which the Court construes as Defendant and Counterclaim Plaintiff PIV Enterprises, Inc.’s 18 (“PIV”) motion to compel Plaintiff and Counterclaim Defendant Mike’s Novelties, Inc.’s 19 (“MNI”) further responses to PIV’s amended written discovery requests.1 Specifically, PIV 20 requests that the Court (1) overrule each of MNI’s objections and compel responses to PIV’s 21 First Amended Requests for Production and First Amended Interrogatories; (2) deem MNI’s 22 response to Request for Admission No. 9 admitted; and (3) compel MNI to produce documents 23 responsive to all of PIV’s Amended Requests for Production of Documents. The Court finds this 24 matter suitable for decision without oral argument. Having considered the informal letter brief, 25 the joint statement of discovery disagreement, as well as the Court's file, the Court issues the 26 following order.

27 1 The parties initially filed a four-page joint discovery dispute letter brief. However, after review of the parties’ informal letter brief, the Court vacated the informal discovery conference and requested that the parties provide 1 I. 2 LEGAL STANDARD 3 Unless otherwise limited by court order, a party “may obtain discovery regarding any 4 nonprivileged matter that is relevant to any party’s claim or defense and proportional to the 5 needs of the case, considering the importance of the issues at stake in the action, the amount in 6 controversy, the parties’ relative access to relevant information, the parties’ resources, the 7 importance of the discovery in resolving the issues, and whether the burden or expense of the 8 proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). “Evidence is relevant 9 if: (a) it has any tendency to make a fact more or less probable than it would be without the 10 evidence; and (b) the fact is of consequence in determining the action.” Fed. R. Evid. 401. 11 Disclosures and discovery are governed by the Federal Rules of Civil Procedure. See Fed. R. 12 Civ. P. 26-37. 13 After being served with interrogatories, requests for production, or requests for 14 admission, the responding party must serve its answers and any objections within 30 days. Fed. 15 R. Civ. P. 33(b)(2), 34(b)(2)(A), 36(a)(3). The failure to timely respond to discovery requests 16 will generally constitute a waiver of any objections thereto. See Fed. R. Civ. P. 33(b)(4) (“Any 17 ground not stated in a timely objection [to an interrogatory] is waived unless the court, for good 18 cause, excuses the failure”); Ramirez v. Cty. of Los Angeles, 231 F.R.D. 407, 409 (C.D. Cal. 19 2005). “Although Rule 34 does not contain an express provision that untimely objections are 20 waived, courts have interpreted the rule regarding waiver consistent with Rule 33.” Sicilia v. 21 State Farm Mut. Auto. Ins. Co., No. 214-CV-00812 GMN GWF, 2015 WL 3448680, at *3 (D. 22 Nev. May 29, 2015) (citations omitted). 23 If the responding party fails to serve a timely response to a request for admission, the 24 matter is deemed admitted. Fed. R. Civ. P. 36(a)(3). Once admitted, the matter is “conclusively 25 established unless the court, on motion, permits the admission to be withdrawn or amended. 26 Fed. R. 36(b). “Subject to Rule 16(e), the court may permit withdrawal or amendment if it 27 would promote the presentation of the merits of the action and if the court is not persuaded that it 1 R. Civ. P. 36(b). “Trial courts [have been] advised to be cautious in exercising their discretion to 2 permit withdrawal or amendment of an admission.” Conlon v. United States, 474 F.3d 616, 621 3 (9th Cir. 2007) (quoting 999 v. C.I.T. Corp., 776 F.2d 866, 869 (9th Cir. 1985)). 4 III. 5 DISCUSSION 6 A. Amended Request for Production of Documents and Interrogatories 7 PIV argues MNI’s objections to PIV’s First Amended Request for Production 8 (“Amended RFP”) and First Amended Interrogatories (“Amended ROGS”) are waived because 9 MNI failed to timely respond to the discovery requests. PIV contends Amended RFP Nos. 1-19, 10 27-29, and 36 and Amended ROG Nos. 6-8, 10-13, and 15-16 are at issue. 11 “It is well established that a failure to object to discovery requests within the time 12 required constitutes a waiver of objection.” Bryant v. Armstrong, 285 F.R.D. 596, 602 (S.D. 13 Cal. 2012) (quoting Richmark Corp. v. Timber Falling Consultants, 959 F.2d 1468, 1473 (9th 14 Cir. 1992)). Generally, in the absence of an extension of time or good cause, the failure to object 15 to discovery requests within the time provide constitutes a waiver and “[t]his is true even of an 16 objection that the information sought is privileged.” Davis v. Fendler, 650 F.2d 1154, 1160 (9th 17 Cir. 1981). “Where a waiver of objections by failure to serve a timely response has been found, 18 it usually has been because the party required to serve a response failed to make any response 19 whatsoever within the time allowed.” Safeco Ins. Co. of Am. v. Rawstrom, 183 F.R.D. 668, 670 20 (C.D. Cal. 1998). Courts retain broad discretion in determining whether good cause exists to 21 excuse a late discovery response. Lizarraga v. Buffalo Wild Wings, Inc., No. 2:15-CV-1655- 22 MMD-VCF, 2016 WL 1465338, at *2 (D. Nev. Apr. 14, 2016). Good cause requires a showing 23 of due diligence. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992); see 24 also Grasshopper House, LLC v. Accelerated Recovery Centers, LLC, No. CV-09-8128 DMG 25 PLAX, 2010 WL 11549374, at *2 (C.D. Cal. Aug. 27, 2010) (noting good cause requires the 26 party to show that despite due diligence the scheduled deadline could not be met.) 27 PIV propounded requests for production, interrogatories, and requests for admission on 1 September 23, 2024, PIV granted MNI’s request for a thirty-day extension of time to respond. 2 (Id. at ¶ 3.) On October 28, 2024, MNI responded to PIV’s initial discovery requests but did not 3 produce any documents. (Id. at ¶ 4.) Notably, MNI’s responses to the original RFP Nos. 1-19 4 and 27-29 as well as ROGs No. 6-8, 10-13, and 15-16 were objected to solely on the basis of 5 PIV’s use of vague and ambiguous terms. (Id., Ex. C, at pp 5-14, 18-19, 32-36.)2 MNI did not 6 raise any objections related to overbreadth, relevance, burden, or the scope of discovery. 7 On November 20, 2024, PIV sent a letter addressing MNI’s responses and failure to 8 produce documents. (Ma Decl. ¶ 5.) On December 18, 2024, counsel conferred and agreed that 9 PIV would amend definitions of certain terms and serve amended discovery requests. (Ma Decl. 10 ¶ 6.) PIV served the amended requests on December 20, 2024.

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Related

Richard Davis v. Robert H. Fendler
650 F.2d 1154 (Ninth Circuit, 1981)
Michael J. Conlon v. United States
474 F.3d 616 (Ninth Circuit, 2007)
Ramirez v. County of Los Angeles
231 F.R.D. 407 (C.D. California, 2005)
Bryant v. Armstrong
285 F.R.D. 596 (S.D. California, 2012)
Richmark Corp. v. Timber Falling Consultants
959 F.2d 1468 (Ninth Circuit, 1992)
Safeco Insurance Co. of America v. Rawstrom
183 F.R.D. 668 (C.D. California, 1998)

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Mike's Novelties, Inc. v. PIV Enterprises, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mikes-novelties-inc-v-piv-enterprises-inc-caed-2025.