M.J. Electric, LLC v. TSG New Orleans, LLC

CourtDistrict Court, E.D. Louisiana
DecidedJanuary 10, 2025
Docket2:23-cv-03218
StatusUnknown

This text of M.J. Electric, LLC v. TSG New Orleans, LLC (M.J. Electric, LLC v. TSG New Orleans, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
M.J. Electric, LLC v. TSG New Orleans, LLC, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

M.J. ELECTRIC, LLC * CIVIL ACTION

VERSUS * NO. 23-3218

TSG NEW ORLEANS, LLC * SECTION “E” (2)

ORDER AND REASONS

Pending before me is Plaintiff M.J. Electric, LLC’s Second Motion to Compel. ECF No. 41. Defendant TSG New Orleans, LLC filed an Opposition, and M.J. Electric filed a Reply. ECF Nos. 45, 46. No party requested oral argument in accordance with Local Rule 78.1, and the court agrees that oral argument is unnecessary. Having considered the record, the submissions and arguments of counsel, and the applicable law, Plaintiff’s Second Motion to Compel is GRANTED IN PART AND DENIED IN PART for the reasons stated herein. I. BACKGROUND Prime contractor Innovative Emergency Management (“IEM”) contracted with the Government of Puerto Rico to assist with the repair, reconstruction and/or relocation of families damaged by hurricanes. ECF No. 41-1 at 1. IEM subcontracted with Defendant TSG New Orleans, LLC (“TSG”) to provide a portion of those services, and TSG in turn subcontracted with Plaintiff M.J. Electric, LLC (“M.J. Electric”) to perform inspection services. Id. M.J. Electric has filed this breach of contract action alleging that TSG failed to pay it for subcontracted services. Id. TSG denied the material allegations and raised twenty-three affirmative defenses including M.J. Electric’s prior material breach. ECF No. 26. M.J. Electric issued Interrogatories and Requests for Production to TSG on July 3, 2024. ECF No. 35-1 at 1; see also ECF No. 35-2. After four extensions, TSG responded on September 20, 2024. ECF Nos. 35-3; 35-4. M.J. Electric then filed a Motion to Compel. ECF Nos. 35, 36, 38. The Court held a hearing on November 6, 2024, after which the Court granted in part and

denied in part the motion. ECF No. 40. The Court specifically ordered TSG to provide supplemental responses and produce responsive documents, or specify a firm date for delivery of same, within 14 days of this Order (i.e., by November 20, 2024). Id. II. THE PENDING MOTION M.J. Electric files this Second Motion to Compel in which it asserts that TSG has failed to sufficiently respond, interposed new and inappropriate relevancy objections, and has failed to provide electronically stored information (“ESI”) from a recovered laptop and custodian Jose Mojena’s emails, as discussed at the hearing. ECF No. 41. TSG produced additional documents and supplemental responses by the November 20, 2024, deadline. ECF No. 41-1 at 4. With regard to the laptop, however, TSG notified M.J. Electric that it was inoperable and had sent same to a

third-party vendor, and would endeavor to have any recovered responsive documents produced by December 11, 2024. Id. Plaintiff asserts that, to date, TSG has not provided any of the ESI or otherwise provided an update on the efforts to recover same. Id. M.J. Electric also contends that, in its supplemental responses (particularly as to Interrogatory No. 12 and Requests for Production Nos. 5, 6, 8 and 13), TSG withdrew its commitment to produce relevant documents and instead urged relevancy objections to the information sought. Id. at 4-5. M.J. Electric contends that information regarding payments from IEM to TSG is not only relevant to its claim because TSG could not have submitted (and received payment) for M.J. Electric’s work if M.J. Electric invoiced for unsupported or unapproved expenses, as alleged by TSG, but is also relevant to TSG’s asserted defense and to the categories of damages to which M.J. Electric may be entitled. Id. at 5-7, 10-11. M.J. Electric also objects to TSG’s continued assertion of ambiguous “harassing” objections despite this Court’s admonition. Id. at 7.

In Opposition, TSG argues that the discovery requests at issue all seek information relating to payments it received from IEM related to the R3 Program, but nothing between it and IEM is relevant because the contract between the parties explicitly states that M.J. Electric is not bound by any terms of the prime contract. ECF No. 45 at 1-4, 7. TSG also argues there is no need for an order compelling it to produce any documents recoverable from the laptop because it is already engaged in efforts to produce same and has continued to update counsel on its efforts, most recently advising that responsive information would be available on January 8, 2025, and in fact produced documents from a custodian on January 2, 2025. Id. at 2, 6. TSG contends that the requested discovery seeking all documents between IEM and TSG is disproportionate to the needs of the case and are cumulative and duplicative. Id. at 8-9.

In Reply, M.J. Electric argues that TSG’s untimely Opposition should not be considered, and the Court has ordered TSG to produce documents but it failed to do so. ECF No. 46 at 1.1 It then reiterates its prior arguments, noting that the IEM contract with TSG requires TSG to certify that the costs invoiced are accurate and allowable; thus, if TSG invoiced for M.J. Electric’s costs, it cannot now inconsistently assert that same are not accurate or allowable. Id. at 2-4.

1 TSG has filed a Motion for Leave to explain that the untimely Opposition resulted from counsel’s miscalculation error. ECF No. 47. The Court has considered the untimely Opposition and thus denies the motion for leave as moot. III. APPLICABLE LAW A. The Scope of Discovery Rule 26 of the Federal Rules of Civil Procedure authorizes parties to: obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.2

Information need not be admissible into evidence to be discoverable.3 Rather, the information merely needs to be proportional and relevant to any claim or defense.4 The threshold for relevance at the discovery stage is lower than the threshold for relevance of admissible evidence at the trial stage.5 At the discovery stage, relevance includes “any matter that bears on, or that reasonably could lead to other matter that could bear on, any issue that is or may be in the case.”6 Discovery should be allowed unless the party opposing discovery establishes that the information sought “can have no possible bearing on the claim or defense of the party seeking discovery.”7 If relevance is in doubt, a court should allow discovery.8 Facts that are not considered in determining the ultimate issues may be eliminated in due course of the proceeding.9 While the discovery rules are accorded broad and liberal treatment to achieve their purpose of adequately informing litigants in civil trials,10 discovery does have “ultimate and necessary

2 FED. R. CIV. P. 26(b)(1). 3 Id. 4 Id. 5 Rangel v. Gonzalez Mascorro, 274 F.R.D. 585, 590 (S.D. Tex. 2011) (citations omitted). 6 Id. (brackets and citations omitted). 7 Dotson v. Edmonson, No. 16-15371, 2017 WL 11535244, at *2 (E.D. La. Nov. 21, 2017) (Morgan, J.) (citing Merrill v. Waffle House, Inc., 227 F.R.D. 467, 470 (N.D. Tex. 2005)). 8 E.E.O.C. v. Simply Storage Mgmt., L.L.C., 270 F.R.D. 430, 433 (S.D. Ind. 2010) (quoting Truswal Sys. Corp. v. Hydro–Air Eng’g, Inc., 813 F.2d 1207, 1212 (Fed. Cir. 1987)). 9 Rangel, 274 F.R.D. at 590 n.5 (quoting In re Gateway Eng’rs, Inc., No. 09-209, 2009 WL 3296625, at *2 (W.D. Pa. Oct. 9, 2009)). 10 Herbert v.

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M.J. Electric, LLC v. TSG New Orleans, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mj-electric-llc-v-tsg-new-orleans-llc-laed-2025.