Ohio Security Insurance Company v. Hi-Tech Aggregate, LLC

CourtDistrict Court, D. Nevada
DecidedFebruary 14, 2025
Docket2:23-cv-01094
StatusUnknown

This text of Ohio Security Insurance Company v. Hi-Tech Aggregate, LLC (Ohio Security Insurance Company v. Hi-Tech Aggregate, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ohio Security Insurance Company v. Hi-Tech Aggregate, LLC, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Case No.: 2:23-cv-01094-JAD-NJK Ohio Security Insurance Company, et al., 4 Plaintiffs/Counterdefendants Order Resolving All Pending Motions and 5 v. Closing Case

6 Hi-Tech Aggregate, LLC, [ECF Nos. 66, 72, 82, 85, 86, 90, 91, 93]

7 Defendant/Counterclaimant

8 This insurance dispute began as a declaratory-judgment action by Ohio Security 9 Insurance Company seeking a determination that it had no insurance-coverage obligations 10 arising from monetary judgments that former defendant Pavestone, LLC, received against co- 11 defendant Hi-Tech Aggregate, LLC, in state court. Hi-Tech responded with counterclaims 12 against Ohio for breach of contract, bad faith, and unfair claims practices. In August 2024, I 13 held that Ohio wasn’t entitled to a no-coverage judgment on any of the policy exclusions it 14 raised. Ohio has since satisfied Pavestone’s underlying judgment, and all of Ohio’s claims 15 against Pavestone have been dismissed. Ohio now moves to voluntarily dismiss its declaratory- 16 judgment claims against Hi-Tech, and I grant that motion because the controversy regarding 17 Ohio’s coverage obligations ceased to exist when Ohio paid out Hi-Tech’s claim. So all that 18 substantively remains in this case are Hi-Tech’s counterclaims, which were amended with leave 19 of court after discovery had closed. 20 The parties raise myriad disputes over the scope of discovery and the validity of Hi- 21 Tech’s counterclaims. Hi-Tech moves for case-dispositive sanctions for Ohio’s alleged failure to 22 supplement its responses to discovery requests. Because Ohio did supplement its responses and 23 Hi-Tech hasn’t sufficiently shown that those supplements were untimely, I deny that motion. 1 Ohio seeks dismissal of one amended counterclaim (breach of fiduciary duty) and summary 2 judgment on the rest. I grant both motions because Nevada courts don’t recognize fiduciary- 3 breach claims in the insurance context, Hi-Tech hasn’t shown that Ohio breached any provision 4 of the applicable insurance contract, and Ohio has met its summary-judgment burden to show 5 that Hi-Tech can provide no evidence of damages it sustained because of Ohio’s alleged bad-

6 faith conduct or unfair-claims practices. And because these decisions leave no active claims 7 remaining in this litigation, I deny as moot Ohio’s objection to the magistrate judge’s discovery 8 order, its request to realign the parties, and its motion for an extension of time to file its answer, 9 and I close this case. 10 Discussion 11 A. Hi-Tech hasn’t shown that Ohio violated its discovery obligations, so its sanctions 12 motion is denied.

13 Two weeks after discovery closed in this case, Hi-Tech filed a motion for case- 14 dispositive sanctions against Ohio under Federal Rule of Civil Procedure (FRCP) 37(c).1 Hi- 15 Tech focuses on two categories of discovery that it claims Ohio failed to timely disclose in 16 violation of FRCP 26(a) and (e). It faults Ohio for failing to initially disclose, and then failing to 17 supplement discovery responses to include, the name and last known address of claims adjuster 18 Jennifer Hormel.2 And it accuses Ohio of failing to timely supplement its discovery responses to 19 produce manuals and training materials available to claims adjusters.3 20 21 1 ECF No. 66 (filed August 26, 2024); see also ECF No. 49 (extending discovery deadline to 22 August 12, 2024); ECF No. 77 at 3 (Hi-Tech’s reply in support of its sanctions motion, clarifying that its motion “was brought [under] Rule 37(c)”). 23 2 ECF No. 66 at 13–14. 3 Id. at 4–13. 1 1. Relevant discovery history 2 a. Ohio objects to Hi-Tech’s discovery requests that it deems outside the 3 scope of its narrow, declaratory-relief action.

4 Ohio initiated this lawsuit as a declaratory-judgment action seeking a ruling that it was 5 not contractually obligated to indemnify Hi-Tech for the $2.6 million judgment levied against it 6 in the underlying state-court action between Pavestone and Hi-Tech.4 Hi-Tech’s initial answer, 7 filed on September 15, 2023, did not assert any counterclaims.5 Despite the limited scope of the 8 case at that point, Hi-Tech served Ohio with broad discovery requests seeking all “claims 9 manuals, memoranda, directives, letters, investigation matrix documents[,] and other forms of 10 written or computerized communication” relating to “the handling of claims generally or the 11 handling of claims like this claim at issue,” and “all training manuals, online related publications, 12 bulletins, instruction memos from management, timelines, and requirements for investigation” 13 provided to “any adjuster or other employee . . . who worked on the claim at issue and/or 14 participated in the decision to deny coverage for the claim in any way.”6 Hi-Tech also served 15 Ohio with interrogatory requests asking it to identify “all manuals . . . used (from 2018 to the 16 present) for reservations of rights,” “all criteria, guidelines, practices, procedures, and[] policies 17 . . . [that] were utilized in any manner whatsoever in handling, reviewing, []or evaluating” Hi- 18 Tech’s claim, and all employees involved in groups “concerning the decision” on Hi-Tech’s 19 claim.7 Hi-Tech further asked Ohio to identify “all employees and agents . . . who handled, 20 21

4 ECF No. 1. 22 5 See ECF No. 9. 23 6 ECF No. 66-2 (requests for production nos. 4 & 5). 7 ECF No. 66-4 (interrogatory nos. 3, 5 & 10). 1 reviewed, evaluated, or recommended any action upon” Hi-Tech’s claim and what experience 2 and training those adjusters received.8 3 Ohio objected to Hi-Tech’s requests for manuals and training materials in part based on 4 relevance and disproportionality, noting that “this is a pure coverage suit with no claim handling 5 causes of action to litigate.”9 It further objected that the production requests seeking “all”

6 documents related to Ohio’s claims-handling practices were “overly broad and unduly 7 burdensome.”10 It also objected to Hi-Tech’s interrogatories seeking the names of employees 8 who worked on its claim, but notwithstanding those objections identified Connie Sanders and 9 Steven Warnock as the people who “handled the claim that is the subject of this litigation.”11 10 b. Hi-Tech amends its answer to include counterclaims against Ohio for bad- 11 faith conduct and unfair-claims practices.

12 On November 1, 2023, Ohio filed a motion for summary judgment on its declaratory- 13 judgment claims and moved to stay discovery pending a decision on that motion.12 That same 14 day, Hi-Tech filed a motion to amend its answer to add counterclaims against Ohio for breaching 15 the insurance contract and its implied covenant of good faith and fair dealing, and for violating 16 state statutory protections against unfair claims practices.13 Magistrate Judge Nancy J. Koppe 17

8 Id. (interrogatory nos. 11–14). 18 9 ECF No. 66-2 at 8, 9; ECF No. 66-4 at 7, 9, 15. In Hi-Tech’s second round of requests for 19 production, it sought “all manuals, educational materials, and written instructions used for instructing [Ohio’s] agents, adjusters, and other personnel in drafting, formulating, and/or 20 authoring reservations of rights and who were involved in the decision” to issue a reservation of rights letter to Hi-Tech. ECF No. 66-3 at 11. On November 13, 2023, Ohio objected to that 21 request for the same reasons it objected to requests for production 4 & 5. Id. 10 ECF No. 66-2 at 8, 9; ECF No. 66-4 at 7, 9, 15. 22 11 ECF No. 66-4 at 20. 23 12 ECF Nos. 14, 15. 13 ECF Nos. 16, 16-2.

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Ohio Security Insurance Company v. Hi-Tech Aggregate, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohio-security-insurance-company-v-hi-tech-aggregate-llc-nvd-2025.