Oliver v. Meow Wolf, Inc

District Court, D. New Mexico·Decided July 1, 2022·No. 1:20-cv-00237·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

LAUREN ADELE OLIVER,

Plaintiff,

vs. Civ. No. 20-237 KK/SCY

MEOW WOLF, INC., a Delaware Corporation; VINCE KADLUBEK, an individual and officer; and DOES 1-50,

Defendants.

ORDER DENYING PLAINTIFF’S MOTION TO COMPEL AND MOTION FOR EXTENSION

In this discovery dispute the parties argue over Plaintiff’s request for marketing materials sent by various individuals associated with Meow Wolf to various companies. Unable to reach an agreement, Plaintiff filed her “Motion to Compel Production of Documents from Defendant Meow Wolf, Inc.” on March 24, 2022 (Doc. 340), and the parties finished briefing the motion on April 27, 2022 (Docs. 350, 369). Relatedly, concerned that she would need to gather such marketing materials from third parties, Plaintiff issued several third-party subpoenas. In connection with these subpoenas, Plaintiff has filed a “Motion to Extend Deadline to File Motions to Compel Related to Third-Party Subpoena.” Doc. 385; see also Doc. 404 (response); Doc. 450 (notice of briefing complete indicating Plaintiff will not file a reply). For the reasons discussed below, the Court denies both motions. LEGAL STANDARD Federal Rule of Civil Procedure 26(b)(1) permits 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. Information within this scope of discovery need not be admissible in evidence to be discoverable.

“Evidence is relevant if: (a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the action.” Fed. R. Evid. 401. Discovery relevance is “to be construed broadly to encompass any matter that bears on, or that reasonably could lead to other matter that could bear on any party’s claim or defense.” Kennicott v. Sandia Corp., 327 F.R.D. 454, 469 (D.N.M. 2018) (internal quotation and citation omitted). And while “relevancy in discovery is broader than that required for admissibility at trial, the object of inquiry must have some evidentiary value” to be discoverable. Dorato v. Smith, 163 F. Supp. 3d 837, 865-6 6 (D.N.M. 2015) (quotation marks omitted). ANALYSIS 1. Motion to Compel At issue in the motion to compel is Plaintiff’s Request for Production (“RFP”) No. 41 to Defendant Meow Wolf, which seeks “all emails dated between March 17, 2016 and December 21, 2019” from a list of 13 Meow Wolf representatives sent to representatives of a list of 23 businesses “and which emails have attachments of pitch decks, one-sheets, press packets, or other graphical promotional or solicitation material containing images of artwork from House of Eternal return, and including the attachments thereto. This request seeks only emails with attachments as described, and the attachments thereto.” Doc. 350-1 at 1-2. In other words, Plaintiff seeks emails between the listed representatives and the listed businesses that attach marketing materials containing any image of any House of Enteral Return (“HoER”) artwork, not just images of Plaintiff’s artwork (the Space Owl/ISQ). Defendant objects to RFP No. 41 as irrelevant, overbroad, unduly burdensome, and exceeding the number of allowable requests. To begin, the parties spend a portion of their briefing discussing only part of the RFP: whether Defendant should produce just marketing materials containing images of Plaintiff’s artwork, as opposed to materials with images of any HoER artwork. Plaintiff asserts that such

materials are relevant to her copyright infringement claim. Defendant, on the other hand, argues that such relevance is minimal because Meow Wolf stopped using images of the ISQ in 2018 after Plaintiff complained and because Plaintiff has no evidence of any actual damages from the ISQ being on pitch decks. But Plaintiff is not required to prove her case in order to obtain discovery. Instead, she is entitled to discovery relevant to her claims in order to help develop and prove her case. As such, the Court agrees with Plaintiff that marketing materials containing images of Plaintiff’s artwork is relevant to her claim for copyright infringement. However, Defendant has already produced such material. See Doc. 205 at 5 n.4 (prior discovery order explaining Defendant’s process to gather pitch decks with images of Plaintiff’s

artwork and noting that Plaintiff withdrew her motion to compel regarding such pitch decks). Plaintiff asserts that she sent RFP No. 41 after deposing Brian Solomon, former Creative Director at Meow Wolf, who testified that images of the Space Owl were included in a large number of early pitch material. Id. at 1-2.1 But Plaintiff does not explain how or why this testimony would cast doubt on Defendant’s assertion that it already produced all the pitch decks

1 On its face, RFP 41 is not limited to pitch decks. In addition to pitch decks, RFP 41 requests “one-sheets, press packets, or other graphical promotional or solicitation material containing images of artwork.” Doc. 350-1 at 2. Plaintiff’s briefing, however, focuses on pitch decks. Moreover, considering marketing material beyond pitch decks makes Plaintiff’s request for material related to HoER (rather than ISQ) broader and even more disproportionate to its potential value. containing images of Plaintiff’s artwork. Said another way, Plaintiff points to nothing specific in Mr. Solomon’s deposition to show that additional pitch decks with Plaintiff’s artwork exist that have not been turned over to Plaintiff. Additionally, pitch decks containing images of just Plaintiff’s artwork is not what RFP No. 41 actually seeks—it seeks marketing materials with images of any HoER artwork. In her

motion, Plaintiff explains that during the meet and confer process with Defendant she twice agreed to narrow the scope of this request. First, “Plaintiff proposed that the request be limited from marketing material advertising the artwork from House of Eternal Return to marketing material advertising Plaintiff’s intellectual property.” Doc. 340 at 5. After Defendant continued to object, Plaintiff proposed limiting the request to emails between only five Meow Wolf custodians and five companies. Id.; see also Docs. 340-4, 350-1 (emails between counsel listing the five custodians and five companies). Defendant disputes that Plaintiff ever offered the first limitation—to only emails containing Plaintiff’s artwork. Doc. 350 at 6. Indeed, the emails attached by both parties regarding the meet and confer only reflect an offered limitation to five

custodians and five companies. See Docs. 340-4, 350-1. In any event, in the present motion to compel, Plaintiff seeks to compel a response to her original RFP No. 41, not any narrowed request previously proposed but not agreed on by the parties. Although the Court could envision a more narrow request or limited search parameter that would properly balance the concerns in Rule 26(b)(1), the Court will not rewrite discovery for the parties but will rule on the actual request before it.2 See Regan-Touhy v. Walgreen Co., 526 F.3d 641, 650 (10th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Oliver v. Meow Wolf, Inc, (D.N.M. 2022).

Oliver v. Meow Wolf, Inc (Oliver v. Meow Wolf, Inc) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Regan-Touhy v. Walgreen Co.
526 F.3d 641 (Tenth Circuit, 2008)
Punt v. Kelly Services
862 F.3d 1040 (Tenth Circuit, 2017)
Dorato ex rel. Wrongful Death Claim of Tillison v. Smith
163 F. Supp. 3d 837 (D. New Mexico, 2015)
Securities & Exchange Commission v. Goldstone
301 F.R.D. 593 (D. New Mexico, 2014)