Pappion v. Phillips 66 Co

CourtDistrict Court, W.D. Louisiana
DecidedJune 20, 2025
Docket2:19-cv-01098
StatusUnknown

This text of Pappion v. Phillips 66 Co (Pappion v. Phillips 66 Co) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pappion v. Phillips 66 Co, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

CLIFTON J. PAPPION : DOCKET NO. 2:19-cv-01098

VERSUS : JUDGE JAMES D. CAIN, JR.

PHILLIPS 66 CO. : MAGISTRATE JUDGE LEBLANC

MEMORANDUM ORDER

Before the court is a Motion to Compel Discovery filed by defendant Phillips 66 Company (“Phillips 66”). Doc. 70. The motion is opposed by plaintiff Clifton J. Pappion. Doc. 74. Defendant has replied [doc. 75], making this motion ripe for resolution.1 For reasons set forth below, the court finds that the motion should be GRANTED IN PART AND DENIED IN PART. I. BACKGROUND This dispute arises from an employment discrimination claim brought by plaintiff Clifton J. Pappion against defendant Phillips 66. Doc. 1. On July 14, 2020, Phillips 66 propounded written discovery upon Plaintiff in the form of interrogatories and requests for production (the “first set of discovery”). Doc. 70, att. 17, pp. 5-6. On August 24, 2020, Plaintiff untimely provided minimal responses to the discovery requests accompanied by broad, boilerplate objections. Id. at p. 6. These responses also provided only five of the eight requested records authorizations. Id. Phillips 66 sent Plaintiff’s counsel a letter describing the deficiencies, and the parties subsequently held a telephone conference to discuss these issues. Id. at pp. 7-8. After Plaintiff failed to supplement

1 The motion was set for hearing on November 21, 2024. Plaintiff did not appear for the hearing, and so this matter has been resolved on the briefing. the answers following the telephone conference, Phillips 66 sent another email to Plaintiff’s counsel requesting the missing authorizations. Id. at pp. 8-9. On May 16, 2024, Phillips 66 propounded another set of requests for production and one interrogatory (the “second set of discovery”) to Plaintiff. Id. at p. 9. Soon thereafter, Phillips 66

sent another letter requesting that Plaintiff supplement his responses to the first set of discovery. Id. On June 14, 2024, Plaintiff provided supplemental responses to the first set of discovery but failed to address any requests from the second set of discovery. Id. at att. 9. Phillips 66 believed the June 14, 2024, supplemental responses were still deficient. Id. at p. 10. On September 5, 2024, both parties participated in a scheduling conference with the Court. Id. at p. 10. The discovery issues were discussed during this conference, and the Court suggested that a formal motion be filed to resolve these issues. Id. Following the conference, the parties met over the phone twice to discuss the discovery issues. Id. at pp. 10-12. On October 5, 2024, Plaintiff’s counsel sent Phillips 66 another set of supplemental responses to the first set of discovery. Id. at p. 12. These supplemental responses also included

untimely objections to the second set of requests for production but failed to acknowledge the second set of interrogatories. Id. at p. 9; att. 12. On October 8, 2024, Phillips 66 contacted Plaintiff’s counsel to afford a final opportunity to fix certain responses that Phillips 66 believed were inaccurate. Id. at p. 13. Phillips 66 subsequently filed the instant Motion to Compel. Doc. 70. II. LAW AND ANALYSIS Pursuant to Federal Rule of Civil Procedure 26(b)(1), “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense.” Federal Rule of Civil Procedure 37(a)(3)(B) permits a party seeking discovery to move for an order compelling disclosure of any materials requested if another party fails to answer an interrogatory submitted under Rule 33 or to produce documents as requested under Rule 34. “For a motion to compel, ‘[t]he moving party bears the burden of showing that the materials and information sought are relevant to the action or will lead to the discovery of admissible evidence.’” Mirror Worlds

Technologies, LLC v. Apple Inc., No. 6:13-cv-419, 2016 WL 4265758, at *1 (E.D. Tex. Mar. 17, 2016) (quoting SSL Servs., LLC v. Citrix Sys., Inc., No. 2-08-cv-158, 2010 WL 547478, at *2 (E.D. Tex. Feb. 10, 2010)) (brackets in original). “Once the moving party establishes that the materials requested are within the scope of permissible discovery, the burden shifts to the party resisting discovery to show why the discovery is irrelevant, overly broad or unduly burdensome or oppressive, and thus should not be permitted.” Id. Further, pursuant to Federal Rules of Civil Procedure 33 and 34, objections to an interrogatory or request for production must be made within thirty days after service of the requests. “[A]s a general rule, when a party fails to object timely to interrogatories, production requests, or other discovery efforts, objections thereto are waived.” In re U.S., 864 F.2d 1153,

1156 (5th Cir. 1989). The Court, however, “retains discretion to decline to compel requested discovery when the request far exceeds the bounds of fair discovery, even if a timely objection has not been made.” Amir Athletic, LLC v. State Farm Fire & Cas. Co., No. CIV. A. 11-2082, 2012 WL 520658 at *2 (E.D. La. Feb. 16, 2012); see also RE/MAX International, Inc. v. Trendsetter Realty, LLC, No. CIV.A. H-07-2426, 2008 WL 2036816, at *6 (S.D. Tex. May 9, 2008). Moreover, courts have found that “the failure to timely object on the basis of privilege does not result in an automatic waiver.” Williams v. Jeld-Wen, Inc., No. 1:17-CV-01366, 2022 WL 509373 at *9 (W.D. La. Feb. 18, 2022) (citing B&S Equip. Co. v. Truckle Servs., Inc., No. 09-3862, 2011 WL 2637289, at *6 (E.D. La. July 6, 2011)). “Rather, a waiver of privilege is a serious sanction reserved for cases of unjustified delay, inexcusable conduct, bad faith, or other flagrant violations.” B&S Equip. Co., 2011 WL 2637289 at *5. Objections to written discovery, including those of privilege, must, however, also be stated with specificity, including reasons for the objection. Fed. R. Civ. P. 33(b)(4), 34(b)(2)(B). Further,

such objections must “state whether any responsive materials are being withheld.” Fed. R. Civ. P. 34(b)(2)(C). Finally, Federal Rule of Civil Procedure 26(b)(5)(A) requires parties withholding discoverable information based on a claim of privilege to “(i) expressly make the claim; and (ii) describe the nature of the documents, communications, or tangible things not produced or disclosed—and do so in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.” Therefore, boilerplate and “conclusory objections that the requested discovery is ‘overly broad, burdensome, oppressive and irrelevant’ are insufficient[.]” Scott v. United States Postal Serv., No. CV 15-712-BAJEWD, 2016 WL 7440468, at *4 (M.D. La. Dec. 27, 2016) (citations omitted); see also Romero v. United States, No. 6:23- CV-00032, 2024 WL 436892 at *2 (W.D. La. Feb. 2, 2024) (“Boilerplate objections are

unacceptable.”); VeroBlue Farms USA Inc. v. Wulf, 345 F.R.D. 406, 420 (N.D. Tex. 2021) (holding that the only thing a boilerplate objection accomplishes is waiver of the objection). Thus, as with untimely objections, insufficient objections are also waived. In re U.S., 864 F.2d at 1156.

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Related

In Re United States of America
864 F.2d 1153 (Fifth Circuit, 1989)

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