Park v. State Farm Fire and Casualty Company

CourtDistrict Court, W.D. Washington
DecidedOctober 15, 2024
Docket2:23-cv-01564
StatusUnknown

This text of Park v. State Farm Fire and Casualty Company (Park v. State Farm Fire and Casualty Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Park v. State Farm Fire and Casualty Company, (W.D. Wash. 2024).

Opinion

1 2 3 4

5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 9 ANNIE PARK, CASE NO. 2:23-cv-01564-TL 10 Plaintiff, ORDER ON MOTION TO COMPEL v. AND MOTION FOR PROTECTIVE 11 STATE FARM FIRE AND ORDER 12 CASUALTY COMPANY et al., 13 Defendant. 14

15 This matter comes before the Court on Plaintiff Annie Park’s First Motion to Compel 16 Discovery (Dkt. No. 25) and Defendant State Farm’s Motion for Protective Order (Dkt No. 41). 17 Having reviewed the motions, responses, and the relevant record, the Court GRANTS Plaintiff’s 18 motion (Dkt. No 25) and DENIES Defendant’s motion (Dkt. No. 41). 19 I. BACKGROUND 20 This is a bad-faith insurance claim. See generally Dkt. No. 1-1. Plaintiff owns a 21 residential rental property located in Lacey, Washington, that was insured by Defendant under a 22 rental dwelling policy. Id. ¶ 7. Plaintiff alleges that, after the property sustained damage and she 23 filed a claim, Defendant mishandled the claim, resulting in the denial of coverage and insurance 24 benefits. Id. ¶¶ 13–37. Plaintiff alleges that Defendant breached their insurance contract, 1 including the implied covenant of good faith and fair dealing, as well as numerous provisions of 2 Washington state law. Id. ¶¶ 38–70. 3 A. Plaintiff’s Requests for Discovery and Defendant’s Responses 4 On December 27, 2023, Plaintiff propounded her first discovery requests, comprising

5 four interrogatories and 14 requests for production. Dkt. No. 25-6. On February 5, 2024, 6 Defendant served its responses. Dkt. No. 25-7. On April 5, 2024, Plaintiff sent Defendant a 7 written “request for supplementation,” advising Defendant that its responses were insufficient, 8 and asking to schedule a conference to discuss the matter. Dkt. No. 25-8 at 1. Plaintiff 9 enumerated insufficiencies in eight of Defendant’s responses to her requests for production and 10 asked that Defendant “fully” supplement its responses by May 3, 2024. Id. at 1–6. Plaintiff noted 11 further that Defendant had “indicated that it would produce discoverable material subject to the 12 entry of a stipulated protective order,” but added that Defendant had not offered any proposed 13 protective order for Plaintiff to review. Id. at 1. Plaintiff indicated her willingness to stipulate to 14 the Western District of Washington’s Model Protective Order “without modification” and

15 attached the Model Protective Order to the letter. Id. at 1, 8–16. Along with the request for 16 supplementation, Plaintiff concurrently propounded her second discovery requests, consisting of 17 four interrogatories, three requests for production, and requests for admission. Dkt. No. 25-10. 18 On April 10, 2024, Plaintiff and Defendant held a conference to discuss the issues raised 19 in Plaintiff’s request for supplementation. Dkt. No. 25-9 at 1–2. In an email Plaintiff sent to 20 Defendant on April 11, 2024, that purported to summarize the conference, Plaintiff advised 21 Defendant that “Plaintiff is willing to stipulate to the Western District’s model protective order, 22 but you believed that [Defendant] would want to use their own. You will get back to us with the 23 proposed order for our review, by the end of next week at the latest.” Id. at 1. On May 23, 2024,

24 Defendant served Plaintiff with supplemental responses to Plaintiff’s first discovery requests and 1 initial responses to Plaintiff’s second discovery requests. Dkt. Nos. 25-11, 25-12. Then, on June 2 6, 2024, Plaintiff propounded an “amended” version of its first discovery requests. Dkt. No. 25- 3 13. On July 12, 2024, Defendant served its responses to the amended first requests. Dkt. No. 31- 4 3.

5 In a parallel email exchange during the first week of June 2024, the parties also discussed 6 a proposed protective order. See generally Dkt. No. 40-1. On June 4, 2024, Defendant emailed 7 Plaintiff a proposed protective order. Id. at 4. But on June 6, 2024, Plaintiff rejected Defendant’s 8 proposal as “one-sided and [in] favor [of] the Defendant.” Id. at 3. Plaintiff expressed her 9 position that the Western District’s model order was “sufficient” and needed no modification. Id. 10 The next day, on June 7, 2024, Plaintiff emailed Defendant and “reiterate[d]” her willingness to 11 stipulate to the Western District of Washington’s Model Protective Order. Id. at 2. 12 On July 8, 2024, Defendant emailed Plaintiff and asserted that it was “finalizing” its 13 responses to Plaintiff’s amended requests for discovery; the email did not mention a protective 14 order. Id. On July 9, 2024, Plaintiff emailed Defendant to inquire about the protective order. Id.

15 at 1. Defendant responded the same day, advising Plaintiff that it was “still working on this” and 16 “should have word to you shortly.” Id. On July 12, 2024, Defendant served Plaintiff with its 17 responses to Plaintiff’s amended discovery requests. Dkt. No. 26. 18 All told, Plaintiff served Defendant with three requests for discovery—

19 (1) Plaintiff’s first requests, dated December 23, 2023 (Dkt. No. 25-6);

20 (2) Plaintiff’s second requests, dated April 5, 2024 (Dkt. No. 25-10); and

21 (3) Plaintiff’s amended first requests, dated December 23, 20231 (Dkt. No. 25-13). 22 Defendant served Plaintiff with four sets of responses— 23

24 1 Upon amending its first requests for discovery, Plaintiff did not re-date the document. 1 (1) Defendant’s first responses, dated February 5, 2024 (Dkt. No. 25-7);

2 (2) Defendant’s supplemental first responses, dated May 23, 2024 (Dkt. No. 25-11); 3 (3) Defendant’s second responses, dated May 23, 2024 (Dkt. No. 25-12); 4 and

5 (4) Defendant’s first amended responses, dated July 12, 2024 (Dkt. No. 31-3).

6 B. Plaintiff’s Motion to Compel 7 On August 23, 2024, Plaintiff filed the instant motion to compel. Dkt. No. 25. Plaintiff 8 asserted therein that she was seeking the Court’s intervention with respect to 10 requests for 9 production and one interrogatory. Id. at 5–6. Specifically, Plaintiff described her unresolved 10 requests as follows: 11 Plaintiff’s First Interrogatories and Requests for Production: 12 • Request for Production No. 2 (application files); 13 • Request for Production No. 4 (underwriting files); 14 • Request for Production No. 5 (property claim handling policies); 15 • Request for Production No. 6 (vandalism and drug contamination 16 policies);

17 • Request for Production No. 7 (reserves set for Plaintiff’s claim);

18 • Request for Production No. 9 (personnel files for claim handlers);

19 • Request for Production No. 10 (Defendant’s bonus/incentive programs); 20

• Request for Production No. 11 (claims audit policies); 21

Plaintiff’s Second Interrogatories and Requests for Production: 22

• Interrogatory No. 1 & Request for Production No. 3 (regarding 23 evaluation of loss of rents); and

24 1 • Request for Production No. 1 (documents related to “hard living”).

2 Id. Plaintiff also requested that the Court award attorney fees, pending the Court’s presumptive 3 granting of her motion. Id. at 15. 4 On September 4, 2024, Defendant responded to Plaintiff’s motion. Dkt. No. 30. 5 Defendant stylized its response as a “Response to Plaintiff’s Motion to Compel Discovery and 6 Cross Motion for Protective Order.” Id. at 1. Defendant’s response: (1) recounted generally the 7 discovery timeline recited above; (2) addressed five of the substantive discovery issues raised by 8 Plaintiff in her motion to compel; (3) argued against a potential award of attorney fees; and 9 (4) discussed at length a proposed protective order. See generally id. Defendant asserted that it 10 “was in the process of providing Plaintiff with an alternative proposed Protective Order . . . 11 because the Western District’s Model does not contemplate document production specific to this 12 insurance-related litigation.” Id. at 4.

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Park v. State Farm Fire and Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/park-v-state-farm-fire-and-casualty-company-wawd-2024.