(PC) Keen v. Cross

District Court, E.D. California·Decided August 4, 2025·No. 2:24-cv-00299·Unknown

Opinion

BRANDON KEEN, Case No. 2:24-cv-0299-JDP (P) Plaintiff, v. ORDER CROSS, et al., Defendants. Plaintiff, a state inmate proceeding pro se, brought this § 1983 action against defendants Cross and Wallace, alleging that they violated his Eighth Amendment rights when they became aware that plaintiff had set a fire in his cell but failed to help him. Now pending before the court are defendants’ and plaintiff’s motions to compel. Defendants further seek to modify the discovery and scheduling order to allow additional time to retake plaintiff’s deposition. For the following reasons, defendants’ motion is granted and plaintiff’s is denied. Defendants’ Motion to Compel Plaintiff’s Deposition Defendants’ move to compel plaintiff to resume his deposition testimony. ECF No. 43. Discovery opened February 20, 2025, and the deadline for completion of discovery was June 13, 2025. ECF No. 35. On March 13, 2025, defendants served plaintiff with a deposition notice for April 30, 2025. ECF No. 43-2 at 5-6. The deposition was scheduled for April 30, 2025, at 9:00 a.m. at California Men’s Colony via audio-visual conference. Id. On April 30, 2025, plaintiff and defense counsel appeared for the deposition. ECF No. 43-2 at 12-16. The deposition started at 9:09 a.m., id. at 16, and defense counsel ended the deposition for the day at 10:33 a.m., id. at 55. At 10:07 a.m., the parties took a break and resumed the deposition at 10:24 a.m. Id. at 47-48. Prior to the break, plaintiff informed defense counsel that he was finished with the deposition because he did not have counsel and because defense counsel had not shown plaintiff the video recording of the alleged fire. Id. at 44-47. Q. Sir, are you refusing to participate in the rest of this deposition? A. I need to get hold of somebody to help me for assistance. Q. I get that, sir. But we’re going to still continue with this deposition today. Okay? A. I’m done. Done answering questions. I’m not refusing. I’m done. That’s it. I don’t know what to tell you. I don’t recall anything else. Q. Okay. Well -- A. I need help. I need assistance and help with this issue. Because if I don’t recall, the only thing you are going to twist it against me. And it’s all on camera. You seen the film over and over. And I haven’t had the opportunity to look at it. Id. at 46. When the parties returned from the break, defense counsel verbalized for the record that plaintiff had placed a sheet over his holding cell such that he was not visible on the screen.1 Id. at 48. Defense counsel asked plaintiff is he was refusing to answer questions based on plaintiff’s lack of recall and lack of desire to continue the deposition. Id. at 49-50. Plaintiff responded that he needed to view the video of the incident to refresh his memory to answer defense counsel’s questions, that he could not answer questions due to his mental health medications, and that he needed first to speak with the court. Id. at 50-51. Following the deposition, defense counsel sent plaintiff a letter that explained that if plaintiff did not inform him that he would sit for another 1 Defendants lodged with the court a video recording on the deposition and the court agrees that plaintiff had placed a white sheet over the holding cell and was not visible. deposition, defendants would file a motion to compel plaintiff’s deposition. Id. at 60. Defendants did not receive a response. Defendants are entitled to conduct discovery, which includes the deposition of plaintiff, to obtain all information pertaining to the factual allegations, and legal claims and defenses at issue in this action. Fed. R. Civ. P. 26(b)(1) & 30. “An objection at the time of the examination– whether to evidence, to a party’s conduct, to the officer’s qualifications, to the manner of taking the deposition, or to any other aspect of the deposition—must be noted on the record, but the examination still proceeds.” Fed. R. Civ. P. 30(c)(2). Objections must be stated concisely in a non-argumentative and non-suggestive manner. Id. The deponent may refuse to answer a question “only when necessary to preserve a privilege, to enforce a limitation ordered by the court, or to present a motion under Rule 30(d)(3).” Id. The court may impose a sanction— including of reasonable expenses and attorney’s fees—on any person who “impedes, delays, or frustrates the fair examination of the deponent.” Fed. R. Civ. P. 30(d)(2). Under Rule 37(a), a party seeking discovery may move for an order compelling discovery when an opposing party has failed to respond. Fed. R. Civ. P. 37(a). In filing a motion to compel, the moving party bears the burden of demonstrating that he will suffer “actual and substantial prejudice” from the denial of discovery. Veterans for Common Sense v. Shinseki, 644 F.3d 845, 888 (9th Cir. 2011) (citing Hallen v. Morgan, 296 F.3d 732, 751 (9th Cir. 2002)). During the deposition, plaintiff advanced two primary bases for refusing to answer defense counsel’s questions. First, he objected that he could not recall the answers to certain questions because he had not seen the video. ECF No. 43-2 at 50-52. Second, he stated that he needed either to speak with the court or to be represented by counsel before answering questions. Id. Both objections are unavailing. Plaintiff’s first objection, that he could not recall answers without first seeing the video of the incident, is not a valid basis under Rule 30 for refusing to answer a question. Plaintiff voluntarily invoked the procedures of this court when he filed this lawsuit, and he must comply with his discovery obligations. Madrid v. De La Cruz, No. 1:18-cv-00947-DAD-EPG, 2019 WL 2994301, at *3 (E.D. Cal. July 9, 2019) (quoting Tene v. City and Cnty of San Francisco, No. C 00-03868 WHA, 2004 1465726 (N.D. Cal. May 12, 2004). Defendants have a fundamental right to discovery and to effectively defend themselves. Fed. R. Civ. P. 26, 30. Plaintiff’s refusal to answer questions at his deposition prejudices defendants’ ability to defend against this case. See Green v. CDCR, No. 2:14-cv-2854-TLN-AC, 2018 WL 4963122, at *2 (E.D. Cal. Oct. 15, 2018) (“It would be fundamentally unfair and prejudicial to defendants to permit plaintiff to continue to pursue this action without requiring his attendance and cooperation at his deposition.”). Plaintiff’s second argument, that he may refuse to participate in his deposition unless he is represented by counsel or talks to the court first, is equally without merit. See Pulliam v. Lozano, No. 1:07-cv-964-LJO-MJS, 2011 WL 335866, at *3 (E.D. Cal. Jan. 31, 2011) (noting that a pro se inmate must fully participate and cooperate in properly noticed deposition despite his preference for appointed counsel); Green, 2018 WL 4963122, at *2 (noting that a pro se plaintiff is “required to fully participate in all stages of the proceedings”). As I have explained to plaintiff previously, see ECF Nos. 7, 17, & 42, there is no right to counsel in 1983 cases. See Nicholson v. Rushen, 767 F.2d 1426, 1427 (9th Cir. 1985) (per curiam). Although a court may request counsel to represent an inmate, such requests are only warranted when justified by exceptional circumstances. Rand v. Rowland, 113 F.3d 1520, 1525 (9th Cir. 1997). And as previously evaluated, this case does not prese

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