Peralta v. PCS USA LLC

CourtDistrict Court, S.D. New York
DecidedJanuary 22, 2024
Docket1:22-cv-09312
StatusUnknown

This text of Peralta v. PCS USA LLC (Peralta v. PCS USA LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peralta v. PCS USA LLC, (S.D.N.Y. 2024).

Opinion

SOMEDAY DA 9 OEE EVER VES? □□□ ViA ECF The Honorable Jessica G. L. Clarke United States District Judge Southern District of New York 500 Pearl St. New York, New York 10007 Re: = Peralta vy. PCS USA LLC et al., 22-cv-9312 (JGLC)— Joint Letter-Motion on Discovery Dispute Regarding Plaintiff's Requests for Production Dear Judge Clarke: In accordance with Local Rule 37.2 and Individual Rule 4(k), Plaintiff Yafreici Peralta and Defendants Louis Van Leeuwen and PCS USA LLC (“PCS”) submit this joint letter seeking the Court’s resolution of a discovery dispute arising from Defendants’ responses to Plaintiff's Requests for Production (“RFPs,” and each an “RFP”) 3, 5, and 14.! The parties have been unable to resolve these issues, despite extensive pre-letter negotiations. Accordingly, the parties submit this joint letter, in which Plaintiff moves this Court to compel Defendants to produce all responsive documents. I. Plaintiff's Position Plaintiff may obtain discovery regarding “any nonprivileged matter that is relevant... and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). To date, Defendants have produced just 86 pages of documents. Defendants have failed to produce numerous documents that are both responsive and critical to Plaintiff's prosecution of this action, including email exchanges related to Plaintiff's termination and commissions, determinations of Plaintiffs salary, and internal discussions of Plaintiffs performance at PCS. Fed. R. Civ. P. 26(1); Doug’s World Clocks.com Pty. Ltd. v. Princess Int'l, Inc., 323 F.R.D. 167, 173-74 (S.D.N.Y. 2017) (holding that defendants had an obligation to produce responsive, relevant documents). Defendants do not dispute the relevance of these documents, but instead claim they no longer exist. Plaintiff is entitled to test the accuracy of this assertion. Moreover, Defendants’ conduct throughout the course of discovery raises significant questions about their compliance with preservation and production obligations under the Federal Rules of Civil Procedure and this District’s precedent. See R.F.M.A.S., Inc. v. So, 271 F.R.D. 13, 24 (S.D.N.Y. 2010) (“To fulfill [its] preservation obligation, a litigant must take affirmative steps to prevent inadvertent spoliation.”). Accordingly, Plaintiff requests that this Court compel the production of the following relevant and responsive documents, which, to date, Defendant has not produced: 1 Plaintiff served the RFPs on October 23, 2023 and engaged undersigned pro bono counsel on November 27. RFP 3 calls for the production of “all documents that refer or relate to any allegation made in Plaintiff's Complaint.” Ex. A. RFP 5 calls for the production of “all communications between Defendants and any other employee of Defendants concerning, relating, or referring to Plaintiff.” Jd. RFP 14 calls for the production of “all documents concerning Defendants’ Fourth Affirmative Defense in Defendants’ Answer to Plaintiff's Complaint.” Jd. Defendants’ Fourth Affirmative Defense states: “Plaintiff's claims for discrimination in pay fail because any alleged difference in pay between Plaintiff and any other similarly situated employees was based on a seniority system, a merit system, a system which measures earnings by quantity or quality of production, and/or a differential based on factors other than sex.” ECF 30 at 9. On December 5, 2023, Plaintiffs counsel alerted Defendants’ counsel to certain deficiencies, Ex. B at 6-7, in Defendants’ production that are the subject of this letter-motion which the parties have been unable to resolve.

RFP 5: All emails between Defendant Van Leeuwen and any other employee of Defendants’ concerning, relating to, or referring to Plaintiff.2 These documents will establish Plaintiff’s disparate treatment at Defendants’ hands and Defendants’ retaliation, help to create a timeline of events leading up to and following Plaintiff’s termination, and may provide evidence negating Defendants’ alleged legitimate, nondiscriminatory reasons for terminating Plaintiff. These documents also likely will evidence Plaintiff’s claim of a hostile work environment, since email messages often contain comments, language, and jokes that contribute to such an environment. Though Defendants did not object to this RFP, Ex. C, and do not dispute the documents’ relevance, Defendants have not produced Mr. Van Leeuwen’s emails. Instead, Defendants informed Plaintiff in November that Mr. Van Leeuwen “lost possession” of his emails after PCS’s distribution agreement with PCS B.V., the Dutch manufacturer of the cookware PCS sold, was terminated and PCS dissolved in September 2022. Defendants wrote that the “email domain” formerly used by PCS “was retained by the ongoing PITT Cooking companies,” including PITT Cooking America (the entity with which PCS B.V. now has a U.S. distribution agreement), PCS B.V., and Dutch holding company PCS Holding B.V. Ex. B at 5. Defendants did not conduct a reasonable search for these documents, inconsistent with their discovery obligations. Defendants did not even begin looking for these documents until after Plaintiff’s counsel repeatedly asked them to do so. And, Defendants did not contact any of these entities to obtain responsive documents.3 See Raine Grp. LLC v. Reign Cap., LLC, 2022 WL 538336, at *1 (S.D.N.Y. Feb. 22, 2022) (“FRCP] 26 and 34 require parties to conduct a reasonable search for documents that are relevant to the claims and defenses”). Instead, Plaintiff diligently attempted to obtain these emails through other means, including by promptly issuing a subpoena to PITT Cooking America and conferring with the founder of that entity. These attempts proved fruitless, however, because PITT Cooking America does not have the documents, despite Defendants’ representations to the contrary. Defendants’ failure to locate these documents in their files or to obtain them through other means is deeply concerning, because Defendants were obligated to preserve these documents beginning in 2021, when they were provided a document preservation notice and reasonably anticipated litigation. Both parties engaged counsel in 2021, and Plaintiff filed an EEOC submission in 2022. See Zubulake, 220 F.R.D. at 217 (“[A litigant] is under a duty to preserve what it knows, or reasonably should know, is relevant in the action, is reasonably calculated to lead to the discovery of admissible evidence, [or] is reasonably likely to be requested during discovery . . . .”); Raymond v. City of New York, 2020 WL 705572, at *6 (S.D.N.Y. Dec. 2, 2020)

2 Defendants also failed to produce any documents responsive to RFP 4, which seeks communications between Plaintiff and Defendants. See Ex. A. Because Plaintiff is able to obtain these communications through other means, however, Plaintiff has not been prejudiced by Defendants’ failure to produce them and does not seek their production nor plan to seek sanctions on this basis. 3 Defendant’s counsel offered “reach out” to PCS B.V. about the emails, but noted this would unlikely be fruitful since Mr. Van Leeuwen is on bad terms with PCS B.V., and disclosed that Mr. Van Leeuwen and PCS were sued by PCS B.V. and PITT Cooking America (the entity that now has a distribution agreement with PCS B.V.) in connection with the use of PITT Cooking trademarks. PITT Cooking America LLC, et al. v. PCS USA LLC et al., 3:23-cv-00057-OAW (D. Conn.). Plaintiff’s counsel gave Defendants one week to notify Plaintiff of a plan to contact PCS B.V. prior to filing this letter. Ex. E. Defendants did not respond and, based on information and understanding, did not reach out to PCS B.V.

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Bluebook (online)
Peralta v. PCS USA LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peralta-v-pcs-usa-llc-nysd-2024.