Photography By Frank Diaz LLC v. Friends of David Schweikert

District Court, D. Arizona·Decided April 25, 2023·No. 2:22-cv-01170·Unknown

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Photography By Frank Diaz LLC, No. CV-22-01170-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Friends of David Schweikert, et al.,

13 Defendants. 14 15 Pending before the Court are two discovery disputes among the parties one of which 16 involves a non-party. 17 Doc. 45 18 In the discovery dispute filed at Doc. 45 (with supplemental briefs filed by the 19 parties as ordered by the Court at Docs. 50 and 51) Plaintiff complains that Defendants will 20 not meaningfully engage in discovery. Specifically, it is undisputed that on “August 22, 21 2022, Plaintiff served request for production (“RFP”) No. 3 for: ‘All documents and 22 communications concerning or referring to the Copyrighted Work, including [Defendants’] 23 use, copying, reproduction, display, or distribution of the Copyrighted Work or derivative 24 works thereof . . . .’” (Doc. 45 at 2). It is undisputed that Defendants did not timely object 25 to this RFP. (Id.; Doc. 50 at 1). Plaintiff asserts that via some third-party discovery, some 26 documents that would have been in Defendants’ possession, custody and control (such as 27 sent emails and sent text messages) were produced that were responsive to RFP 3, but 28 Defendants never produced them. (Doc. 45 at 2). Thus, Plaintiff asks that this Court order: 1 “that, within fourteen (14) days following entry of this Order, Defendants shall produce all 2 documents and communications concerning or referring to the Copyrighted Work [footnote 3 omitted], including Defendants’ use, copying, reproduction, display, or distribution of the 4 Copyrighted Work or derivative works thereof, and documents sufficient to show the dates 5 Defendants caused any portions of the Copyrighted Work to be distributed.” (Doc. 45-1 at 6 1). 7 Defendants now raise several objections to RFP 3, some of which at a surface glance 8 appear to have merit. However, by failing to timely object, Defendants have forfeited these 9 objections.1 10 To be sure, Rule 33(b)(4) of the Federal Rules of Civil Procedure provides that “[t]he grounds for objecting to an interrogatory must be stated 11 with specificity” and “[a]ny ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure.” Thus, a party waives 12 any objection to an interrogatory “by failing timely to raise it.” Friedman v. Live Nation Merch., Inc., 833 F.3d 1180, 1185 n.2 (9th Cir. 2016). The same 13 principles govern RFPs under Rule 34. Although the concept of waiver/forfeiture is not enshrined in the text of Rule 34, the Ninth Circuit has 14 recognized that, under both Rules 33 and 34, “a failure to object to discovery requests within the time required constitutes a waiver of any objection.” 15 Richmark Corp. v. Timber Falling Consultants, 959 F.2d 1468, 1473 (9th Cir. 1992). 16 ThermoLife Int’l LLC v. NeoGenis Labs Inc., No. CV-18-02980-PHX-DWL, 2021 WL 17 1424408, at *5 (D. Ariz. Apr. 15, 2021). 18 “It is well established that a failure to object to discovery requests within the 19 time required constitutes a waiver of any objection.” Richmark Corp. v. Timber Falling Consultants, 959 F.2d 1468, 1473 (9th Cir. 1992). However, 20 Rule 33 allows courts to excuse such a waiver “for good cause.” Fed. R. Civ. P. 33(b)(4). Although Rule 34 does not contain an analogous provision, 21 courts “generally agree that there is no reason to treat waiver under Rule 34 any different than Rule 33.” Liguori v. Hansen, No. 2:11–cv–00492–GMN– 22 CWH, 2012 WL 760747, at *12 (D. Nev. Mar. 6, 2012). Accordingly, courts “retain discretion to relieve a late or non-responding party from the 23 1 24 Although the rules and case law use the term “waiver” when referring to the consequences arising from the failure to raise timely objections to a 25 discovery request, it would be more accurate to use the term “forfeiture” in this context. See generally United States v. Olano, 507 U.S. 725, 733 (1993) 26 (“Waiver is different from forfeiture. Whereas forfeiture is the failure to make the timely assertion of a right, waiver is the intentional relinquishment 27 or abandonment of a known right.”) (internal quotation marks omitted).

28 ThermoLife Int'l LLC v. NeoGenis Labs Inc., No. CV-18-02980-PHX-DWL, 2021 WL 1424408, at *5 n.7 (D. Ariz. Apr. 15, 2021). 1 potentially harsh consequences associated with waiver.” Id. at *11. 2 Ocean Garden Prod. Inc. v. Blessings Inc., No. CV-18-00322-TUC-RM, 2020 WL 3 4284383, at *1 (D. Ariz. July 27, 2020). 4 As indicated above, Defendants forfeiture of their objections could be excused if 5 they showed good cause. However, Defendants’ supplemental brief (Doc. 50) does not 6 argue good cause, and indeed never uses the words “good cause.” Defendants do argue, 7 as to one of their objections, that additional information came to light after the 30-day 8 window to make objections closed. However, the majority of Defendants’ objections are 9 premised on information that was known to them at the time the RFP was propounded. 10 Thus, even if this Court liberally construes Doc. 50 as impliedly making a “good cause” 11 argument based on a change in circumstances, the majority of the objections are still 12 forfeited. 13 As to Defendants’ implied argument for good cause, Defendants say, “Defendants 14 did not lodge a written objection to RFP 3 within 30 days of its service on Defendants 15 because Defendants do not believe that the request was necessarily facially improper at the 16 time it was propounded.” Doc. 50 at 1. The Court finds that the following objections of 17 Defendants were known to Defendants at the time RPF 3 was propounded; and, therefore, 18 waived/forfeited by the failure to timely object: 1) relevance; 2) whether the mailing list is 19 protected under Arizona state law; 3) confidentiality of mailing lists; and 4) “CEO” 20 discovery must be limited to personal knowledge. 21 Thus, the only remaining objection is that because Plaintiff has obtained responsive 22 documents from other sources (such as receiving a copy of Defendants’ sent emails from 23 the non-party who received the emails), RFP 3 has become cumulative and duplicative. In 24 considering a cumulative objection, 25 …the court is required to limit discovery when “the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some 26 other source that is more convenient, less burdensome, or less expensive.” Fed. R. Civ. P. 26(b)(2)(C). A discovery request is cumulative or duplicative 27 if the requesting party already has the information that they are seeking to obtain. In those circumstances, the usual course of action is to limit or modify 28 the discovery request upon motion. See Bounkhoun v. Barnes, No. 15-CV- 631, 2020 WL 1526917, at *5 (W.D.N.Y. Mar. 30, 2020) (modifying 1 deposition subpoenas because the requestor already had access to certain information); S.E.C. v. Chen, No. CV157425, 2016 WL 3598108, at *5 (C.D. 2 Cal. Feb. 4, 2016) (ordering that movants need not produce certain records to the extent they are already in the possession of the requestor).

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Photography By Frank Diaz LLC v. Friends of David Schweikert, (D. Ariz. 2023).

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