Plain v. Safeport Insurance Company

CourtDistrict Court, M.D. Louisiana
DecidedMay 8, 2025
Docket3:23-cv-00740
StatusUnknown

This text of Plain v. Safeport Insurance Company (Plain v. Safeport Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Plain v. Safeport Insurance Company, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

KENDALL PLAIN CIVIL ACTION

VERSUS

SAFEPORT INSURANCE COMPANY NO. 23-740-BAJ-RLB

ORDER Before the Court are Safeport Insurance Company’s (“Defendant”) Motion to Compel Discovery and Kendall Plain’s (“Plaintiff”) opposition. (R. Docs. 36; 41). Also before the Court is Defendant’s Reply. (R. Doc. 50). I. Background On August 16, 2023, Plaintiff commenced this action to recover for breach of contract, violations of Louisiana insurance law, and bad faith from his insurer, Defendant, with respect to property loss resulting from Hurricane Ida that occurred on August 29, 2021. (R. Doc. 1). On December 10, 2024, Defendant served interrogatories and requests for production (“RFP(s)”) on Plaintiff through his counsel at the time. (R. Docs. 36-2; 36-4). Responses were initially due on January 9, 2025, but this deadline was changed to February 18, 2025, following many communications between Defendant’s counsel and Plaintiff’s counsel at the time. (R. Doc. 36-3). Plaintiff’s and Defendant’s counsel also discussed setting up a deposition of Plaintiff, but no date was agreed upon. On February 13, 2025, Plaintiff’s counsel filed a Motion to Withdraw, wherein he sought leave to withdraw as counsel of record for Plaintiff. (R. Doc. 29). Five days later, this Court granted the Motion to Withdraw, noting the objection of Plaintiff, but finding no reason to compel counsel to continue representing Plaintiff. (R. Doc. 31). On February 19, 2025, Defendant filed a Motion to Compel Discovery, which sought an order compelling Plaintiff to provide complete discovery responses and deposition dates. (R. Doc. 32). This motion was emailed to Plaintiff on the same day and proof of service was filed into the record on March 7, 2025. (R. Docs. 33; 36-5 at 4). On March 10, 2025, Plaintiff, now appearing pro se, filed an Emergency Motion for Relief Under Rule 59(e), and Rule 60(b), for Rehearing on Motion to Withdraw, for Stay of

Proceedings, for Updated Scheduling Order, and for Extension of Time to File Opposition to Motion to Compel Discovery. (R. Doc. 34). On March 11, 2025, this Court (1) denied the motion to the extent it sought reconsideration of the Court’s order allowing Plaintiff’s former counsel to withdraw, (2) denied the motion as moot to the extent it sought modification of any deadlines or a stay of this proceeding, (3) required the parties to meet and confer with respect to the order, and (4) denied Defendant’s Motion to Compel Discovery without prejudice to refile on or before April 3, 2025 or as otherwise allowed pursuant to Local Rule 26(d). (R. Doc. 35). The same day, Defendant’s counsel emailed Plaintiff, noting he had called Plaintiff in compliance with the court’s order but Plaintiff had not picked up the phone. (R. Doc. 36-5 at 3).

Throughout March, Defendant’s counsel called and emailed Plaintiff, but received no response. (R. Doc. 36-5). Then, on March 18, 2025, a telephone conference was held, and it was agreed that Plaintiff had until March 21, 2025 to provide his responses to the first set of discovery requests. (R. Doc. 36-6). The parties also “agreed upon an extension of the pending deadlines in the scheduling order by 90 days.” Id. (emphasis in original). Plaintiff noted he wished to reopen past deadlines and would be seeking a stay of the case; Defendant noted it was opposed to this. On March 25, 2025, Defendant filed the instant motion, asking this Court to compel Plaintiff to respond to the still outstanding discovery requests and to provide what dates he would be available for a deposition. (R. Doc. 36). Defendant also asked this Court to sanction Plaintiff by requiring him to pay the costs and attorneys’ fees associated with the motion and/or dismissing Plaintiff’s case. The next day Plaintiff filed a Motion for Status Conference, Request for Stay, and Relief under Rules 59(e) and 60(b), seeking a stay of deadlines, as well as extensions, to provide him the opportunity to obtain new counsel. (R. Doc. 37). Noting that

Plaintiff himself is an attorney, this Court determined that Plaintiff had already been afforded plenty of time—two months—to obtain counsel such that a stay would not be provided and no deadlines would be extended at that time. (R. Doc. 40). Following this court’s order, Plaintiff filed his response on April 15, 2025, stating that the motion to compel was improper because he was not himself served with the relevant discovery requests before the motion to compel was filed and because no formal Fed. R. Civ. P. 37 conference occurred.1 (R. Doc. 41). Plaintiff also noted he recently responded to Defendant’s discovery requests and offered some dates that he would be available for a deposition. Defendant filed its reply the next day, arguing Plaintiff’s responses were insufficient and requesting a deadline for Plaintiff to appear for a deposition. (R.

Doc. 50). II. Law and Analysis A. Legal Standards If a party fails to respond fully to written discovery requests in the time allowed by the parties or by the Federal Rules of Civil Procedure, the party seeking discovery may move to compel responses. See Fed. R. Civ. P. 37. An “evasive or incomplete . . . response must be treated as a failure to disclose, answer or respond.” Fed. R. Civ. P. 37(a). “Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery

1 This Court notes that service on Plaintiff’s attorneys was service upon Plaintiff, and Plaintiff did not need to be re- served the requests after his counsel withdrew from the case. A proper Fed. R. Civ. P. 37 conference also occurred. regarding any non-privileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of

discovery need not be admissible in evidence to be discoverable.” Fed. R. Civ. P. 26(b)(1). The court must limit the frequency or extent of discovery if it determines that “(i) the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive; (ii) the party seeking discovery has had ample opportunity to obtain the information by discovery in the action; or (iii) the proposed discovery is outside the scope permitted by Rule 26(b)(1).” Fed. R. Civ. P. 26(b)(2)(C). B. Fed. R. Civ. P. 37 Conference Motions to compel must include certificates “that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an

effort to obtain it without court action.” Fed. R. Civ. P. 37. A Fed. R. Civ. P.

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