Praecipio Consulting, LLC, et al. v. Nicholas Howser, et al.

CourtDistrict Court, N.D. California
DecidedDecember 3, 2025
Docket4:25-cv-02927
StatusUnknown

This text of Praecipio Consulting, LLC, et al. v. Nicholas Howser, et al. (Praecipio Consulting, LLC, et al. v. Nicholas Howser, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Praecipio Consulting, LLC, et al. v. Nicholas Howser, et al., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 SAN FRANCISCO DIVISION 7 8 PRAECIPIO CONSULTING, LLC, et al. Case No. 25-cv-02927-JST (PHK)

9 Plaintiffs, ORDER RE: DISCOVERY DISPUTE REGARDING AUDIT DOCUMENTS v. 10 Re: Dkt. 59 11 NICHOLAS HOWSER, et al., Defendants. 12

13 INTRODUCTION 14 This case has been referred to the undersigned for all discovery purposes. See Dkt. 29. Now 15 pending before the Court is a joint letter brief regarding a dispute concerning documents relating to 16 an internal audit conducted at Praecipio Consulting. [Dkt. 59]. 17 LEGAL STANDARD 18 The Court has broad discretion and authority to manage discovery. U.S. Fidelity & Guar. 19 Co. v. Lee Inv. LLC, 641 F.3d 1126, 1136 n.10 (9th Cir. 2011) (“District courts have wide latitude 20 in controlling discovery, and their rulings will not be overturned in the absence of a clear abuse of 21 discretion.”); Laub v. U.S. Dep’t of Int., 342 F.3d 1080, 1093 (9th Cir. 2003). The Court’s discretion 22 extends to crafting discovery orders that may expand, limit, or differ from the relief requested. See 23 Crawford-El v. Britton, 523 U.S. 574, 598 (1998) (holding trial courts have “broad discretion to 24 tailor discovery narrowly and to dictate the sequence of discovery”). For example, the Court may 25 limit the scope of any discovery method if it determines that “the discovery sought is unreasonably 26 cumulative or duplicative, or can be obtained from some other source that is more convenient, less 27 burdensome, or less expensive.” Fed. R. Civ. P. 26(b)(2)(C)(i). 1 scope of discovery in federal civil actions and provides that “[p]arties may obtain discovery 2 regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional 3 to the needs of the case.” Information need not be admissible to be discoverable. Id. Relevancy for 4 purposes of discovery is broadly defined to encompass “any matter that bears on, or that reasonably 5 could lead to other matter that could bear on, any issue that is or may be in the case.” In re Williams- 6 Sonoma, Inc., 947 F.3d 535, 539 (9th Cir. 2020) (quoting Oppenheimer Fund, Inc. v. Sanders, 437 7 U.S. 340, 350-51 (1978)); see also In re Facebook, Inc. Consumer Privacy User Profile Litig., No. 8 18-MD-2843 VC (JSC), 2021 WL 10282215, at *4 (N.D. Cal. Sept. 29, 2021) (“Courts generally 9 recognize that relevancy for purposes of discovery is broader than relevancy for purposes of trial.”) 10 (alteration omitted). 11 While the scope of relevance is broad, discovery is not unlimited. ATS Prods., Inc. v. 12 Champion Fiberglass, Inc., 309 F.R.D. 527, 531 (N.D. Cal. 2015) (“Relevancy, for the purposes of 13 discovery, is defined broadly, although it is not without ultimate and necessary boundaries.”). 14 Information, even if relevant, must be “proportional to the needs of the case” to fall within the scope 15 of permissible discovery. Fed. R. Civ. P. 26(b)(1). The 2015 amendments to Rule 26(b)(1) 16 emphasize the need to impose reasonable limits on discovery through increased reliance on the 17 commonsense concept of proportionality: “The objective is to guard against redundant or 18 disproportionate discovery by giving the court authority to reduce the amount of discovery that may 19 be directed to matters that are otherwise proper subjects of inquiry. The [proportionality 20 requirement] is intended to encourage judges to be more aggressive in identifying and discouraging 21 discovery overuse.” Fed. R. Civ. P. 26 advisory committee’s note to 2015 amendment. In 22 evaluating the proportionality of a discovery request, the Court considers “the importance of the 23 issues at stake in the action, the amount in controversy, the parties' relative access to the information, 24 the parties' resources, the importance of the discovery in resolving the issues, and whether the burden 25 or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). 26 The party seeking discovery bears the burden of establishing that its request satisfies the 27 relevancy requirements under Rule 26(b)(1). La. Pac. Corp. v. Money Mkt. 1 Inst. Inv. Dealer, 285 1 discovery should not be allowed. Id. The resisting party must specifically explain the reasons why 2 the request at issue is objectionable and may not rely on boilerplate, conclusory, or speculative 3 arguments. Id.; see also Blankenship v. Hearst Corp., 519 F.2d 418, 429 (9th Cir. 1975) (“Under 4 the liberal discovery principles of the Federal Rules defendants were required to carry a heavy 5 burden of showing why discovery was denied.”). 6 With regard to proportionality, “[t]he parties and the court have a collective responsibility 7 to consider the proportionality of all discovery and consider it in resolving discovery disputes.” Fed. 8 R. Civ. P. 26 advisory committee’s note to 2015 amendment. “A party claiming undue burden or 9 expense ordinarily has far better information—perhaps the only information—with respect to that 10 part of the determination. A party claiming that a request is important to resolve the issues should 11 be able to explain the ways in which the underlying information bears on the issues as that party 12 understands them. The court’s responsibility, using all the information provided by the parties, is 13 to consider these and all the other factors in reaching a case-specific determination of the appropriate 14 scope of discovery.” Id. 15 As part of its inherent discretion and authority, the Court has broad discretion in determining 16 relevancy for discovery purposes. Surfvivor Media, Inc. v. Survivor Prods., 406 F.3d 625, 635 (9th 17 Cir. 2005) (citing Hallett v. Morgan, 296 F.3d 732, 751 (9th Cir. 2002)). Similarly, a district court’s 18 determination as to proportionality of discovery is within the district court’s discretion. See Jones 19 v. Riot Hospitality Grp. LLC, 95 F.4th 730, 737-38 (9th Cir. 2024) (finding district court did not 20 abuse discretion on proportionality ruling). Ultimately, “the timing, sequencing and proportionality 21 of discovery is left to the discretion of the Court.” Toro v. Centene Corp., No. 19-cv-05163 LHK 22 (NC), 2020 WL 6108643, at *1 (N.D. Cal. Oct. 14, 2020). 23 Under Rule 26, a party “who has responded to an interrogatory, request for production, or 24 request for admission—must supplement or correct its disclosure or response: (A) in a timely 25 manner if the party learns that in some material respect the disclosure or response is incomplete or 26 incorrect, and if the additional or corrective information has not otherwise been made known to the 27 other parties during the discovery process or in writing[.]” Fed. R. Civ. P. 26(e)(1)(A).

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Bluebook (online)
Praecipio Consulting, LLC, et al. v. Nicholas Howser, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/praecipio-consulting-llc-et-al-v-nicholas-howser-et-al-cand-2025.