Raiser v. San Diego County

District Court, S.D. California·Decided July 9, 2021·No. 3:19-cv-00751·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 AARON RAISER, Case No.: 19-cv-0751-GPC-KSC

12 Plaintiff, ORDER: 13 v. (1) OVERRULING PLAINTIFF’S 14 SAN DIEGO COUNTY, et al., OPPOSITIONS TO THE 15 Defendants. MAGISTRATE JUDGE’S ORDER; AND 16

17 (2) ADOPTING THE REPORT AND RECOMMENDATION 18

19 [ECF Nos. 101, 112, 128, 131]

21 I. INTRODUCTION 22 On January 13, 2021, Magistrate Judge Karen S. Crawford issued (1) an Order 23 denying Plaintiff’s request for additional time to comply with the Magistrate Judge’s 24 Chambers Rule VIII.A, and for monetary sanctions against Defendants; and (2) a Report 25 and Recommendation (“R&R”) recommending that this Court deny Plaintiff’s request for 26 default judgment (referenced in Plaintiff’s underlying documents as “terminating 27 1 sanctions”) against Defendants.1 ECF No. 112. Plaintiff challenged these decisions in 2 two Oppositions, in which the later document amends the former. See ECF Nos. 128, 3 131. Upon considering the moving papers and the record of the case, the Court 4 OVERRULES Plaintiff’s Oppositions and ADOPTS in full the R&R. 5 II. RELEVANT BACKGROUND 6 At the center of this dispute is Plaintiff’s desire to conduct depositions without a 7 court reporter reasoning that a public notary would suffice. Defendants did not agree to 8 such arrangements and declined to attend the depositions that Plaintiff scheduled without 9 a court reporter. Eventually, Plaintiff sought sanctions for Defendants’ failure to attend 10 the depositions. Accordingly, a detailed description of the procedural history is provided. 11 A. Plaintiff’s Initial Deposition Requests 12 On August 13, 2020, at 6:30 PM and 6:39 PM, Plaintiff sent two emails to 13 Defendants’ counsel concerning depositions. The emails asked if Defendants agreed to 14 (1) conduct depositions via Zoom, and (2) have the deposition “be taken before any 15 person.” See ECF No. 70-1 at 35–38.2 16 The next day, before Defendants had an opportunity to respond to Plaintiff’s email 17 and before the Parties met and conferred,3 see id. at 5, 40, Plaintiff filed an Ex Parte 18

19 20 1 Hereinafter, the Court replaces the phrase “terminating sanctions” with “default judgment.” See Fed. R. Civ. P. 37(b)(2)(A)(vi). This is to avoid the potential confusion 21 of interpreting “terminating sanctions” to mean “terminating existing sanctions,” 22 although the Court is aware that “terminating sanctions” is a term used as well. 23 2 References to specific page numbers in a document filed in this case correspond to the page numbers assigned by the Court’s Electronic Case Filing (“ECF”) system. 24 3 Indeed, the Court observes that the docket entry was made at 4:27 PM, see ECF No. 68, 25 which means that Plaintiff gave Defendants less than 24 hours to respond, not even 26 accounting for the fact that Plaintiff sent the emails after typical business hours. See also ECF No. 70 at 10. 27 1 Application. ECF No. 68. The Ex Parte Application, in part, asked for: (1) depositions 2 via Zoom, (2) “record[ing] the depositions using Zoom and then to have them transcribed 3 later if needed,” and (3) “‘any person’ be the deposition officer.” See ECF No. 68-1 at 4 11–12. 5 Responding to Plaintiff’s Ex Parte Application, Defendants filed an Opposition on 6 August 19, 2020. ECF No. 70. As part of the Opposition, Defendants discussed how 7 Plaintiff’s Ex Parte Application was procedurally improper, including Plaintiff’s failure 8 to meaningfully engage in meet-and-confer communications. Cf. Magistrate Judge 9 Crawford Chambers Rule VIII.A; CivLR 26.1. And while Defendants did not oppose 10 conducting depositions via Zoom, they stated they do not waive the protections provided 11 under Federal Rule of Civil Procedure (“FRCP”) 30 to have a deposition officer present. 12 Defendants raised a host of concerns, such as: (1) how the deposition officer must 13 conduct the recording of the deposition and not be a party to the lawsuit, (2) whether 14 Plaintiff can adequately and reliably record his questioning, especially given Plaintiff’s 15 internet connection issues, (3) admissibility concerns unless a stenographic transcript is 16 created, and (4) how Plaintiff will almost certainly need to hire an individual to create a 17 transcript of any recording of the deposition. See ECF No. 70 at 10–11. 18 On September 2, 2020, Plaintiff made a similar request in another Ex Parte 19 Application (among many other Ex Parte Applications filed in the process). ECF No. 78. 20 Here, Plaintiff requested that he himself be the deposition officer. Defendants 21 immediately filed an Opposition, once again discussing the need for FRCP 30 22 protections, such as a third-party officer, a certified deposition transcript, and the officer 23 administering oaths. See ECF No. 79. 24 B. Plaintiff’s First Deposition Notice 25 While the Magistrate Judge’s ruling on Plaintiff’s Ex Parte Applications was 26 pending, the Parties also corresponded with each other regarding deposition dates. See 27 1 ECF No. 101 at 4. Eventually Plaintiff sent Defendants the deposition notices. The 2 notices were signed by Plaintiff on August 26, 2020, and informed Defendants that the 3 depositions will take place on September 10, 2020. See ECF No. 101-3. On August 27, 4 2020, Defendants’ counsel via email acknowledged receipt, but asked “who the 5 [deposition] officer is, who will be responsible for recording the deposition, and if 6 [Plaintiff] hired a court reporter.” ECF No. 101 at 4. 7 No part of the record indicates that Plaintiff replied to the counsel’s August 27, 8 2020 email. Instead, on September 9, 2020, Plaintiff emailed Defendants’ counsel that 9 “depositions are on for tomorrow” since Plaintiff had hired a “California notary.” See id. 10 at 5. Counsel replied the same day that the presence of a notary would merely solve the 11 issue regarding an appropriate oath administrator, still failing to address the other 12 concerns Defendants raised in their Oppositions. Counsel also expressed to Plaintiff that 13 it would be best to wait for the Magistrate Judge to issue rulings on Plaintiff’s other 14 pending Ex Parte Applications, and that Defendants would not appear at the September 15 10, 2020 deposition absent a court order. See id. About an hour later, Plaintiff disclosed 16 the name of the deposition officer, and stated that she can record the deposition and that 17 no rules prohibit Plaintiff or anyone from making the transcript. See id. at 7. While 18 Plaintiff also asked Defendants’ counsel if they can contact the Magistrate Judge 19 concerning the matter, the counsel informed he was disinclined to do so. This was 20 because according to the counsel, Plaintiff had already filed briefings that “directly raise 21 the issues we’d call about,” and the Magistrate Judge’s Chambers Rules do not allow for 22 a same-day conference. See id. 23 C. The Magistrate Judge’s Order on Depositions 24 On October 5, 2020, the Magistrate Judge issued an Order concerning the various 25 Ex Parte Applications that Plaintiff filed, including the ones concerning Plaintiff’s 26 requests to conduct depositions in the way discussed above. Specifically, the Magistrate 27 1 Judge denied “Plaintiff’s request to conduct depositions without an independent, 2 qualified deposition officer who meets the requirements of Rule 30 of the Federal Rules 3 of Civil Procedure.” ECF No. 87 at 8. 4 D. Plaintiff’s Second Deposition Notice 5 On October 12, 2020, Plaintiff reached out to Defendants’ counsel regarding 6 potential deposition dates. See ECF No. 101 at 5.

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