Renata Shiloah, on behalf of herself and all others similarly situated v. GEICO Indemnity Company

CourtDistrict Court, W.D. New York
DecidedMarch 13, 2026
Docket6:24-cv-06447
StatusUnknown

This text of Renata Shiloah, on behalf of herself and all others similarly situated v. GEICO Indemnity Company (Renata Shiloah, on behalf of herself and all others similarly situated v. GEICO Indemnity Company) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Renata Shiloah, on behalf of herself and all others similarly situated v. GEICO Indemnity Company, (W.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

RENATA SHILOAH, on behalf of herself and all others similarly situated, DECISION AND ORDER Plaintiff, v. 6:24-CV-06447 EAW CDH

GEICO INDEMNITY COMPANY,

Defendant.

INTRODUCTION In this putative class action, plaintiff Renata Shiloah (“Plaintiff”) asserts a claim for breach of contract based on defendant GEICO Indemnity Company’s (“Defendant” or “GEICO”) failure to pay sales tax as part of the “actual cash value” for total loss vehicles. (Dkt. 1). Pending before the Court is Plaintiff’s motion for an order requiring Defendant to “further respond” to Plaintiff’s requests for admission and, if necessary, to modify the Scheduling Order entered in this case.1 (Dkt. 82). For the reasons below, Plaintiff’s motion is granted in part and denied in part. The Court further concludes that it is unnecessary to modify the Scheduling Order.

1 Though not styled as such, Plaintiff’s motion seeks to invoke the Court’s authority to determine the sufficiency of answers or objections to requests for admission under Federal Rule of Civil Procedure 36(a)(6). To clarify, this is distinct from a motion to compel discovery pursuant to Rule 37(a). See, e.g., Goodyear Tire & Rubber Co. v. CEVA Logistics Singapore, Ltd., 348 F.R.D. 54, 83 (E.D. La. 2024). BACKGROUND This case has been referred to the undersigned for all pretrial matters excluding dispositive motions. (Dkt. 29). Familiarity with the background of this case

is assumed and the procedural history of this matter is discussed only in relevant part. Plaintiff commenced this action on July 17, 2024. (Dkt. 1). On August 22, 2025, the Court issued a Scheduling Order, which provides that the parties may engage in an initial period of non-expert fact discovery in connection with Plaintiff’s anticipated motion for class certification, to be completed by October 15, 2025. (Dkt. 65 at 1-2). On September 9, 2025, Plaintiff served her second set of requests for admission

(“RFAs”). (Dkt. 83 at ¶ 5). The instant motion concerns a dispute over RFAs 8 and 11 in Plaintiff’s second set of requests. As initially served, RFA 8 stated: 8. Admit that when adjusting first party claims for total loss by Your New York policyholders during the Relevant Time Period You elected to make a cash settlement as that phrase is used in 11 NYCRR § 216.7(c).

(Dkt. 83-1 at 5). As initially served, RFA 11 stated:

11. Admit that the valuation reports You obtained from CCC Intelligent Solutions Inc. to determine the values of the total loss vehicles when adjusting first party claims for total loss by Your New York policyholders during the Relevant Time Period were generated using a computerized database.

(Id. at 6).

On October 9, 2025, Defendant served its objections and responses to Plaintiff’s second set of requests for admission. (Dkt. 83 at ¶ 12). Defendant interposed general and specific objections. One of Defendant’s specific objections to RFAs 8 and 11 was that they would “require[] an individual claim file by claim file review of every first- party total loss claim GEICO adjusted in New York between July 17, 2018 and the present.” (Dkt. 83-2 at 3-4, 6-7). After interposing its objections, Defendant responded

to RFA 8 as follows: Subject to and without waiving these objections, GEICO DENIES this Request as GEICO could not respond to this Request without reviewing each of the tens of thousands of first-party total loss claims GEICO adjusted in New York between July 17, 2018 and the present, which is unduly burdensome and not appropriate for a putative class action.

(Id. at 4). Defendant’s response to RFA 11 was identical. (Id. at 7).

The parties subsequently corresponded with each other about Defendant’s responses via letter and held a meet and confer on October 28, 2025. (Dkt. 83 at ¶ 15). Following their meet and confer, the parties each submitted letters to the Court outlining the dispute over the RFAs and the parties’ respective positions. On November 18, 2025, the Court held a telephonic discovery conference with the parties and directed them to make further efforts to meet and confer. (Dkt. 77). The parties held another meet and confer on November 25, 2025. (Dkt. 83 at ¶ 23). Following this meet and confer, Plaintiff proposed revising RFA 8 to instead refer to GEICO’s “general practice, policy, or procedure” regarding cash settlements. (Id. at ¶ 25). Defendant responded by asserting that this proposed revision would constitute a brand new RFA and objected on the grounds that the initial period of non-expert, class-focused fact discovery had closed. (Id. at ¶ 26). After the parties could not agree informally to a rewording of RFAs 8 and 11, Plaintiff served a revised set of RFAs on December 4, 2025. (Id. at ¶ 29). Plaintiff’s revised RFA 8 (“Revised RFA 8”) requests:

8. Admit that when adjusting first party claims for total loss by Your New York policyholders during the Relevant Time Period it was Your general practice, policy, or procedure to elect to make a cash settlement as that phrase is used in 11 NYCRR § 216.7(c).2

(Dkt. 83-6 at 5). Plaintiff also revised RFA 11. (Id. at 6). On December 11, 2025, Defendant served amended objections and responses to Plaintiff’s revised set of RFAs. (Dkt. 83 at ¶ 30). Defendant formally objected to Revised RFA 8 on the grounds that it “constitutes a new and different Request that was not timely served[.]” (Dkt. 83-7 at 4). Defendant also amended its response. The amended response to Revised RFA 8 states: Because Plaintiff purports to serve this Request beyond the Court- imposed deadline to complete all class focused fact discovery, GEICO need not and does not respond to this Request. To the extent a response is nonetheless required, GEICO DENIES this Request based on its objections.

(Id. at 5) (formatting omitted). Defendant also objected to and denied Plaintiff’s revised RFA 11. (Id. at 6-7). The parties held another meet and confer on December 30, 2025, during which they discussed potential further revisions to RFA 11 centered around removing “the suggestion that GEICO use[s] [CCC] reports to determine vehicle values.” (Dkt. 83 at

2 Revised RFA 8 is the last served iteration of this request. ¶ 37). On December 31, 2025, Plaintiff served a second revised set of RFAs. (Id. at ¶ 38). The second revised RFA 11 (“Second Revised RFA 11”) requests: 11. Admit that the valuation reports You obtain from CCC Intelligent Solutions Inc. when adjusting first party claims for total loss by Your New York policyholders during the Relevant Time Period were generated using one or more computerized databases.3

(Dkt. 83-10 at 4) (formatting omitted).

On January 7, 2026, Defendant served its second amended responses and objections. (Dkt. 83 at ¶ 39). Defendant again interposed objections based on, inter alia, its view that the request relies on incorrect assumptions about GEICO’s use of CCC reports. (Dkt. 83-11 at 4). After interposing its objections, Defendant’s response to Second Revised RFA 11 states: Subject to and without waiving these objections, GEICO DENIES Plaintiff’s Second Revised Request for Admission No. 11.

(Id. at 5). On January 9, 2026, the Court held a second telephonic discovery conference with the parties. (Dkt. 80). When it became apparent during the conference that the parties were at an impasse with respect to their informal efforts to resolve the RFA dispute, the Court set a briefing schedule for the instant motion. (See id.). Plaintiff filed the instant motion on January 16, 2026. (Dkt. 82).

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Renata Shiloah, on behalf of herself and all others similarly situated v. GEICO Indemnity Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/renata-shiloah-on-behalf-of-herself-and-all-others-similarly-situated-v-nywd-2026.