Renteria v. Liberty Mutual Personal Insurance Company

CourtDistrict Court, D. New Mexico
DecidedJuly 2, 2025
Docket1:23-cv-01093
StatusUnknown

This text of Renteria v. Liberty Mutual Personal Insurance Company (Renteria v. Liberty Mutual Personal Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Renteria v. Liberty Mutual Personal Insurance Company, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

JAVIER RENTERIA,

Plaintiff,

v. No. 1:23-cv-01093-KK-JHR

LIBERTY MUTUAL GROUP INC., LIBERTY MUTAL INSURANCE COMPANY, LIBERTY MUTUAL PERSONAL INSURANCE COMPANY, ONESPAN, INC., and ONESPAN NORTH AMERICA, INC.

Defendants.

MEMORANDUM OPINION AND ORDER GRANTING IN PART PLAINTIFF’S MOTION TO COMPEL [DOC. 69]. THIS MATTER comes before the Court on Javier Renteria’s First Motion to Compel Liberty Mutual Personal Insurance Company [Doc. 69]. Liberty Mutual filed a response [Doc. 73] and Renteria replied [Doc. 76]. The Court has reviewed the briefing, case file, and applicable law. The Court GRANTS IN PART Renteria’s motion to compel. I. PROCEDURAL BACKGROUND On December 8, 2023, Renteria filed suit alleging Liberty Mutual used a fraudulent signature on an uninsured/underinsured motorist coverage waiver to deny Renteria’s claim arising from a severe collision in October 2022. [Doc. 1]. Liberty Mutual filed its answer and a counterclaim on February 19, 2024. [Doc. 9]. Renteria filed an answer to the counterclaim and then an amended answer on March 11, 2024. [Doc. 25]. Magistrate Judge Jennifer M. Rozzoni entered a scheduling order on May 3, 2024, and a stipulated protective order on May 31, 2024. [Docs. 38, 43]. On July 11, 2024, I was reassigned as the case’s referral judge. [Doc. 48 text only]. The parties filed a joint motion to vacate and reset the scheduling order on July 29, 2024. [Doc. 49]. I entered a new scheduling order on August 20, 2024. [Doc. 60]. On September 27, 2024, Renteria filed the instant motion to compel after receiving Liberty Mutual’s objections to his interrogatories and requests for production. [Doc. 69].

II. BRIEFING SUMMARY Renteria moves to compel responses for interrogatories #1–5 and #7–11 and requests for production #1–31, 37, 42, and 44–49. 1 Renteria seeks extensive disclosures of Liberty Mutual’s personnel, files, contracts, handbooks, organization, communications, and other documents as they may relate to Renteria’s policy, Liberty Mutual’s general practices, and OneSpan, the electronic signature service used by Liberty Mutual. [Doc. 69-2].2 Renteria argues that Liberty Mutual’s objections to his discovery requests—overbreadth, undue burden, irrelevance, confidentiality, and privilege—are non-specific, waivable, and otherwise inapplicable. [Doc. 69, at 9–27]; [Doc. 76]. Liberty Mutual responds that it raised valid objections and gave adequate responses to all

discovery requests. [Doc. 73]. III. APPLICABLE LAW Discoverable material includes “any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). Factors include the importance of the issues at stake, the importance of the discovery to resolving those issues, the amount in controversy, the parties’ resources and relative access to information, and the burden of

1 While Liberty Mutual objected to requests for production #32–36, 38–41, and 43, it later supplemented its disclosures and Renteria does not ask the Court to compel responses. [Doc. 69, at 25]. 2 After filing his motion to compel, Renteria filed an amended complaint adding Liberty Mutual Group Inc., Liberty Mutual Insurance Company, OneSpan, Inc. and OneSpan North America, Inc. as defendants. [Doc. 79]. producing the discovery compared to its likely benefit. Id. Courts enjoy considerable discretion to balance these factors. Gomez v. Martin Marietta Corp., 50 F.3d 1511, 1520 (10th Cir. 1995). The scope of discovery is presumptively broad: material that has any possibility of relevance to a claim or defense, even if the material itself is not admissible at trial, may be discoverable. Fed. R. Civ. P. 26(b)(1); Sugar v. Tackett, No. 20-cv-00331, 2021 WL 5769463, at *4 (D.N.M. Dec. 6, 2021)

(quotation omitted). So long as requested discovery appears facially relevant, the objecting party must demonstrate it falls outside Rule 26’s scope. Cardenas v. Dorel Juv. Grp., Inc., 232 F.R.D. 377, 382–83 (D. Kan. 2005). Discovery devices include interrogatories and requests for production. A party may serve an interrogatory inquiring about any matter within the scope of discovery. Fed. R. Civ. P. 33(a)(2). The responding party must answer an interrogatory itself if the party is a natural person, or by an officer or agent if the party is an entity. Fed. R. Civ. P. 33(b)(1). A party may also request for production any discoverable documents, electronically stored information, or tangible thing in the other’s possession or control. Fed. R. Civ. P. 34(a)(1). A responding party has “possession, custody,

or control” of a document if it has the right, authority, or practically ability to obtain and produce it. City of Las Cruces v. United States, No. 17-cv-00809, 2021 WL 330062, at *8 (D.N.M. Feb. 1, 2021); Landry v. Swire Oilfield Servs., L.L.C., 323 F.R.D. 360, 382 (D.N.M. 2018). A responding party must state any objection to an interrogatory or request for production with specificity or risk waiving it. Fed. R. Civ. P. 33(b)(4), 34(b)(2)(C). If a party fails to properly respond to an interrogatory or request for production, the requesting party may move to compel a proper response. Fed. R. Civ. P. 37(a)(3)(B). If granted, the court must award the moving party its reasonable costs for the motion after giving the other party an opportunity to be heard. Fed. R. Civ. P. 37(a)(5)(A). But the court may decline an award if it finds the moving party failed to attempt conferral in good faith, or the other party was substantially justified in refusing the discovery, or other circumstances would make the award unjust. Id. "Substantially justified" means reasonable minds could differ on the appropriateness of the discovery requests served to the responding party. See In re Rael, 753 F. App'x 649, 657 (10th Cir. 2018); Lincoln v. State Farm Fire & Cas. Ins. Co., No. 18-cv-00652, 2019 WL 11623918, at

*2 (D.N.M. June 13, 2019). A court may also reduce a fee award in its discretion, or not award fees at all, if it only partially grants the motion. Fed. R. Civ. P. 37(a)(5)(C); Benavidez v. Sandia Nat’l Lab’ys, 319 F.R.D. 696, 730 (D.N.M. 2017). IV. ANALYSIS Renteria argues globally that Liberty Mutual’s objections do not specify grounds beyond boilerplate statements like “overly broad,” “unduly burdensome,” or “privilege”. [Doc. 69, at 5– 7]. Many of Liberty Mutual’s objections merely state that an interrogatory or request for production “is overly broad, unduly burdensome, . . . and seeks information that is not reasonably calculated to lead to the discovery of admissible evidence.” E.g., [Doc. 69-2, at 11, 18]. That generalization

subjects these objections to waiver. AerSale, Inc. v. City of Roswell, No. 22-cv-00218, 2023 WL 8005213, at *5 (D.N.M. Nov. 17, 2023). To its credit, Liberty Mutual provided some information or documents “notwithstanding” objections.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Frontier Refining Inc. v. Gorman-Rupp Co.
136 F.3d 695 (Tenth Circuit, 1998)
Regan-Touhy v. Walgreen Co.
526 F.3d 641 (Tenth Circuit, 2008)
Murphy v. Deloitte & Touche Group Insurance Plan
619 F.3d 1151 (Tenth Circuit, 2010)
Santa Fe Pacific Gold Corp. v. United Nuclear Corp.
2007 NMCA 133 (New Mexico Court of Appeals, 2007)
Punt v. Kelly Services
862 F.3d 1040 (Tenth Circuit, 2017)
Texas Brine Co. v. Occidental Chem. Corp.
879 F.3d 1224 (Tenth Circuit, 2018)
Cardenas v. Dorel Juvenile Group, Inc.
232 F.R.D. 377 (D. Kansas, 2005)
Moses v. Halstead
236 F.R.D. 667 (D. Kansas, 2006)
Lucero v. Valdez
240 F.R.D. 591 (D. New Mexico, 2007)
Anaya v. CBS Broadcasting, Inc.
251 F.R.D. 645 (D. New Mexico, 2007)
Benavidez v. Sandia National Laboratories
319 F.R.D. 696 (D. New Mexico, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Renteria v. Liberty Mutual Personal Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/renteria-v-liberty-mutual-personal-insurance-company-nmd-2025.