Rutherford v. Central Bank of Kansas City

District Court, W.D. Washington·Decided August 21, 2025·No. 3:24-cv-05299·Unknown

Opinion

WESTERN DISTRICT OF WASHINGTON SAMUEL C. RUTHERFORD, III, Case No. 3:24-cv-05299-TLF Plaintiff, v. ORDER ON PLAINTIFF’S MOTION TO COMPEL (DKT. 76) CENTRAL BANK OF KANSAS CITY, Defendant.

Plaintiff Samuel Rutherford III seeks an order compelling Defendant Central Bank of Kansas City (“CBKC”) to produce certain categories of documents and responses to plaintiff’s First Set of Interrogatories and First Request for Production of Documents, and further, ordering defendant to pay plaintiff’s attorney fees incident to this motion. Dkt. 76. CBKC claims they have responded to plaintiff’s interrogatories and document requests that are in their own possession; any requests that require CBKC to produce documents on behalf of third parties are not appropriate because those documents are not in their custody or control and many of plaintiff’s other discovery requests are irrelevant to the issues that remain in this case.1

1 CBKC further states the Court should deny plaintiff’s motion to compel for failure to comply with the Standing Order. The Order defendant refers to is a Sample Order Setting Forth Court Procedures that is available on the undersigned’s judicial website (Chief Magistrate Judge Theresa L. Fricke Chambers | Western District of Washington | United States District Court). It is a sample order intended to provide parties with an example of an order setting forth certain procedures that may be entered into a civil case; Plaintiff’s motion to compel is GRANTED in part and DENIED in part. Plaintiff’s motion for attorney fees is DENIED. Plaintiff brought this class action suit against CBKC to recover damages for

prepaid debit card fees charged to persons released from Pierce County Jail. Plaintiff alleges CBKC violated the Electronic Transfer Fund Act (“EFTA”) when it issued unsolicited debit cards and charged fees that plaintiff did not agree to. Plaintiff further alleges violations of the Washington Consumer Protection Act (“WCPA”) and contends defendant is liable for conversion and unjust enrichment under Washington state law. Dkt. 1, Complaint. Plaintiff served interrogatories and document requests on CBKC on February 19, 2025. Dkt. 78, Declaration of Chris R. Youtz, at ¶2. CBKC responded to plaintiff’s discovery requests on April 21, 2025. Id. ¶4. The parties engaged in a discovery conference and exchanged several emails. On June 23, 2025, plaintiff’s counsel had a

telephone conference with CBKC’s counsel in an attempt to resolve their discovery disputes before filing the instant motion to compel. Id. ¶28. On June 24, 2025, the Court denied CBKC’s summary judgment motion on plaintiff’s claim under 15 U.S.C. 1693i, which prohibits the unauthorized issuance of debit cards, and his Washington state law claims; the Court granted CBKC ‘s motion for summary judgment on plaintiff’s claim under 15 U.S.C. 1693l-1, which prohibits general- use prepaid card service fees. Dkt. 73. it was not ordered by the Court in this case. Because it was not a standing order and did not become a docketed order in this case, the parties are not required to comply with the sample order. The Federal Rules of Civil Procedure authorize parties to obtain discovery of any nonprivileged information discoverable under Rule 26 if it is (1) relevant, and (2) proportional to the needs of the case. Fed. R. Civ. P. 26(b)(1). Federal Rule of Civil

Procedure 26(b)(1), as amended in 2015, provides that parties— may obtain discovery regarding any nonprivileged 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 the 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. Id.

Evidence must be “relevant to any party's claim or defense” to fall within the scope of permissible discovery. Id. The 2015 amendment to Rule 26(b) deleted the phrase “reasonably calculated to lead to the discovery of admissible evidence” because it was often misconstrued to define the scope of discovery and had the potential to “swallow any other limitation.” Fed. R. Civ. P. 26(b)(1) advisory committee notes to 2015 amendment. See also San Diego Unified Port Dist. v. Nat'l Union Fire Ins. Co. of Pittsburg, PA, No. 15CV1401-BEN-MDD, 2017 WL 3877732, at *1 (S.D. Cal. Sept. 5, 2017). The amendment replaced this phrase with the statement that information “need not be admissible in evidence to be discoverable.” Fed. R. Civ. P. 26(b)(1) advisory committee notes to 2015 amendment. Information must also be “proportional to the needs of the case” to fall within the scope of permissible discovery. Fed. R. Civ. P. 26(b)(1). When analyzing the proportionality of a party's discovery requests, a court should consider the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to the 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. Id.

Federal Rule of Civil Procedure 33 provides that a party may serve on any other party interrogatories that relate to any matter within the scope of discovery defined in Rule 26(b). Fed. R. Civ. P. 33(a)(2). Under Federal Rule of Civil Procedure 34, a party may request the production of documents within the scope of Rule 26(b). Fed. R. Civ. P. 34(a). When a party objects to an interrogatory or request for production, that objection can neither be a boilerplate objection nor a blanket refusal. See Burlington N. & Santa Fe Ry. Co. v. U.S. Dist. Court for the Dist. of Mont., 408 F.3d 1142, 1149 (9th Cir. 2005). If a party fails to answer an interrogatory or produce documents, or if the

response provided is evasive or incomplete, the propounding party may bring a motion to compel. See Fed. R. Civ. P. 37(a). The party opposing the discovery bears the burden of resisting disclosure. Bryant v. Armstrong, 285 F.R.D. 596, 600 (S.D. Cal. 2012). If a motion to compel is granted or the disclosure or requested discovery is provided after the filing of the motion, the court must order the offending party “to pay the movant's reasonable expenses incurred in making the motion, including attorney's fees” unless “(i) the movant filed the motion before attempting in good faith to obtain the disclosure or discovery without court action; (ii) the opposing party's nondisclosure,

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