Sacerdote v. Retirement Plan Committee

CourtDistrict Court, S.D. New York
DecidedFebruary 9, 2024
Docket1:17-cv-08834
StatusUnknown

This text of Sacerdote v. Retirement Plan Committee (Sacerdote v. Retirement Plan Committee) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sacerdote v. Retirement Plan Committee, (S.D.N.Y. 2024).

Opinion

Nixon Peabody LLP Charles M. Dyke N 1X0 N One Embarcadero Center, 32nd Floor Partner, ERISA Litigation Practice Leader San Francisco, CA 94111 P EA B 0 DY Attorneys atlaw —T / 415.984.8315 sponpesbodyco” F/844.540.4098 cdyke@nixonpeabody.com MEMO ENDORSED February 8, 2024 \Vwy yd 2 HON. VALERIE FIGUEREDO Via ECF UNITED STATES MAGISTRATE JUDGE DATED: 2/9/2024 Hon. Valerie Figueredo Plaintiffs are directed to provide a United States District Court for the response to the issues addressed Southern District of New York herein by no later than 5:00 p.m. Daniel Patrick Moynihan Courthouse on Wednesday, February 14, 2024. 500 Pearl Street New York, New York 10007-1312 Re: Sacerdote v. Cammack LaRhette Advisors, LLC., No. 1:17-cv-8834-AT-VEF (S.D.N.Y.) Dear Magistrate Judge Figueredo: I write on behalf of Cammack LaRhette Advisors, LLC (“Cammack”) to request a pre-motion discovery conference in accordance with § ILc. of this Court’s Individual Practices and Local Civil Rule 37.2. On February 6, 2024, my office was served with the attached Fed. R. Civ. P. 30(b)(6) Notice of Deposition of Cammack seeking testimony on eight topics aimed at discovering Cammack’s net worth and finances, as well as the terms of a corporate transaction (“Deposition Notice”) (See Exh. A). It was unilaterally noticed for February 16, 2024, the day that discovery in this matter closes. (Dkt. 269 □□□□ 5-6.) On February 7, 2024, I emailed Joel Rohlf and Michael Wolff, counsel for Plaintiffs, objecting to the Notice on the ground that it was untimely and unreasonable under the circumstances, and indicating that in any event Cammack and its counsel are unavailable on February 16, 2024. Mr. Rohlf responded that Plaintiffs’ counsel were informed “for the first time” on February 5, 2024, that Cammack “may have insufficient funds to satisfy a possible judgment against it.” He also stated that the Deposition Notice “seeks information that Cammack is required to keep as part of its records by Massachusetts law and should be readily available.” On February 8, 2024, at 11:30 a.m. (PST), counsel for the parties conducted a telephonic meet-and- confer that lasted approximately 30 minutes. The conference was attended by the undersigned and Dawn Valentine for Cammack, and by Messrs. Rohlf and Wolff for Plaintiffs. Since neither I nor anyone at Cammack had ever said to counsel for Plaintiffs that Cammack may have insufficient assets to satisfy a possible judgment against it, and since a focus of Plaintiffs’ Notice appeared to relate to a publicized transaction in January 2021 in which CAPTRUST acquired the assets of Cammack Retirement Group (i.e., Topic 5 in the Notice of Deposition, see Ex. A), which had recently been mentioned, I began the call by asking counsel if they were taking the position that they had been

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February 8, 2024 Page 2 unaware of the January 2021 transaction prior to February 5. (A copy of CAPTRUST’s press release concerning the transaction is attached as Exhibit B.) Mr. Rohlf responded that Plaintiffs were not taking that position and in fact had been aware of the January 2021 transaction long before February 5. I then noted that Cammack and its counsel had never told Plaintiffs’ counsel that Cammack may have insufficient assets to satisfy a possible judgment, and Mr. Rohlf agreed that was the case. I then asked Mr. Rohlf to let us know what “possible judgment” he was referring to. He was unable to answer. So I indicated that if Plaintiffs in this case were able to obtain a judgment for the same $358 million (or more) in damages on their claims against Cammack that they had asserted on the identical claims they tried and lost against NYU in Sacerdote v. New York Univ., 328 F. Supp. 3d 273 (S.D.N.Y. 2018) (Sacerdote I), then Cammack would stipulate that it would not be able to satisfy such a judgment. Otherwise, Cammack long ago produced in discovery copies of its insurance coverage, and there is no basis for believing that Cammack could not meet its obligations under the law to satisfy a judgment, if Plaintiffs could obtain one. Meanwhile, Plaintiffs’ counsel have long known about the publicized transaction with CAPTRUST, and if Plaintiffs had had any concerns, they should have initiated discovery long ago. Mr. Rohlf responded by re-asserting that Plaintiffs first heard (from someone other than Cammack) on February 5 that Cammack “may have insufficient assets to satisfy a possible judgment,” and the information sought should be readily available.

Mr. Wolff asked what prejudice Cammack would suffer from having to sit for a new deposition, and I responded that two depositions in this case already are set for February 13 and 15, 2024, and neither Cammack nor counsel is available to sit on February 16 or to prepare for such a deposition. Mr. Wolff indicated his belief that the topics were simple and easy for a witness to testify on, and I disagreed, walking him through the topics and explaining the burden. Mr. Wolff said he was unpersuaded.

Mr. Wolff indicated that Plaintiffs should be allowed to discover whether funds had been “siphoned off” from Cammack “to avoid paying a judgment.” I asked him the evidentiary basis for any such belief, and he responded with a circular argument: Cammack’s unwillingness to agree to sit for the noticed deposition constituted such evidence. Finally, Ms. Valentine indicated that this inquiry, if it were proper, should have been conducted via written discovery rather than depositions. Mr. Wolff disagreed. I then noted the parties’ impasse and indicated that Cammack would be filing this letter with the Court.

For the reasons set forth below, Cammack requests a pre-motion discovery conference and an order taking the deposition of Cammack off-calendar, at least until after the discovery conference is completed and any needed motion for protective order is heard and decided.

Plaintiffs Failed to Provide Cammack Reasonable Notice

Plaintiffs have failed to provide Cammack with reasonable notice. The Deposition Notice seeks to conduct a 30(b)(6) deposition on the last day of discovery on matters that could have been explored in 2022 or 2023, with only eight business-days’ notice. Notice must be reasonable under the circumstances. Davidson v. Dean, 204 F.R.D. 251, 256 (S.D.N.Y. 2001). Courts have “generally determined that 14 days is presumptively reasonable.” JB Aviation LLC v. R. Aviation Charter Servs., LLC, 2016 Dist. LEXIS 112703, *8 (E.D.N.Y. 2016). See also Brown v. Hendler, 2011 U.S. Dist. LEXIS 9476, *5 February 8, 2024 Page 3 (S.D.N.Y. 2011) (“Although Rule 45 does not define ‘reasonable time,’ many courts have found 14 days from the date of service as presumptively reasonable.”). Plaintiffs’ Notice of Deposition falls far short of the 14-day standard.

A Rule 30(b)(6) deposition notice requires that a party must produce witnesses, “but more importantly, prepare them so that they may give complete, knowledgeable and binding answers on behalf of the corporation.” SEC v. Morelli, 143 F.R.D. 42, 45 (S.D.N.Y. 1992). Demanding that a party identify and adequately prepare 30(b)(6) witnesses on eight business days’ notice is unreasonable and unrealistic. See Holloway v. 3M Co., 2019 U.S. Dist. LEXIS 222001, *74 (C.D. Cal. 2019) (holding that nine days’ notice for a person most knowledgeable deposition is not reasonable and granting protective order); Kilby v. CVS Pharm., Inc., 2017 U.S. Dist. LEXIS 63502, *2-3 (S.D.Cal. 2017) (Rule 30(b)(6) notice served 10 calendar days before deposition failed to provide defendant with reasonable notice). See also Coury v. Air & Liquid Sys. Corp., 2019 U.S. Dist. LEXIS 247134, *13 (D. Or.

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Related

Sacerdote v. N.Y. Univ.
328 F. Supp. 3d 273 (S.D. Illinois, 2018)
Davidson v. Dean
204 F.R.D. 251 (S.D. New York, 2001)
Securities & Exchange Commission v. Morelli
143 F.R.D. 42 (S.D. New York, 1992)

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Bluebook (online)
Sacerdote v. Retirement Plan Committee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sacerdote-v-retirement-plan-committee-nysd-2024.