Safeco Insurance Company Of America v. Air Vent, Inc.

CourtDistrict Court, D. Nevada
DecidedMarch 21, 2023
Docket2:20-cv-01579
StatusUnknown

This text of Safeco Insurance Company Of America v. Air Vent, Inc. (Safeco Insurance Company Of America v. Air Vent, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Safeco Insurance Company Of America v. Air Vent, Inc., (D. Nev. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 SAFECO INSURANCE COMPANY OF 7 AMERICA, Case No. 2:20-cv-01579-JAD-NJK

8 Plaintiff(s), Order

9 v. [Docket Nos. 118, 119, 120]

10 AIR VENT, INC., et al., 11 Defendant(s). 12 Pending before the Court are three motions arising out of the uncompleted status of 13 discovery: (1) Third-Party Defendant Powermax filed a motion to amend the scheduling order to 14 reopen discovery, Docket No. 118; (2) Third-Party Defendant King of Fans filed a motion to 15 amend the scheduling order to reopen discovery, Docket No. 119; and (3) Plaintiff filed a motion 16 to bifurcate trial, Docket No. 120. Responses have not been filed to those motions. The motions 17 are properly resolved without a hearing. See Local Rule 78-1. 18 I. STANDARDS 19 The Ninth Circuit has repeatedly emphasized the importance of scheduling orders, see 20 Desio v. State Farm Mut. Auto. Ins. Co., 339 F.R.D. 632, 641 (D. Nev. 2011) (collecting cases), 21 and has stated bluntly that Rule 16 scheduling orders must “be taken seriously,” Janicki Logging 22 Co. v. Mateer, 42 F.3d 561, 566 (9th Cir. 1994). A request to extend deadlines in the scheduling 23 order must be premised on a showing of good cause. Fed. R. Civ. P. 16(b)(4); Local Rule 26-3. 24 The good cause analysis turns on whether the subject deadlines cannot reasonably be met despite 25 the exercise of diligence. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 610 (9th Cir. 26 1992). The required showing of diligence is measured by the conduct displayed throughout the 27 entire period of time already allowed. See, e.g., Muniz v. United Parcel Serv., Inc., 731 F. Supp. 28 2d 961, 967 (N.D. Cal. 2010). 1 When a request for relief from a case management deadline is made after that deadline has 2 expired, an additional showing of excusable neglect must be made. Branch Banking & Trust Co. 3 v. DMSI, LLC, 871 F.3d 751, 764-65 (9th Cir. 2017) (addressing former Local Rule 26-4); see also 4 Local Rule 26-3. The excusable neglect analysis is guided by factors that include (1) the danger 5 of prejudice to the opposing party; (2) the length of the delay and its potential impact on the 6 proceedings; (3) the reason for the delay; and (4) whether the movant acted in good faith. Branch 7 Banking, 871 F.3d at 765.1 8 II. THIRD-PARTY DEFENDANT POWERMAX’S MOTION 9 Third-Party Defendant Powermax filed a motion to amend the scheduling order to reopen 10 discovery. Docket No. 118. 11 On December 17, 2021, the discovery cutoff expired. Docket No. 59 at 2. On December 12 23, 2021, Third-Party Defendant Powermax filed a motion to dismiss. Docket No. 77. On July 13 26, 2022, the Court denied that motion to dismiss. Docket No. 92. On August 17, 2022, Powermax 14 filed a motion to certify for interlocutory appeal. Docket No. 97. On January 25, 2023, the Court 15 denied the motion to certify the interlocutory appeal. Docket No. 113. On February 1, 2023, 16 Powermax filed an answer. Docket No. 116. On February 6, 2023, Powermax filed the instant 17 motion to reopen discovery. Docket No. 118. 18 As the motion itself recognizes, a key consideration in deciding such a request is whether 19 the moving party was diligent in obtaining discovery. See Docket No. 118 at 4. As part of this 20 diligence inquiry, a party seeking relief from a scheduling order may be required to show that it 21 was diligent in seeking relief from the Court once it became apparent that the deadlines in place 22 could not be met. Jackson v. Laureate, Inc., 186 F.R.D. 605, 608 (E.D. Cal. 1999) (citing Eckert 23 Cold Storage, Inc. v. Behl, 943 F. Supp. 1230, 1233 (E.D. Cal. 1996)). 24

25 1 The Ninth Circuit has at times stated the factors for consideration somewhat differently, including “1) whether trial is imminent, 2) whether the request is opposed, 3) whether the non- 26 moving party would be prejudiced, 4) whether the moving party was diligent in obtaining discovery within the guidelines established by the court, 5) the foreseeability of the need for 27 additional discovery in light of the time allowed for discovery by the district court, and 6) the likelihood that the discovery will lead to relevant evidence.” City of Pomona v. SQM N. Am. 28 Corp., 866 F.3d. 1060, 1066 (9th Cir. 2017). 1 The instant motion fails to adequately explain how the Court can find diligence here given 2 that the request to reopen discovery was filed 14 months after Powermax appeared in this case, at 3 which time it could have sought the same relief it now seeks.2 Accordingly, this motion to reopen 4 discovery is DENIED without prejudice. 5 III. THIRD-PARTY DEFENDANT KING OF FANS’ MOTION 6 Third-Party Defendant King of Fans filed a motion to amend the scheduling order to reopen 7 discovery. Docket No. 119. As with the motion to reopen filed by Powermax, King of Fans is 8 entitled to relief only upon a showing of, inter alia, diligence in its discovery conduct. With respect 9 to discovery involving Powermax, the instant motion is predicated on the erroneous assertion that 10 such discovery could not be conducted until after Powermax filed an answer. Docket No. 119 at 11 5.3 Accordingly, sufficient diligence has not been demonstrated as to King of Fans’ belated 12 attempt to obtain discovery from Powermax. 13 King of Fans seeks to engage in discovery not just with respect to Powermax, however, but 14 also seeks an additional opportunity for discovery from Defendant/Third-Party Plaintiff Air Vent, 15 from Plaintiff, and from Plaintiff’s insureds. See Docket No. 119 at 7.4 King of Fans indicates 16 that it purposefully chose to avoid this discovery until after Powermax could participate because 17 King of Fans believes proceeding earlier would have been potentially inconvenient. See, e.g., id. 18 at 5 (“The parties did not proceed with depositions or much other discovery without Powermax’s 19 2 To be clear, the need to engage in discovery is triggered by the filing of an answer or any 20 other appearance in the case. See Local Rule 26-1(a); see also Fed. R. Civ. P. 16(b)(2). The filing of a motion to dismiss for lack of personal jurisdiction is an appearance triggering discovery 21 obligations. See PlayUp, Inc. v. Mintas, ___ F. Supp. 3d ____, 2022 WL 10967692, at *4, *6 n.9 (D. Nev. Oct. 18, 2022). Moreover, it is well settled law that “[t]he Federal Rules of Civil 22 Procedure do not provide for automatic or blanket stays of discovery when a potentially dispositive motions is pending.” Tradebay, LLC v. eBay, Inc., 278 F.R.D. 597, 601 (D. Nev. 2011). It is 23 wrong to assert that Powermax did not appear for discovery purposes until filing its answer. But see Docket No. 119 at 5. 24 3 King of Fans did not serve discovery on Powermax when the motion to dismiss was 25 pending, but served requests for admission after that motion was decided, at which time Powermax objected on the ground that it had not yet filed an answer. See Docket No. 119 at 5. King of Fans 26 did not file a motion to compel related to that dispute. 27 4 The discussion of excusable neglect fails from the start because it is predicated on state law, but it is the Federal Rules of Civil Procedure and the local rules of this Court that apply in 28 this case. See, e.g., Fed. R. Civ. P.

Related

United States v. Koziy
540 F. Supp. 25 (S.D. Florida, 1982)
Eckert Cold Storage, Inc. v. Behl
943 F. Supp. 1230 (E.D. California, 1996)
City of Pomona v. Sqm North America Corp.
866 F.3d 1060 (Ninth Circuit, 2017)
Branch Banking and Trust Co. v. D.M.S.I., LLC
871 F.3d 751 (Ninth Circuit, 2017)
United States v. Childress
731 F. Supp. 13 (District of Columbia, 1990)
Jackson v. Laureate, Inc.
186 F.R.D. 605 (E.D. California, 1999)
Tradebay, LLC v. eBay, Inc.
278 F.R.D. 597 (D. Nevada, 2011)

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Safeco Insurance Company Of America v. Air Vent, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/safeco-insurance-company-of-america-v-air-vent-inc-nvd-2023.