Safelite Group, Inc. v. Lockridge

CourtDistrict Court, S.D. Ohio
DecidedSeptember 19, 2025
Docket2:21-cv-04558
StatusUnknown

This text of Safelite Group, Inc. v. Lockridge (Safelite Group, Inc. v. Lockridge) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Safelite Group, Inc. v. Lockridge, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION SAFELITE GROUP, INC., Plaintiff, Case No. 2:21-cv-4558 Chief Judge Sarah D. Morrison v. Magistrate Judge Elizabeth P. Deavers NATHANIEL LOCKRIDGE, et al., Defendants. OPINION AND ORDER This matter is before the Court on two discovery-related motions, one filed by Plaintiff Safelite Group, Inc. (“Safelite”) and one filed by Defendant Caliber Collision Center (“Caliber”). Safelite’s motion (ECF No. 333) seeks a protective order to limit a 30(b)(6) deposition. Caliber’s motion (ECF No. 338) seeks leave to serve Safelite with additional interrogatories as an alternative to obtaining the same information at a Rule 30(b)(6) deposition. Both motions have been fully briefed. (ECF Nos. 337, 340, 341, 351.) For the following reasons, Caliber’s motion is GRANTED, in part, and deferred, in part, pending further ruling by the presiding Chief District Judge. Further, Safelite’s motion is GRANTED, in part, DENIED, in part, and deferred, in part, pending further ruling by the presiding Chief District Judge. I.

The lengthy history of this case has been detailed across various orders of the Court and will not be repeated here. By way of very quick background relevant to the current Motions, at issue here is a revised 30(b)(6) deposition notice that Caliber, on behalf of all Defendants, sent to Safelite. The notice contained 29 numbered topics. (ECF No. 333, Exhibit A.) To date, the parties have agreed on Topics 13, 15, 16, 18, 19, 21, 23, 24, 27, and 29. That leaves Topics 1- 12, 14, 17, 20, 22, 25, 26, and 28 remaining at issue and the subject of Safelite’s motion for a protective order. Through its separate motion, Caliber has requested leave, pursuant to Federal Rule of Civil Procedure 33, to serve 15 additional interrogatories to resolve the dispute as to Topics 3-6, 8, 14, 20, 22, 26 and 28, see ECF No. 338-1, in the event the Court would find such

an approach preferable. Without belaboring it, upon review of the Rule 30(b)(6) Topics at issue, in the exercise of the discretion afforded to the Court in managing discovery, the Court finds it preferable for Caliber to attempt to obtain certain information in the form of interrogatory answers. Accordingly, the Court will consider Caliber’s alternative proposal set forth in its Motion. Further, because the resolution of Caliber’s Motion would impact the scope of Safelite’s Motion, the Court will consider the Motions in reverse order. II. Rule 33, by its express terms, limits each party to a total of 25 written interrogatories with

certain specified exceptions. Rule 33 states: Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2). Fed. R. Civ. P. 33. the Advisory Committee Note to Fed. R. Civ. P. 33 makes clear that 25 written interrogatories is the limit unless a party obtains either a stipulation by the opposing party or leave of court to exceed the limit. The district court has “broad discretion to determine the proper scope of discovery” under Fed. R. Civ. P. 26(b)(2). Mall v. Merlo, No. 2:18-cv-430, 2019 WL 2521165, at *1 (S.D. Ohio June 19, 2019). Under Rule 26(b)(2) the Court has discretion to “alter the limits” on the number of written interrogatories a party may serve on another party. West v. Hilton, No. 3:10-cv-284, 2012 WL 1186007, at *1 (S.D. Ohio Apr. 9, 2012). “To determine whether a party should be permitted to serve additional discovery requests, ‘the Court looks to whether the benefits of the expansion outweigh[ ] the burden of the extra discovery.’” Mall, 2019 WL 2521165, at *1 (quoting Pettus-Brown v. Phelps, No. 2:18-cv-082, 2018 WL 5960821, at *5 (S.D. Ohio Nov.

14, 2018)), report and recommendation adopted, No. 2:18-cv-82, 2019 WL 132346 (S.D. Ohio Jan. 8, 2019) (quoting Martin v. Posey, No. 2:15-cv-2294, 2017 WL 412876, at *4 (S.D. Ohio Jan. 31, 2017)). A party who seeks leave to serve additional discovery requests “must make a ‘particularized showing’” to demonstrate a need for the additional requests. Id. (quoting Pettus- Brown, 2018 WL 5960821, at *5) (quoting in turn St. Ann v. McLean, No. 5:15-cv-11770, 2017 WL 5732991, at *2 (E.D. Mich. Nov. 28, 2017) (collecting cases)). Through its current Motion, Caliber proposes to obtain certain information originally sought by way of Rule 30(b)(6) Deposition Topics through the use of fourteen contention interrogatories, Interrogatory Nos. 25-38. (ECF No. 338-1.) These proposed interrogatories are

directed to Topics 3-6, 8, 14, 20, and 22 request the factual bases for Safelite’s claims (Topics 3- 6), allegations (Topics 14, 20, and 22), and attorney fees and damages (Topic 8), including supporting documents by Bates number. Caliber also proposes one non-contention interrogatory, Interrogatory No. 39, which it describes as directed to Rule 30(b)(6) Topic Nos. 26-29. (ECF No. 338-1.) Topics 26 and 28 both address the matter of spoliation. Unsurprisingly, Safelite opposes Caliber’s proposals on several grounds. Turning first to the contention interrogatories, Safelite primarily argues that Caliber has not made the required particularized showing that such interrogatories “largely addressing [Caliber’s] own documents” are necessary. (ECF No. 341 at 3.) While recognizing that contention interrogatories are allowable, Safelite further contends that, under the circumstances of this case, responding would require significant resources, would provide no additional facts, and would “only explain what Safelite’s counsel thinks about the documents already exchanged.” (Id. at 5.) For its part, Caliber asserts that the additional interrogatories are designed to accommodate

Safelite’s claim of undue burden and Safelite’s assertion that the information Caliber sought by way of a Rule 30(b)(6) deposition was more appropriately obtained utilizing interrogatories. In rejecting Caliber’s alternative offer, Caliber contends that Safelite is attempting to preclude “the only two forms of discovery-under-oath that are available under the Civil Rules.” (ECF No. 351 at 2) (emphasis in original). As for particularized need, Caliber asserts that more than 3½ years since Safelite filed this action, Safelite still has not identified by Bates number: (1) the specific trade secrets allegedly misappropriated by Caliber or Caliber’s means of that alleged misappropriation; (2) the documents supporting Safelite’s customer and employee solicitation claims; or (3) the documents supporting Safelite’s claims of tortious interference with customer

relationships and contracts. (Id.) Moreover, Caliber contends, Safelite fails to acknowledge the complexity of this litigation involving five Defendants and over a dozen claims or that Caliber served its first 17 interrogatories before the Court granted Safelite leave to file its Second Amended Complaint in April 2022. Caliber also refutes Safelite’s claims of burden and that additional interrogatories should not be permitted because the information sought resides with Caliber. This issue, at least as it relates to the proposed contention interrogatories, Interrogatories 25- 38, does not require significant discussion. Caliber should be permitted to serve these additional interrogatories.

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

Related

Nix v. Sword
11 F. App'x 498 (Sixth Circuit, 2001)
Securities & Exchange Commission v. Morelli
143 F.R.D. 42 (S.D. New York, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
Safelite Group, Inc. v. Lockridge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/safelite-group-inc-v-lockridge-ohsd-2025.