Samuel Lombeh Allen v. Amazon

CourtDistrict Court, N.D. Texas
DecidedDecember 23, 2025
Docket3:24-cv-02846
StatusUnknown

This text of Samuel Lombeh Allen v. Amazon (Samuel Lombeh Allen v. Amazon) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Samuel Lombeh Allen v. Amazon, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SAMUEL LOMBEH ALLEN, § § Plaintiff, § § VS. § Civil Action No. 3:24-CV-2846-D § AMAZON, § § Defendant. § MEMORANDUM OPINION AND ORDER In response to defendant Amazon’s subpoenas served on three non-parties, pro se plaintiff Samuel Lombeh Allen (“Allen”) has filed a “Motion to Compel Discovery Responses and to Require Defendant to Withdraw Boilerplate Objections” and a “Motion to Modify Subpoenas and for Protective Order (Under Fed. R. Civ. P. 45(d)(3) and 26(c)).” For the reasons that follow, the court denies the motion to compel, and grants in part and denies it part the motion to modify subpoenas and for a protective order. I The relevant background facts of this case are largely set out in a prior memorandum opinion and order and need not be repeated at length for purposes of deciding these motions. See Allen v. Amazon, 2025 WL 3059629, at *1-2 (N.D. Tex. Nov. 3, 2025) (Fitzwater, J.). Allen served discovery requests on Amazon. According to Allen, Amazon responded to the requests with improper and unsupported objections. Allen then filed a motion to compel discovery responses and to require Amazon to withdraw its boilerplate objections. In October 2025 Amazon notified Allen of its intention to serve three identically worded subpoenas on non-parties Medical City Dallas (“Medical City”), Parkland Health & Hospital System (“Parkland”), and Concentra Urgent Care (“Concentra”). The subpoenas

required these three medical facilities to produce “any and all medical records” related to Allen from January 1, 2015 to the present. D. App. (ECF No. 65-3) 34, 38, 42. In response, Allen filed a motion to modify subpoenas and for protective order. Amazon opposes the motions, which the court is deciding on the briefs, without oral

argument. II The court begins by addressing Amazon’s contention that Allen’s motions should be stricken because of their failure to comply with the court’s local civil rules. A

Amazon maintains that, before Allen filed his motion to modify the subpoenas and for a protective order, he failed to satisfy the conference requirements of N.D. Tex. Civ. R. 7.1. In his motion, Allen represented that he “attempted in good faith to confer with Defendant’s counsel . . . on 25, OF October, 2025 but no agreement was reached.” P. Br. (ECF No. 58) 2. Amazon disputes Allen’s representation of what occurred. It contends that,

on October 27, 2025, Allen sent a letter to Amazon’s counsel after business hours to “initiate a good-faith meet-and-confer regarding [Amazon]’s recently served subpoenas” and then requested a response within two days. D. Resp. (ECF No. 64) 3 (alteration in original). Before the two-day deadline expired, Allen filed the motion to modify the subpoenas and for - 2 - a protective order. Allen failed to comply both with a Federal Rule of Civil Procedure and with one of this court’s local civil rules: he did not confer in “good faith,” see Fed. R. Civ. P. 26(c)(1),

and did not fully explain why it was not possible to confer, see N.D. Tex. Civ. R. 7.1(b)(3) (“If a conference was not held, the certificate must explain why it was not possible to confer[.]”). Nevertheless, “[a] failure to satisfy conference requirements does not . . . mandate summary denial of [a motion,] because the Court retains discretion to waive strict

compliance with the conference requirements and to consider the motion[] on [its] merits.” Brown v. Bridges, 2015 WL 11121361, at *5 (N.D. Tex. Jan. 30, 2015) (Solis, C.J.) (citation and internal quotation marks omitted), modified in part, 2015 WL 12532137 (N.D. Tex. June 22, 2015). The court in its discretion can excuse a failure to confer when “it is clear that the motion is opposed and that a conference would neither have eliminated nor narrowed the

parties’ dispute.” Obregon v. Melton, 2002 WL 1792086, at *1 n.3 (N.D. Tex. Aug. 2, 2002) (Fitzwater, J.). Here, although Allen’s certificate of conference violates both a Federal Rule of Civil Procedure and one of this court’s local civil rules, it is clear that the motion is opposed. The issue in dispute—whether the information sought in three identically worded subpoenas is

relevant—is also already sufficiently narrow despite the absence of the required conference. Accordingly, the court will not deny Allen’s motion based solely on his failure to comply with Rule 26(c)(1) and local civil rule 7.1. See State Auto. Mut. Ins. Co. v. Freehold Mgmt., Inc., 2018 WL 10391736, at *2 (N.D. Tex. Dec. 17, 2018) (Rutherford, J.) (declining to deny - 3 - motion to quash and for protective order based on failure to comply with Rule 26(c)(1) and local civil rule 7.1). Although the court has decided not to deny Allen’s motion to modify the subpoenas

and for a protective order based on his failure to abide by these national and local rules, the court emphasizes that the “[f]ailure to comply with a local civil rule of this court is to be carefully avoided and should not be repeated.” Obregon, 2002 WL 1792086, at *1 n.3. Indeed, a magistrate judge of this court has cautioned that “future noncompliance with the

certificate of conference requirement may result in the Court striking the offending motion from the docket.” Monitronics Int’l, Inc. v. Skyline Sec. Mgmt., Inc., 2017 WL 7520612, at *1 n.1 (N.D. Tex. Oct. 30, 2017) (Toliver, J.). The same is true for a failure to comply with a Federal Rule of Civil Procedure. B

Amazon also maintains that the court should strike Allen’s motion to compel because of his failure to disclose his use of artificial intelligence (“AI”). N.D. Tex. Civ. R. 7.2(f)(1) requires that “[a] brief prepared using generative [AI] must disclose this fact on the first page[.]” Allen does not dispute that he used AI or that he failed to make the required disclosure. According to Amazon, Allen’s use of AI has resulted in his citing non-existent

cases and procedures and providing hallucinated quotations. The court declines at this time to sanction Allen for his undisclosed use of AI. Allen is proceeding pro se, and the court has not previously warned him of the consequences of failing to comply with the court’s local civil rules. While such a warning is not necessarily - 4 - required in this or any other case involving a pro se party, the court deems it best to admonish Allen before imposing sanctions that could be quite severe. Accordingly, the court warns Allen that, going forward, his failure to comply with N.D. Tex. Civ. R. 7.2(f) “may

result in the imposition of sanctions, including the striking of filings, the imposition of filing restrictions, monetary penalties, or dismissal of this action.” Jayroe v. Progressive Cas. Ins., 2025 WL 3144976, at *3 (N.D. Tex. Oct. 27, 2025) (Toliver, J.), rec. adopted, 2025 WL 3143269 (N.D. Tex. Nov. 10, 2025) (Fish, J.).

III The court now turns to Allen’s motion to modify the subpoenas that Amazon served on Medical City, Parkland, and Concentra. A The court must initially decide whether Allen has standing to challenge the subpoenas.

“A party’s standing to quash subpoenas served on non-parties pursuant to Rule 45 is limited.” MC Trilogy Tex., LLC v. City of Heath, Tex., 2023 WL 5918925, at *9 (N.D. Tex. Sept. 11, 2023) (Fitzwater, J.).

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