Scanlan v. Adams Manufacturing Company

District Court, E.D. Wisconsin·Decided April 16, 2024·No. 2:22-cv-00586·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

RONALD SCANLAN,

Plaintiff, Case No. 22-cv-586-pp v.

UNITED HEALTHCARE CORPORATION,

Involuntary Plaintiff,

v.

ADAMS MANUFACTURING COMPANY, ABC INSURANCE COMPANY, and DEF INSURANCE COMPANY,

Defendants,

and

Cross-Claimant,

Cross-Defendant.

ORDER GRANTING DEFENDANT’S MOTION TO ENFORCE COURT’S DISCOVERY ORDER AND FOR SANCTIONS AGAINST PLAINTIFF (DKT. NO. 58)

On September 18, 2023, the court filed an order, which, in pertinent part, granted in part defendant Adams Manufacturing Company’s motion to compel. Dkt. No. 54 at 7-23. On February 22, 2024, the defendant filed a motion to enforce the court’s discovery order and for sanctions against plaintiff Ronald Scanlan. Dkt. No. 58. The plaintiff did not file a response to this motion by the required deadline and, as of the time of this order, still has not filed a response. See Civil Local Rule 7(b) (E.D. Wis.) (“For all motions other than

those for summary judgment or those brought under Civil L.R. 7(h) . . . any memorandum and other papers in opposition must be filed within 21 days of service of the motion.”). Based on the defendant’s unopposed declaration and exhibits, dkt. no. 59, the court finds that the plaintiff has not fully complied with the court’s September 18, 2023 order, dkt. no. 54. The court will grant the defendant’s motion to enforce the court’s discovery order and for sanctions against the plaintiff. Dkt. No. 58.

I. Background On May 17, 2022, the plaintiff filed the complaint, alleging that he suffered injuries and damages due to an Adirondack-style chair manufactured by the defendant. Dkt. No. 1. The plaintiff alleged that on October 29, 2021, while he was staying at a vacation home rented from Homestead Suites, Inc. (Homestead), he “placed some, but not all, of his weight on” the chair. Id. at ¶¶7-11. The plaintiff alleged that the chair collapsed, causing him to strike the

ground and “suffer[] serious personal injuries resulting in quadriplegia.” Id. at ¶11. On January 10, 2023, the defendant filed a motion to compel the plaintiff to respond to its September 30, 2022 discovery requests and produce responsive documents. Dkt. No. 30 at 1. As noted, the court granted this motion in part on September 18, 2023. Dkt. No. 54 at 7-23. A. The September 18, 2023 Order (Dkt. No. 54) The court rejected the plaintiff’s argument that he should not have to

respond to Interrogatories No. 13 to 21 and their related requests for production (Requests for Production 9 to 20) because the defendant had exceeded the twenty-five-interrogatory limit in Federal Rule of Civil Procedure 33 and Civil L.R. 22. Id. at 8, 16. The court observed that the parties disputed the number of interrogatories the defendant had served the plaintiff,1 but found the number of interrogatories immaterial. Id. at 8-9. Based on the plaintiff’s failure to comply with the parties’ agreed-upon procedure for objecting to excess interrogatories,2 the court found that the plaintiff had “waived his

objections to the number of interrogatories in the requests.” Id. The court also addressed the parties’ disputes regarding specific interrogatories and requests for production. Id. at 20-21. The court overruled the plaintiff’s objections to Request for Production No. 22, which “ask[ed] the plaintiff to ‘produce any and all communications between you and any third-

1 The plaintiff claimed the defendant had served fifty-three interrogatories, while the defendant claimed it had served only twenty-one. Dkt. No. 54 at 8.

2 In their joint Rule 26(f) report, the parties agreed that any party in receipt of interrogatories exceeding the number allowed by Rule 33 “may file objections within 10 business days from the date of service asserting that the excess Interrogatories are not reasonable in light of the circumstances of the case[.]” Dkt. No. 54 at 8-9 (quoting Dkt. No. 21 at 2). Despite the plaintiff having proposed this procedure, he did not file objections with the court within ten business days of receipt of the defendant’s interrogatories. Id. party regarding or related to the Incident.’” Id. at 20 (quoting Dkt. No. 31 at 18). The court explained that this request captured not only communications about the October 29, 2021 incident but also “the injuries that resulted from the incident.” Id. The court stated that “the defendant asked for

communications[—a term defined in the defendant’s discovery requests— ]rather than statements”3 and that “[t]he plaintiff’s responses to inquiries about how he is doing in his recovery would be relevant to this litigation.”4 Id. The court ordered that “[t]he plaintiff must provide full and complete responses to . . . Request for Production No[]. 22[.]” Id. at 23. The court also addressed the disputes surrounding Request for Production No. 24, which requested any and all communications with Homestead and/or its representatives. Id. at 21. At the time of the court’s

order, the plaintiff had responded to this request for production only by

3 The court stated earlier in its order:

The defendant did not [define] the word “statement” in its discovery requests; however, the defendant included a definition for “communication” to include “transmissions of any nature between one or more persons and one or more other persons including, without limitation, formal or informal discussions, conversations, conferences, or meetings in person or by telephone, text, social media, computer application, smart phone app, or any other means of transmission of written, electronic, or verbal communications.”

Dkt. No. 54 at 18 (quoting Dkt. No. 30 at 10); see also Dkt. No. 31 at 8.

4 In the plaintiff’s first amended responses, he stated that “[t]here have been inquires to plaintiff from friends and relatives since the accident as to how he is doing generally, and he has responded. The responses were in the form of text messages and are only a general overview of how he may have been doing at the time.” See Dkt. No. 39-6 at 5-6. providing “the Park House Vacation Home Rental Agreement and House Rules.” Id. The defendant argued that “[i]t is clear this cannot be the only responsive document Plaintiff has in his possession and control[,]” and “suggest[ed] that it [was] aware that communications exist[ed] between the plaintiff and

Homestead Suites’ insurers.” Id. The court determined that it would “give the plaintiff an opportunity to clarify whether any such documents exist.” Id. The court ordered that “[t]he plaintiff must provide full and complete responses to . . . Request for Production No[]. . . . 24.” Id. at 23. The court concluded by denying without prejudice the defendant’s request for an award of costs and fees in bringing the motion to compel. Id. at 22. The court reasoned that “[b]ecause some of the requests and interrogatories were overly broad and/or not proportional, the court will require the parties to

bear their own costs for this discovery dispute.” Id. B. Events Following the Court’s Order

According to the defendant, its counsel sent a letter to the plaintiff’s counsel on October 17, 2023, summarizing the supplemental discovery responses and production required by the court’s order. Dkt. No. 58 at 2 (citing Dkt. No. 59 at ¶4). The plaintiff did not respond to this letter, so the defendant sent a follow-up email on October 30, 2023, asking the plaintiff to provide supplemental responses and a supplemental document production on or before November 6, 2023. Id. (citing Dkt. No. 59 at ¶¶5-6). On November 6, 2023, the plaintiff provided the defendant with unverified supplemental responses and a supplemental document. Id. (citing Dkt. No. 59 at ¶7).

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

Scanlan v. Adams Manufacturing Company, (E.D. Wis. 2024).

Scanlan v. Adams Manufacturing Company (Scanlan v. Adams Manufacturing Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Carmelo Melendez v. Illinois Bell Telephone Company
79 F.3d 661 (Seventh Circuit, 1996)
Lori David v. Caterpillar, Incorporated
324 F.3d 851 (Seventh Circuit, 2003)
Joe Rice v. The City of Chicago
333 F.3d 780 (Seventh Circuit, 2003)
Hunt v. DaVita, Inc.
680 F.3d 775 (Seventh Circuit, 2012)
Sik Gaek, Incorporated v. Marcus Harris
789 F.3d 797 (Seventh Circuit, 2015)