Scr-Tech LLC v. Evonik Energy Servs. LLC

2014 NCBC 70
Procedural entryThis page is a short order in Scr-Tech LLC v. Evonik Energy Servs. LLC. Read the opinion of the Court — 2014 NCBC 71
North Carolina Business Court·Decided December 31, 2014·No. 08-CVS-16632·Published

Opinion

SCR-Tech LLC v. Evonik Energy Servs. LLC, 2014 NCBC 70.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF MECKLENBURG 08 CVS 16632

SCR-TECH LLC, ) ) Plaintiff, ) ) v. ) ) EVONIK ENERGY SERVICES LLC, ) EVONIK ENERGY SERVICES ORDER ) GMBH, EVONIK STEAG GMBH, ) HANS-ULRICH HARTENSTEIN, and ) BRIGITTE HARTENSTEIN, ) ) Defendants. ) )

{1} THIS MATTER is before the Court on a number of discovery matters. There is a separate pending motion for summary judgment which the Court will address in a separate order.

King & Spalding LLP by Timothy G. Barber, Natasha H. Moffitt, Antonio E. Lewis, David Glen Guidry, John W. Harbin, and Mary Katherine Bates for Plaintiff SCR-Tech, LLC.

Troutman Sanders LLP by Samuel T. Reaves and Hamilton Martens Ballou & Carroll, LLC by Beverly A. Carroll for Defendants Steag Energy Services, LLC, Hans-Ulrich Hartenstein, and Brigitte Hartenstein.

Bryan Cave, LLP by Mark Vasco, Benjamin F. Sidbury, and Christina Davidson Trimmer and Alston & Bird, LLP by M. Scott Stevens for Defendants Steag Energy Services GmbH and Steag GmbH.

Gale, Chief Judge.

{2} The Court does not here repeat the underlying facts of the several claims in the action which are fully detailed in the Court’s July 22, 2011, Order and Opinion on Defendants’ Joint Motion for Summary Judgment on the Non-Existence of Trade Secrets or Confidential Information. The Court will state additional facts or procedural history related to or necessary for decision of each discrete discovery matter discussed below.

1. Defendants’ Renewed Motion to Preclude Evidence of Alleged Confidential Information, and to Strike Plaintiffs’ Third Supplemental Response to Steag Interrogatory 1

{3} Essentially, Defendants seek to preclude Plaintiff from pursuing claims for misappropriation of confidential information of which Plaintiff was aware when filing the action but which it chose not to disclose in an early interrogatory. Instead, Defendants ask the Court to restrict the claim to only that misappropriation of which Plaintiff could not have been aware without the benefit of discovery. Defendant STEAG Energy Services, LLC (“Steag”) served its interrogatory number 1, asking Plaintiff to identify trade secrets and confidential or propriety information it contended had been misappropriated. Plaintiff’s response described the information broadly. Defendants challenged the adequacy of the disclosures. The Court ordered that Plaintiff must detail its trade secrets more specifically before moving forward with discovery. SCR-Tech LLC v. Evonik Energy Servs. LLC, Order, 08 CVS 16632 [Mecklenburg] (N.C. Super. Ct. May 19, 2009). Plaintiff limited its supplemental response to trade secrets and contends that it reached agreement with Defendants to revise interrogatory number 1 to be limited to trade secrets. {4} Later, Defendants filed their Joint Motion to Preclude Evidence of Alleged Confidential Information Stricken from Plaintiff’s Discovery Response (“Motion to Preclude”), contending that Plaintiff should be barred from supplementing any response to interrogatory number 1 and then pursuing claims regarding alleged misuse of confidential information. On March 19, 2013, the Court ruled that Plaintiff was entitled to discovery before it would be required to file a final supplement to its interrogatory response. At the same time, the Court noted that this case is unusual because Plaintiff had the benefit of significant forensic examination in advance of filing its claims. {5} Plaintiff then filed its Third Supplemental Response to Interrogatory Number 1. Defendants responded by letter, renewing their Motion to Preclude, which had been filed on July 17, 2013. That motion seeks to strike portions of the response and to preclude evidence of confidential information of which Plaintiff knew when filing its claims without the need for discovery. Alternatively, Defendants ask the Court to order Plaintiff to state with greater specificity the confidential information it claims was misappropriated. {6} The Court has carefully considered the parties’ submissions and arguments, and the authorities cited. Having done so, it concludes that Defendants’ Motion to Preclude should be DENIED at this time, without prejudice to consideration by later motion at the close of discovery whether Plaintiff is able to delineate its claim with sufficient specificity to withstand summary judgment.

2. Defendants’ Motion for Sanctions for Spoliation of Evidence and Violation of Rule 26(g)

{7} Defendants seek sanctions against Plaintiff based on (1) spoliation of data used to prepare a pre-litigation forensic report and (2) SCR-Tech’s improper interrogatory response that the author of the forensic report could not be identified, when, in fact, Plaintiff’s counsel had earlier identified that company, as indicated by his notes. Defendants ask that the sanctions include (1) precluding SCR-Tech from discovery relating to any alleged wrongdoing by Defendants before December 15, 2005, a date after the forensic report had been prepared and on which SCR-Tech and the Hartensteins entered a settlement agreement; (2) an adverse inference that, when the Hartensteins were terminated from SCR-Tech on March 18, 2005, the date of the report, no SCR-Tech confidential or trade secret information had been removed from and was not returned to SCR-Tech; (3) an adverse inference that any documents or materials created or modified before March 18, 2005, that have now been lost would have been favorable to Defendants; (4) dismissal of all of SCR- Tech’s claims premised on misappropriation of confidential, proprietary, and trade secret information; and (5) an evidentiary limitation precluding SCR-Tech from introducing into evidence or otherwise relying on the forensic report, any e-mails between CompuServe representatives and the Hartensteins, or any efforts to delete or destroy such e-mails (although Defendants have also indicated that they may use the report in their defense). (Defs.’ Resp. SCR-Tech’s Post-Hr’g Br. Concerning Defs.’ Mot. Sanctions Relating to SCR-Tech’s Spoliation Evidence and Violation of Rule 26(g) (“Defs. Post-Hr’g Br.”) 17; Mem. Supp. Defs.’ Mot. Sanctions Relating to SCR-Tech’s Spoliation Evidence and Violation of Rule 26(g) (“Defs. Supp. Br. Rule 26(g) Sanctions”) 18.)

a. Factual Background

{8} SCR-Tech’s parent, Catalytica Energy Services, Inc. (“Catalytica”), retained Forentech, LLC (“Forentech”) to do a forensic examination of computer files maintained by SCR-Tech or the Hartensteins, who were then SCR-Tech’s principal officers. (Pl.’s Supplemental Resp. STEAG Energy Services, LLC’s Interrog. No. 35). On February 28, 2005, Robert Zack, Catalytica’s CEO and an officer of SCR-Tech, supervised Forentech. Zack and Forentech’s representative went on-site at SCR-Tech’s North Carolina office and made full images of SCR- Tech’s servers and the Hartensteins’ laptop computers. Forentech issued an interim report on March 18, 2005 (“the Report”); Zack terminated the Hartensteins’ employment the same day. {9} Forentech submitted the Report to Catalytica through Zack. Zack was at that time an SCR-Tech manager and officer. He apparently granted consent on SCR-Tech’s behalf, allowing Forentech access to SCR-Tech’s data. There is no direct evidence that the Report was furnished to SCR-Tech in any other way. {10} Forentech furnished certain data along with its Report, including some, but not all, e-mails, from the Hartensteins’ accounts with CompuServe. Forentech did not, however, provide Catalytica with the bit-by-bit images it made of the servers and laptops. These images were retained by Forentech and ultimately discarded on an uncertain date.

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Scr-Tech LLC v. Evonik Energy Servs. LLC, 2014 NCBC 70 (N.C. Super. Ct. 2014).

2014 NCBC 70 (Scr-Tech LLC v. Evonik Energy Servs. LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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