Spectrum Scientifics, LLC v. Celestron Acquisition, LLC

CourtDistrict Court, N.D. California
DecidedMay 26, 2022
Docket5:20-cv-03642
StatusUnknown

This text of Spectrum Scientifics, LLC v. Celestron Acquisition, LLC (Spectrum Scientifics, LLC v. Celestron Acquisition, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spectrum Scientifics, LLC v. Celestron Acquisition, LLC, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 SAN JOSE DIVISION 7 8 IN RE TELESCOPES ANTITRUST Case No. 20-cv-03642-EJD (VKD) LITIGATION 9 ORDER RE MARCH 29, 2022 10 DISCOVERY DISPUTE 11 Re: Dkt. No. 226 12

13 14 Direct Purchaser Plaintiffs (“DPPs”) and Defendants ask the Court to resolve their dispute 15 concerning the sufficiency of defendants Synta Technology Corp. and Suzhou Synta Optical 16 Technology Co. Ltd.’s (“Synta defendants”) response to DPPs’ Interrogatory No. 1. The Court 17 finds this dispute suitable for resolution without oral argument. Civil. L.R. 7-1(b). 18 As explained below, the Court will not require the Synta defendants to respond to the 19 disputed interrogatory. 20 I. BACKGROUND 21 At issue is DPPs’ Interrogatory No. 1 to the Synta defendants, which asks: 22 Describe in detail and in narrative form every communication between You (or Your counsel) and Joyce Huang since June 1, 2020, 23 including but not limited to, the date, the substance of the communication, and the method of communication. 24 Dkt. No. 226 at 1. DPPs say that the information requested is relevant to their investigation of Ms. 25 Huang’s destruction of the Synta defendants’ business records and the Synta defendants’ 26 knowledge of her activities. Id. at 3. The Synta defendants object that this interrogatory 27 1 with a third-party witness, and that such materials are “privileged”. Id. at 5-6. In addition, the 2 Synta defendants object that the interrogatory is overbroad and seeks information that is not 3 relevant to any claim or defense and/or is duplicative of DPPs’ deposition discovery. Id. at 7. 4 II. LEGAL STANDARD 5 A party may obtain discovery of any non-privileged matter that is relevant to a claim or 6 defense and that is “proportional to the needs of case, considering the importance of the issues at 7 stake in the action, the amount in controversy, the parties’ relative access to relevant information, 8 the parties’ resources, the importance of the discovery in resolving the issues, and whether the 9 burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 10 26(b)(1). 11 The attorney-client privilege protects from discovery communications concerning legal 12 advice sought from an attorney in his or her capacity as a professional legal advisor, where the 13 communication is made in confidence, is intended to be maintained in confidence by the client, 14 and is not disclosed to a third party. United States v. Sanmina Corp., 968 F.3d 1107, 1116 (9th 15 Cir. 2020). The privilege extends to a client’s confidential disclosures to an attorney in order to 16 obtain legal advice, as well as an attorney’s advice in response to such disclosures. United States 17 v. Ruehle, 583 F.3d 600, 607 (9th Cir. 2009) (citations and quotations omitted). “Because it 18 impedes full and free discovery of the truth, the attorney-client privilege is strictly construed.” Id. 19 The work product doctrine, codified in Rule 26(b)(3) of the Federal Rules of Civil 20 Procedure, protects from discovery documents and tangible things prepared by a party or his 21 representative in anticipation of litigation or for trial. Fed. R. Civ. P. 26(b)(3); Sanmina, 968 F.3d 22 at 1119 (citation omitted). “At its core, the work-product doctrine shelters the mental processes of 23 the attorney, providing a privileged area within which he can analyze and prepare his client’s 24 case.” United States v. Nobles, 422 U.S. 225, 237–38 (1975). The doctrine protects both 25 “material prepared by agents for the attorney as well as those prepared by the attorney himself,” 26 id. at 238–39, and its primary purpose is to “prevent exploitation of a party’s efforts in preparing 27 for litigation,” Admiral Ins. Co. v. U.S. Dist. Ct., 881 F.2d 1486, 1494 (9th Cir. 1989). Typically, 1 as to verbatim witness statements. See Hickman v. Taylor, 329 U.S. 495, 511 (1947); Hatamanian 2 v. Advanced Micro Devices, Inc., No. 14-cv-00226-YGR(JSC), 2016 WL 2606830 at *3 (N.D. 3 Cal. May 6, 2016). 4 Work product may be discoverable if the materials meet the requirements of Rule 5 26(b)(1)—i.e., they are relevant and proportional to the needs of the case—and if the party seeking 6 production shows a “substantial need for the materials to prepare its case and cannot, without 7 undue hardship, obtain their substantial equivalent by other means.” Fed. R. Civ. P. 26(b)(3)(A). 8 Upon such a showing, a court must nevertheless “protect against disclosure of the mental 9 impressions, conclusions, opinions, or legal theories of a party’s attorney or other representative 10 concerning the litigation.” Fed. R. Civ. P. 26(b)(3)(B). 11 III. DISCUSSION 12 This discovery dispute requires resolution of three issues. First, the Court considers 13 whether Interrogatory No. 1 seeks information relevant to a claim or defense. Second, the Court 14 considers whether the information requested is protected from disclosure by the attorney-client 15 privilege or the attorney work product doctrine. And if it is, finally, the Court considers whether 16 the privilege or protection has been waived or if, in the case of work product protection, DPPs 17 have shown a substantial need for the disputed work product under Rule 26(b)(3). 18 A. Relevance 19 Based on the parties’ prior brief regarding Topics 14 and 15 in the Rule 30(b)(6) notice 20 served on the Synta defendants, the Court understands that DPPs believe the Synta defendants 21 deliberately destroyed documents concerning collusion between Ningbo Sunny and its horizontal 22 competitors when they knew those documents would be relevant to this litigation. See Dkt. Nos. 23 190, 191. DPPs say that Interrogatory No. 1 seeks information that is “relevant to [their] 24 investigation of Ms. Huang’s destruction of Defendant[s]’ documents—namely, what Defendants 25 knew about the destruction and when they knew it.” Dkt. No. 226 at 3. 26 The Court has already concluded that DPPs may obtain deposition testimony from the 27 Synta defendants regarding when they learned of the destruction of documents by Ms. Huang and 1 relevant to DPPs’ claims in the case. See Dkt. No. 192 at 4-5. But Interrogatory No. 1 is not 2 limited to these matters, or even to “what Defendants knew about the destruction and when they 3 knew it.” Rather, the disputed interrogatory asks the Synta defendants to catalog the details of 4 each of their and their counsel’s communications with Ms. Huang since June 1, 2020, regardless 5 of the subject matter of the communication. In other words, the interrogatory does not merely 6 request relevant facts, as DPPs claim, but asks for a description of all communications, which may 7 or may not contain relevant facts. 8 Because the Court is not persuaded that Interrogatory No. 1 represents a reasonable effort 9 to obtain discovery of relevant facts, the Court does not reach the question of burden or 10 proportionality. 11 B. Attorney-Client Privilege or Work Product Protection 12 The Synta defendants argue that “there are no substantive communications between 13 Defendants and Ms.

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Related

Hickman v. Taylor
329 U.S. 495 (Supreme Court, 1947)
United States v. Nobles
422 U.S. 225 (Supreme Court, 1975)
United States v. Ruehle
583 F.3d 600 (Ninth Circuit, 2009)
United States v. Sanmina Corporation
968 F.3d 1107 (Ninth Circuit, 2020)

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Bluebook (online)
Spectrum Scientifics, LLC v. Celestron Acquisition, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spectrum-scientifics-llc-v-celestron-acquisition-llc-cand-2022.