Venticinque v. Back to Nature Foods Company, LLC

CourtDistrict Court, S.D. New York
DecidedFebruary 18, 2025
Docket1:22-cv-07497
StatusUnknown

This text of Venticinque v. Back to Nature Foods Company, LLC (Venticinque v. Back to Nature Foods Company, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Venticinque v. Back to Nature Foods Company, LLC, (S.D.N.Y. 2025).

Opinion

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February 12, 2025 MEMO ENDORS| Via CM/ECF Hon. Valerie Figueredo USDC SDNY United States District Court, Southern District of New York DOCUMENT 500 Pearl Street, Courtroom 17A ELECTRONICALLY FILE New York, NY 10007 DOC #: T: (212) 805-0298 DATE FILED: 2/18/25 Re: — Venticinque v. Back to Nature Food Company LLC., No. 1:22-cv-7497 Dear Judge Figueredo: We represent Plaintiff Gracemarie Venticinque (“Plaintiff”) in the above action and write in accordance with Local Civil Rule 37.2 and Your Honor’s Individual Rule II.C.2. to respectfully request a discovery conference on the issues described below. See Ex. 1. On January 24, 2025, from approximately 2:00 pm to 3:45 pm ET, I participated in a meet and confer video conference (“M&C”) with Amelia Hritz and Laura Shapiro, who represent Defendant Back to Nature Food Company LLC (“Defendant”). Either through statements made at the M&C or a February 6, 2025 email from Defendant’s counsel, all issues discussed herein are at an impasse. Background On September 1, 2022, Plaintiff filed this class action based on Defendant’s misleading statement “Organic Whole Wheat Flour” (“Label Claim’) on the front of its Back to Nature Stoneground Wheat Crackers (“Product”), because the main flour in the Product is unbleached enriched wheat flour instead of whole wheat flour. Plaintiff brought claims under New York General Business Law §§ 349 and 350 and seeks to represent a class of New York purchasers. On August 8, 2023, the District Court granted Defendant’s motion to dismiss the claims on the ground that no reasonable consumer could be deceived. See ECF No. 28. On July 12, 2024, the Second Circuit reversed this decision, and the case was remanded to this Court for further proceedings, including the taking of discovery. See ECF No. 31. Timeline for Production Despite the fact that Plaintiff served the discovery requests at issue on November 1, 2024, no documents have been produced to date by Defendant, and during the M&C Defendant stated that it had not yet begun to search for documents. When Defendant refused to provide a date when production would begin and when it would be complete, Plaintiff requested that production begin within two weeks, and be completed within two months. In the follow-up email, Defendant agreed to a rolling production that would begin in ten days (i.e., Feb. 16") but would not commit to a date for substantial completion before the close of fact discovery. The Federal Rules make clear that “[t]he production must then be completed no later than the time for inspection specified in the request or another reasonable time specified in the response.” Fed. R. Civ. P. 34(b)(2)(B). Numerous courts have held that the responding party must give a timeline for the completion of production. See, e.g., Daedalus Blue, LLC v. MircoStrategy Inc., 2021 WL 11709428, at *2 (E.D. Va. May 3, 2021) (“If a party suggests ‘another reasonable time’ for production, that response must indicate, among other things, ‘a specific time, place and manner’ to be considered a complete answer under Rule 34(b)”); Granados v. Traffic Bar and Restaurant, Inc., 2015 WL 9582430, at *3 (S.D.N.Y. Dec. 30, 2015) (response that 121 North Washington Avenue « Floor 2 ° Minneapolis, Minnesota 55401

Letter Requesting Discovery Conference February 12, 2025 Pdeafgeen d2a onft s4 “were conducting a search for responsive documents” was “thoroughly deficient”); Jayne H. Lee v. Flagstaff Ind. Corp., 173 F.R.D. 651, 656 (D. Md. 1997) (“a response to a request for production of documents which merely promises to produce the requested documents at some unidentified time in the future, without offering a specific time, place and manner, is not a complete answer as required by Rule 34(b) and, therefore, pursuant to Rule 37(a)(3) is treated as a failure to answer or respond”). Under the current schedule, fact discovery must be completed by October 1, 2025. ECF No. 41. To allow Defendant to sit on its production through the end of the discovery period would deprive Plaintiff of the ability to seek targeted follow-up discovery and utilize relevant documents in preparing for and taking depositions. It would also deprive Plaintiff of the ability to seek third- party discovery through subpoenas, which often first require seeking the information from the opposing party. Therefore, Plaintiff respectfully requests the Court order Defendant to substantially complete document production by April 30, which will be six months from the date of service of Plaintiff’s requests. 1. Time Period of Discoverable Information - Defendant takes the position that it will not produce any documents that predate September 1, 2019 (i.e., the start of the liability period). During the M&C, Plaintiff pointed out that numerous courts have ruled that relevant documents that predate the liability period are discoverable, and followed up by providing citations. Defendant claims these cases are distinguishable on the facts or as being out of circuit. During the M&C, Defendant also refused to produce any Product labels that postdate the filing of the action. Numerous courts have held that “[i]nformation before the statute of limitations period may fall within the scope of discoverable information.” Hall v. Marriott Int’l Inc., 2021 WL 1906464, at *9 (S.D. Cal. May 12, 2021); see In re: Coca-Cola Prod. Mktg. & Sales Pracs. Litig. (No. II), No. 14-md-02555-JSW(MEJ), 2016 WL 6245899, at *6 (N.D. Cal. Oct. 26, 2016) (“Pre-class period discovery is often relevant, particularly in misleading advertising cases.”). Here, for example, if the labels were created in 2018, then the internal discussions about why to put the Labeling Claim on the Product would be relevant, as would the marketing surveys that likely predate the creation of the label. Similarly, labels produced after the filing of the complaint are relevant as Plaintiff may seek a class period that extends through judgment. See, e.g. Andrews v. Sazerac Co., 2025 WL 19312, at *10 (S.D.N.Y. Jan. 2, 2025), later withdrawn, (certifying a class “to the date of judgment”). In fact, at Plaintiff’s deposition on January 30 , 2025, Defendant introduced newer labels, thereby undermining their claim that such labels are not relevant. Accordingly, Defendant’s blanket cutoff dates are inappropriate, and Plaintiff is not in a position to determine when relevant information was obtained or created by Defendant (e.g., when it conducted consumer and/or marketing surveys ). Plaintiff respectfully requests the Court order Defendant to provide responsive documents and information regardless of the date they were created, including Product labels through the present. 2. Request No. 3 – Product Ingredient Documents - Document Request No. 3 seeks documents showing how each wheat ingredient is milled or produced. Defendant refuses to produce any such documents, arguing they are irrelevant. But Plaintiff’s allegation is that the Product label is deceptive because whole wheat is not the main wheat in the Product, and per FDA regulations whole wheat flour is defined based on its production process. See 21 C.F.R. § 137.200(a) (“whole wheat flour. . . is the food prepared by so grinding cleaned wheat, other than Letter Requesting Discovery Conference February 12, 2025 Pofa gthei s3 soefc 4ti on, not less than 90 percent passes through a 2.36 mm (No. 8) sieve and not less than 50 percent passes through a 850 μm (No. 20) sieve”). Plaintiff is entitled to know how the Product’s ingredients have been produced to know whether any of them even classify as whole wheat, and to then determine what percentages of the wheat in the Product is whole wheat versus non-whole wheat.

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Jayne H. Lee, Inc. v. Flagstaff Industries Corp.
173 F.R.D. 651 (D. Maryland, 1997)

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Venticinque v. Back to Nature Foods Company, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/venticinque-v-back-to-nature-foods-company-llc-nysd-2025.