Wadeea v. Mercedes-Benz USA, LLC

District Court, S.D. California·Decided August 21, 2025·No. 3:24-cv-01587·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MASHID WADEEA, Individually and on Case No.: 24-cv-1587-H-DDL Behalf of All Others Similarly Situated, 12 ORDER DENYING WITHOUT Plaintiff, 13 PREJUDICE PLAINTIFF’S MOTION v. FOR ISSUANCE OF LETTERS 14 ROGATORY MERCEDES-BENZ USA, LLC, a 15 Delaware Corporation, [Dkt. No. 49] 16 Defendant. 17

18 Plaintiff moves for the issuance of letters rogatory directed to the appropriate judicial 19 authority of Germany requesting production of documents from third party Mercedes-Benz 20 Group AG (“Mercedes Germany”). Dkt. No. 49 (“Mot.”). Plaintiff argues this discovery is 21 necessary because Mercedes Germany has possession, custody, or control over documents 22 necessary to prove her design defect and fraud claims. Id. at 2. Defendant Mercedes-Benz 23 USA, LLC (“MBUSA”) opposes the motion as untimely, procedurally improper, and 24 undermined by the comity analysis set forth in Societe Nationale Industrielle Aerospatiale 25 v. U.S. Dist. Ct. for S. Dist. of Iowa, 482 U.S. 522, 544 (1987). Dkt. No. 59 (“Opp’n”). The 26 Court concludes that although Plaintiff’s motion is timely and procedurally proper, it is 27 also futile considering the requirements of the Hague Evidence Convention as it has been 28 implemented in Germany. Accordingly, the Court DENIES the motion without prejudice. 1 I. 2 BACKGROUND 3 A. The Underlying Action 4 Plaintiff brings this action against MBUSA on behalf of persons who purchased 5 Mercedes-Benz S-Class vehicles of model years 2021 through 2024 (the “Class Vehicles”) 6 in California. Dkt. No. 1-2 ¶ 1 (“Compl.”). “The Class Vehicles suffer from a defect 7 affecting the 21-inch AMG wheels that causes the tires to bubble along the sidewall, leak 8 air, and blow out while driving.” Dkt. No. 21 (citing Compl. ¶¶ 34, 37-43). Plaintiff 9 purchased a 2023 S-Class vehicle on October 29, 2022. Compl. ¶ 33. Over the next six 10 months, Plaintiff brought her vehicle to authorized dealerships for repairs due to problems 11 caused by the defect at least six times. Id. ¶ 37-44. Plaintiff’s vehicle was never adequately 12 repaired or replaced, and she does not believe her vehicle is safe for normal operation. Id. 13 ¶¶ 44-45, 130. Additionally, “[b]eginning in mid-2022, consumers complained about the 14 defect affecting the Class Vehicles on internet forums and social media accounts monitored 15 by MBUSA.” Dkt. No. 21 (citing Compl. ¶¶ 74-75). Plaintiff alleges claims for: 16 (1) violations of California’s Song-Beverly Consumer Warranty Act; (2) violations of 17 California’s Unfair Competition Law; (3) breach of express warranty; (4) breach of implied 18 warranty; (5) unjust enrichment; and (6) fraudulent concealment. Id. ¶¶ 128-222. 19 B. The Discovery Dispute 20 Plaintiff moves for the issuance of letters rogatory to discover information in 21 Mercedes Germany’s possession. Mot. at 3. Plaintiff notes Mercedes Germany “is the 22 designer and manufacturer of the Class Vehicles, and distributed the Class Vehicles to and 23 through MBUSA, and therefore has valuable communications, documents, and evidence 24 regarding the claims in Plaintiff’s Complaint.” Id. Plaintiff points to several things 25 uncovered during discovery as evidence: MBUSA produced documents referencing 26 Mercedes Germany; MBUSA produced emails showing it communicates, or has access to 27 emails with, Mercedes Germany; and MBUSA objected to several of Plaintiff’s discovery 28 requests “on the basis that it does not develop, design, test, analyze, produce or 1 manufacture Mercedes-Benz vehicles or their component parts; nor does it interact with 2 suppliers.” Id. at 5-6. Plaintiff further argues the five-factor comity analysis weighs in favor 3 of issuing the letters rogatory. Dkt. No. 76 (“Reply”) at 8-9. 4 Defendant argues the motion is procedurally improper, untimely, and unreasonable. 5 First, Defendant contends that neither the Federal Rules of Civil Procedure nor the statutes 6 Plaintiff cites provide a basis for issuing letters rogatory. Opp’n at 11-12. Second, 7 Defendant contends Plaintiff has known of the need to seek discovery in Germany for at 8 least six months (when MBUSA answered the Complaint and denied that it manufactured 9 or designed the Class Vehicles), and likely even before then (when Plaintiff purchased the 10 car in October 2022 and received multiple indicia that Mercedes Germany designed and 11 manufactured the vehicle). Id. at 8-10. By waiting until three months before the close of 12 fact discovery to file a motion for letters rogatory—the response to which may take more 13 than six months—Plaintiff has failed to exercise diligence. Id. at 8. And third, Defendant 14 contends all five comity factors weigh against issuing the letters rogatory. Id. at 11-12. 15 II. 16 LEGAL STANDARDS 17 “A letter rogatory is a formal written request sent by a court to a foreign court for 18 the purpose of obtaining evidence, including depositions and documents, in a pending 19 action.” Scalia v. Int’l Longshore & Warehouse Union, 337 F.R.D. 281, 287 20 (N.D. Cal. 2020) (citing Optrics, Inc. v. Barracuda Networks, Inc., No. 17-cv-04977-RS 21 (TSH), 2019 WL 5485890, at *1 (N.D. Cal. Oct. 25, 2019) (“Parties may use letters 22 rogatory to take evidence from a specific person within the foreign jurisdiction, including 23 requests for production of documents.”)); see also Fed. R. Civ. P. 28(b)(1)(B) (providing 24 for the taking of foreign depositions through letters rogatory).1 25

26 1 All citations, subsequent history, and parallel reporter citations are omitted unless 27 otherwise noted. In direct quotes, all internal quotation marks, brackets, ellipses and 28 footnotes are omitted, and all emphasis is added, unless otherwise noted. 1 The issuance of a letter rogatory is a matter within both the authority and the 2 discretion of the Court. See Scalia, 337 F.R.D. at 288; 28 U.S.C. § 1781(a)(2). When 3 determining whether to exercise its discretion, the Court applies “Rule 28(b) in light of the 4 scope of discovery provided for by the Federal Rules of Civil Procedure.” Scalia, 337 5 F.R.D. at 288; Evanston Ins. Co. v. OEA, Inc., No. CIVS-021505DFLPAN, 2006 WL 6 1652315, at *2 (E.D. Cal. June 13, 2006) (Rule 28(b) “must be read together” with Rule 7 26(c) in determining whether to issue letters rogatory)). 8 Rule 26 provides that “parties may obtain discovery regarding any non-privileged 9 matter that is relevant to any party’s claim or defense and proportional to the needs of the 10 case, considering the importance of the issues at stake in the action, the amount in 11 controversy, the parties’ relative access to relevant information, the parties’ resources, the 12 importance of the discovery in resolving the issues and whether the burden or expense of 13 the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). The scope 14 of discovery under the Federal Rules applies equally to parties and nonparties. See Fed. R. 15 Civ. P. 45, advisory committee notes to 1991 amendment, subdivision (a) (“The non-party 16 witness is subject to the same scope of discovery under this rule as that person would be as 17 a party to whom a request is addressed pursuant to Rule 34.”). 18 In addition to determining whether the requested discovery falls within the bounds 19 of Rule 26, the Court “can also consider a five-factor comity analysis.” Walther-Meade v. 20 Leidos, Inc., No.

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Wadeea v. Mercedes-Benz USA, LLC, (S.D. Cal. 2025).

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