Zhou v. Chai

CourtDistrict Court, N.D. California
DecidedMay 11, 2023
Docket3:21-cv-06067
StatusUnknown

This text of Zhou v. Chai (Zhou v. Chai) 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
Zhou v. Chai, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 YUE ZHOU, et al., Case No. 21-cv-06067-AMO (DMR)

8 Plaintiffs, ORDER RE: PLAINTIFFS’ MOTION FOR SANCTIONS; REPORT AND 9 v. RECOMMENDATION RE: PLAINTIFFS’ REQUEST FOR 10 SIN KIONG CHAI, et al., EVIDENTIARY SANCTIONS 11 Defendants. Re: Dkt. No. 68

12 This wage-and-hour lawsuit is pending before the Honorable Araceli Martinez-Olguin. All 13 discovery disputes have been referred to the undersigned. [Docket No. 40.] Plaintiffs now move 14 pursuant to Federal Rule of Civil Procedure 37 for terminating or issue sanctions due to 15 Defendants’ discovery violations. [Docket No. 68 (“Mot.”).] They also seek monetary sanctions. 16 Defendants opposed and Plaintiffs replied. [Docket Nos. 72 (“Opp’n”), 74 (“Reply”).] 17 For the reasons stated below and at the January 26, 2023 hearing, the court grants 18 Plaintiffs’ motion in part and recommends the imposition of evidentiary sanctions against 19 Defendants with respect to the following discovery responses: interrogatory numbers 1 through 3, 20 4, and 6, and requests for admissions numbers 35 and 37. The court recommends denial of the 21 request for terminating sanctions. Out of an abundance of caution, the court recommends rather 22 than orders these particular sanctions because the determinations are evidentiary in nature and may 23 be dispositive of issues in the case. See 28 U.S.C. § 636(b)(1)(B). 24 The court also issues a non-dispositive discovery order with respect to interrogatory 25 numbers 1 through 3, 7, 12 through 15, 16, and 17, and orders monetary sanctions. See 28 U.S.C. 26 § 636(b)(1)(A). 27 1 I. BACKGROUND 2 This motion follows several attempts by Plaintiffs to obtain complete responses to 3 interrogatories, requests for admission (“RFAs”), and requests for production (“RFPs”) served on 4 April 11, 2022. Defendants provided written responses to the RFAs and RFPs on June 10, 2022. 5 [Docket No. 69 (X. Young Lai Declaration, December 21, 2022) ¶ 2.] They did not respond to the 6 interrogatories or produce documents until July 24 and July 25, 2022 respectively. Id. ¶¶ 2, 4. 7 Defendants’ late and insufficient responses have been the subject of several disputes presented to 8 the undersigned, including two unilateral discovery letters filed by Plaintiffs (Docket Nos. 42, 54) 9 and one joint discovery letter (Docket No. 57). 10 Plaintiffs submitted the first unilateral discovery letter in June 2022 after Defendants failed 11 to respond to interrogatories or produce documents and did not engage in the meet and confer 12 process that Plaintiffs tried to initiate. [Docket Nos. 42, 43.] The court ordered Defendants to file 13 a response to Plaintiffs’ discovery letter brief. [Docket No. 44.] Defendants did not respond. The 14 court then ordered Defendants to show cause in writing why they should not be sanctioned for 15 failure to comply with a court order. [Docket No. 45.] Once again, Defendants did not respond. 16 As a result, Defendants and their counsel were ordered to appear for a hearing on July 28, 2022 to 17 explain why they failed to comply with their discovery obligations as well as violate two court 18 orders. [Docket No. 46.] 19 At the hearing, the court ordered Defendants to submit “complete, legally sufficient 20 responses to Plaintiffs’ discovery requests” by July 29, 2022. [Docket No. 48 (the “First Order”).] 21 In addition, defense counsel Timothy Allen Reed was ordered to file a sworn declaration 22 explaining why he missed case deadlines, failed to communicate with opposing counsel, and 23 violated two court orders. Id. Reed was instructed to identify all flaws in his case management 24 system that contributed to these multiple failures, as well as describe in detail all measures he is 25 implementing to remedy these problems to ensure these mistakes never happen again in this case 26 or other cases. Id. The court warned Reed that any similar conduct would result in sanctions and 27 a referral to the Northern District of California Standing Committee on Professional Conduct. Id. 1 10, 2022, Defendants submitted amended responses to Plaintiffs’ interrogatories and produced 2 additional responsive documents. Lai Decl. ¶ 6. 3 On October 19, 2022, Plaintiffs filed a second unilateral discovery letter explaining that 4 they had “exhausted all possible ways to get Defendants to comply” with the First Order. [Docket 5 No. 54.] The letter describes multiple attempts to obtain defense counsel’s compliance that were 6 met with requests for more time and promises to provide supplemental responses and documents 7 that went unfulfilled. Id. at 2-3. The court ordered Defendants to file a response to Plaintiffs’ 8 discovery letter brief, to which Defendants timely responded. [Docket Nos. 55, 56.] The parties 9 then refiled their submissions as a joint discovery letter. [Docket No. 57.] 10 At the November 30, 2022 hearing on the joint discovery letter, Defendants were ordered 11 to amend their discovery responses consistent with the court’s detailed instructions. [Docket No. 12 61 (the “Second Order”).] Defendants were further ordered to file the amended discovery 13 responses so the court could review them for compliance, as well as an accompanying declaration 14 verifying that Defendants and their counsel exercised due diligence in searching for responsive 15 documents and amending their discovery responses. Id. Defendants timely filed their 16 supplemental responses on December 7, 2022. [Docket No. 62.] After being prodded by the 17 court, Defendants filed the declaration. [Docket Nos. 66, 67.] 18 Plaintiffs now move for sanctions pursuant to Rule 37 and the court’s inherent powers. 19 They ask for terminating sanctions in the form of default judgment against Defendants or, in the 20 alternative, issue sanctions tied to the discovery responses that they contend remain deficient. 21 Plaintiffs also request $21,909.50 in monetary sanctions. 22 II. LEGAL STANDARD 23 Federal Rule of Civil Procedure 37 authorizes the imposition of various sanctions for 24 discovery violations, including a party’s failure to obey a court order to provide or permit 25 discovery. Fed. R. Civ. P. 37(b)(2)(A). Such sanctions may include, for example, directing that 26 the matters embraced in the order or other designated facts be taken as established for purposes of 27 the action; prohibiting the disobedient party from supporting or opposing designated claims or 1 part; dismissing the action; or rendering a default judgment against the disobedient party. See Fed. 2 R. Civ. P. 37(b)(2)(A)(i)-(vii). A court may also order a party to pay the reasonable expenses, 3 including attorneys’ fees, caused by its failure to comply with the order or rule. Fed. R. Civ. P. 4 37(b)(2)(C). 5 Additionally, courts are vested with inherent powers arising out of “the control necessarily 6 vested in courts to manage their own affairs so as to achieve the orderly and expeditious 7 disposition of cases.” Unigard Sec. Ins. Co. v. Lakewood Eng’g & Mfg. Corp., 982 F.2d 363, 368 8 (9th Cir. 1992) (quoting Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991)).

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