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in Re: Toyota Motor Sales, U.S.A., Inc., and Toyota Motor Corporation

Citation: Not availableDocket: 05-18-00582-CV

Court: Court of Appeals of Texas; May 21, 2018; Texas; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this legal matter, Toyota Motor Sales, U.S.A. Inc. and Toyota Motor Corporation contested a discovery order issued by the 134th District Court in Dallas County, Texas, presided over by Judge Dale Tillery. The issue arose from the court's refusal to extend a stay on an order requiring Toyota to review and produce documents as requested by the plaintiffs, whom Toyota claimed included invasive and overbroad demands. Citing Texas Rule of Appellate Procedure 52.10, Toyota sought emergency relief to prevent the compliance that could potentially disclose privileged information. Toyota argued that the order was improperly broad, requiring document translation and exceeding permissible discovery limits, as protected under precedents such as *In re Weekley Homes* and *In re Colonial Pipeline Co.*. Furthermore, Toyota emphasized the potential irreparable harm from the order's execution, which lacked specificity and could lead to undue access to sensitive corporate data. The case highlights the tension between discovery obligations and protections against overbroad and burdensome requests. Toyota's motion sought a stay pending the resolution of its mandamus petition, underscoring the procedural safeguards necessary in complex litigation. The case was supported by submissions from Morgan, Lewis & Bockius LLP and aligned with prior case law, including *In re VERP Inv. LLC*.

Legal Issues Addressed

Discovery Order Scope and Compliance

Application: Toyota contended that the trial court's order for discovery exceeded permissible limits and required translation of documents contrary to procedural rules.

Reasoning: The request emphasizes that the discovery order exceeds permissible limits by necessitating translation of documents from Japanese to English, contrary to rules that allow production of documents as maintained in the usual course of business.

Emergency Relief under Texas Rule of Appellate Procedure 52.10

Application: Toyota sought emergency relief to prevent compliance with a discovery order that could lead to the disclosure of privileged materials, arguing the order was invasive and overbroad.

Reasoning: Toyota asserts that the discovery requests are invasive and overbroad, necessitating immediate relief to prevent compliance that could result in the disclosure of privileged materials.

Mandamus Relief Considerations

Application: Toyota sought mandamus relief by asking for a stay of the order, emphasizing that executing the order would cause irreparable harm.

Reasoning: Toyota argues that the order's execution would give Plaintiffs undue access to sensitive information, undermining the court's authority and causing irreparable harm.

Protection Against Overbroad Discovery Requests

Application: Toyota argued that the order was overbroad, irrelevant, and disproportionate, lacking specificity, which could lead to undue access to sensitive information.

Reasoning: The order... is criticized for being overbroad, irrelevant, and disproportionate, lacking specificity regarding scope, time, and subject matter.