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Udeen v. Subaru of Am., Inc.
Citation: 378 F. Supp. 3d 330Docket: Civil No. 18-17334(RBK/JS)
Court: United States District Court; March 12, 2019; Federal District Court
Defendants requested a stay of all discovery pending the resolution of their Motion to Dismiss, which plaintiffs opposed. After reviewing the parties' letter briefs and hearing oral arguments, the Court denied the request but allowed limited, focused discovery on core issues. The case involves a class action lawsuit against Subaru regarding alleged defects in the Starlink infotainment system, which plaintiffs claim pose safety hazards. The Court highlighted that the mere filing of a motion to dismiss does not automatically stay discovery, referencing established legal principles and case law. Key factors considered included potential prejudice to the plaintiffs if discovery were stayed, the hardship on defendants, simplification of issues, and the status of discovery. The Court found that staying discovery would unduly prejudice plaintiffs, potentially delaying their ability to pursue claims, especially concerning safety hazards. The Court emphasized the risk of losing relevant evidence and witness availability over time, which could affect trial outcomes. Conversely, the Court determined that limited discovery would not unduly burden defendants, as it would focus on essential issues and should be manageable and cost-effective. Notably, defendants acknowledged that some discovery would proceed regardless of the outcome of their motion, indicating that discovery is ultimately unavoidable. Defendants' concerns regarding the high costs of discovery are deemed exaggerated by the Court, which will manage the discovery process to ensure it remains proportional to the case's core issues. A stay on discovery would not simplify trial matters; rather, initial discovery will target relevant issues to educate the plaintiffs on key individuals and matters. The Court asserts that this approach will ultimately benefit defendants by preventing unnecessary discovery efforts. The lack of a trial date at this early case stage is not a significant factor in the Court's decision. While acknowledging defendants' worries about proceeding with discovery before resolving their motion to dismiss, the Court maintains that focused discovery on core issues aligns with the goals of Federal Rules of Civil Procedure Rule 1, promoting fair and efficient resolution. As a result, the Court denies the request for a complete discovery stay during the motion to dismiss period. Specific orders include: (1) defendants must produce certain documents by April 15, 2019; (2) plaintiffs must provide documents regarding their Subaru vehicle purchases and related complaints by the same date; (3) the parties are to meet and confer about additional document requests, with the Court emphasizing the need for narrow, focused requests. Should disagreements arise, they must submit simultaneous letter briefs by April 15. Additionally, the parties are required to serve their initial disclosures by April 8, and a conference is scheduled for April 22 to address any discovery disputes. The Court stipulates that no discovery will occur without permission until the motion to dismiss is resolved, although it allows for important record depositions. All document references will include electronically stored information (ESI), and the Court refrains from making any judgments on the merits of the motion to dismiss.