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Zito v. Leasecomm Corp.

Citations: 233 F.R.D. 395; 2006 U.S. Dist. LEXIS 5197; 2006 WL 318837Docket: No. 02 Civ. 8074 GEL/JCF

Court: District Court, S.D. New York; February 9, 2006; Federal District Court

Narrative Opinion Summary

In a civil RICO case, over 200 plaintiffs accused Leasecomm Corporation of engaging in a fraudulent scheme involving deceptive e-commerce leasing practices. The plaintiffs sought a protective order to modify deposition and interrogatory processes, proposing written responses and a bellwether trial structure. The court distinguished between plaintiffs asserting intentional infliction of emotional distress (IIED) and non-IIED plaintiffs, mandating in-person depositions for the former in New York. For non-IIED plaintiffs, the court allowed depositions via telephone or videoconference if defendants bore the cost and arranged for a convenient location. Defendants' extensive interrogatories were deemed excessive under Rule 33(a), leading to a ruling that no further individualized responses were required. The court rejected the bellwether proposal due to inadequate justification and deferred case grouping decisions. Consequently, a revised case management schedule was established, with specific deadlines for document production, depositions, and expert reports, while the protective order was partially granted to streamline the discovery process.

Legal Issues Addressed

Case Management and Bellwether Trials

Application: The court rejected the plaintiffs' proposal for bellwether trials, citing a lack of clarity and justification for case selection, and deferred decisions on case grouping until after discovery.

Reasoning: Discovery will not be structured as the plaintiffs suggested, with decisions on case grouping deferred until after discovery concludes.

Discovery Format in Civil Litigation

Application: The court emphasized that oral depositions are preferred over written questions due to the effectiveness of interaction and spontaneity. Telephone depositions are valid without requiring hardship justification.

Reasoning: The court found the plaintiffs' request for depositions via written questions unmeritorious, emphasizing that such a format lacks the effectiveness of oral depositions due to limited interaction and spontaneity.

Limitations on Interrogatories under Federal Rules

Application: Defendants' submission of 169 interrogatories was deemed excessive and potentially abusive, violating Rule 33(a) which limits interrogatories to 25 unless otherwise stipulated.

Reasoning: Doubts exist regarding the defendants’ discovery demand, specifically its compliance with the Federal Rules' limitation on interrogatories. According to Rule 33(a), a party may serve a maximum of 25 written interrogatories, including all discrete subparts, unless stipulated otherwise.

Protective Orders in Discovery

Application: The court granted partial relief, allowing non-IIED plaintiffs to be deposed via teleconference or videoconference, while IIED plaintiffs must appear in New York for depositions.

Reasoning: The motion for a protective order is granted in part: non-IIED plaintiffs will be deposed via teleconference or videoconference, and they are not required to respond further to the defendants' interrogatories. IIED plaintiffs must appear in New York for depositions.