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Connectu LLC v. Zuckerberg

Citations: 240 F.R.D. 34; 2006 U.S. Dist. LEXIS 86118; 2006 WL 3422411Docket: Civil Action No. 2004-11923-DPW

Court: District Court, D. Massachusetts; November 27, 2006; Federal District Court

Narrative Opinion Summary

In this case, the court conducted an evidentiary hearing to establish whether Divya Narendra was a member of ConnectU LLC on September 2, 2004, a fact critical to determining the diversity of citizenship required for federal jurisdiction. The plaintiff LLC argued that Narendra was a citizen of New York, as was Mark Zuckerberg, which would negate diversity if Narendra's membership was confirmed. The defendants attempted to introduce Narendra's admissions from a separate California lawsuit, arguing their relevance. However, the court found that under California Code of Civil Procedure § 2033.410(b), admissions are binding only for the pending action and cannot be used elsewhere if qualified. Thus, the court granted the plaintiff's Motion to Strike Admissions, excluding related evidence. The court also found no waiver of objection rights by ConnectU's counsel. The court's decision emphasized the importance of qualified admissions and their limited applicability beyond the immediate legal context. Further detailed reasoning will be provided in an upcoming Report and Recommendation.

Legal Issues Addressed

Admissibility of Qualified Admissions

Application: The court found Narendra's qualified admissions in a separate California lawsuit inadmissible for the current case, based on California Code of Civil Procedure § 2033.410(b), which limits the use of admissions to the pending action.

Reasoning: Under California Code of Civil Procedure § 2033.410(b), any admission is binding only for the specific pending action and cannot be used against the party in any other context or proceeding.

Diversity of Citizenship and LLC Membership

Application: The determination of Divya Narendra's membership in ConnectU LLC on September 2, 2004, affects the diversity of citizenship necessary for federal jurisdiction. If Narendra was a member, the case lacks diversity and is subject to dismissal.

Reasoning: An evidentiary hearing was conducted to determine whether Divya Narendra was a member of ConnectU LLC on September 2, 2004, which is crucial for establishing the citizenship of the plaintiff LLC.

Motion to Strike Admissions

Application: The court granted the plaintiff's Motion to Strike Admissions, excluding exhibits and testimonies related to Narendra’s responses from the California lawsuit.

Reasoning: As a result, the plaintiff's Motion to Strike Admissions is granted, and specific exhibits and testimonies related to these admissions will be excluded from evidence.

No Waiver of Objection Rights

Application: The court determined that there was no waiver of the right to object to the admissibility of Narendra's responses by ConnectU's counsel.

Reasoning: Additionally, the court finds no waiver of the right to object to the admissibility of the responses by ConnectU's counsel.