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Forbes v. 21st Century Insurance

Citations: 258 F.R.D. 335; 2009 U.S. Dist. LEXIS 68510; 2009 WL 2347327Docket: No. 08-cv-00884-PHX-ROS

Court: District Court, D. Arizona; July 30, 2009; Federal District Court

Narrative Opinion Summary

This case involves a series of discovery disputes in a bifurcated proceeding, where the court addressed issues concerning the disclosure and production of documents and witnesses. The parties initially agreed to bifurcated discovery to resolve specific legal issues, with Plaintiffs granted limited additional discovery regarding a 'bad faith' claim. The court resolved four disputes, stressing compliance with discovery dispute instructions despite overlooking procedural violations due to complexity. Discovery related to the 'bad faith' claim was deferred to Phase Two. Plaintiffs' use of depositions from prior actions was not ruled on, with admissibility to be addressed later. The court clarified that Rule 26(a)(1) does not mandate document production, as they should be obtained through Rule 34 or informal requests. Several disclosures were excluded under Rule 37(c)(1) due to untimeliness, including documents and a witness named 'Lisa.' The court mandated the exclusion of privileged information from discovery responses per Rule 26(b)(5). Ultimately, the court prohibited the use of untimely disclosures and ordered amendments to discovery responses, with Defendants tasked to submit a revised joint case management plan.

Legal Issues Addressed

Admissibility of Depositions from Prior Actions

Application: The court refrains from ruling on the admissibility of depositions from prior actions, leaving it to be addressed at a later stage.

Reasoning: The Court determines that this matter does not constitute a discovery dispute and will not rule on the admissibility of the depositions at present, allowing Defendants to object when appropriate.

Discovery Dispute Resolution

Application: The court resolved four discovery disputes, emphasizing adherence to the court's Discovery Dispute Instructions and the Amended Rule 16 Scheduling Order.

Reasoning: The current Joint Position Statement presents four disputes, which the Court resolves, while highlighting that its excessive length breaches the Court’s Discovery Dispute Instructions and the Amended Rule 16 Scheduling Order.

Duty to Disclose versus Duty to Produce

Application: Rule 26(a)(1) does not require parties to produce documents, as production is expected to occur through Rule 34 or informal requests.

Reasoning: Rule 26(a)(1) does not obligate parties to produce documents, as other parties are expected to obtain them via Rule 34 or informal requests.

Exclusion of Untimely Disclosures

Application: Documents and witnesses disclosed after the deadline are excluded from Phase One proceedings under Rule 37(c)(1).

Reasoning: Consequently, Rule 37(c)(1) prohibits Plaintiffs from using these photographs as evidence.

Scope of Discovery in Bifurcated Proceedings

Application: Discovery regarding the 'bad faith' claim is postponed until Phase Two, as it was not selected for early resolution.

Reasoning: Since this issue was not selected for early resolution, further discovery related to it is postponed until Phase Two, with the possibility for additional objections at that time.

Use of Privileged Information

Application: Plaintiffs must amend their discovery responses to exclude privileged materials, as dictated by Rule 26(b)(5).

Reasoning: The court emphasizes that Rule 26(b)(5) prohibits using privileged material, necessitating an amendment of Plaintiffs’ responses to exclude such reliance.