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Composition Roofers Union Local 30 Welfare Trust Fund v. Graveley Roofing Enterprises Inc.

Citations: 160 F.R.D. 70; 32 Fed. R. Serv. 3d 213; 1995 U.S. Dist. LEXIS 2708; 1995 WL 100546Docket: No. 93-CV-2759

Court: District Court, E.D. Pennsylvania; March 6, 1995; Federal District Court

Narrative Opinion Summary

In a dispute involving labor unions and employee benefit plans against Graveley Roofing, the core issue centered on the latter's failure to remit benefit contributions as mandated under ERISA. During legal proceedings, it was discovered that Graveley Roofing subcontracted work to Jackel Services, which breached collective bargaining agreements. A subpoena was issued to Kathryn A. Graveley, associated with Jackel, for deposition and production of pertinent business records. Jackel Services and Graveley filed a Motion to Quash the subpoena, asserting undue burden, confidentiality concerns, irrelevance, and insufficient compliance time. The court found these arguments unconvincing, particularly noting that Ms. Graveley's role as Jackel's secretary provided her with access to necessary documents. The court emphasized the relevance of the information for calculating damages and denied the motion to quash, underscoring that the movants did not demonstrate undue burden or potential harm from disclosing confidential information. Consequently, the subpoena remained valid, allowing the plaintiffs to pursue discovery essential to their claims.

Legal Issues Addressed

Disclosure of Confidential Information under Rule 45(c)(3)(B)(i)

Application: The court determined the movants did not establish a specific, serious harm from the disclosure of confidential information, thus failing to justify quashing the subpoena on these grounds.

Reasoning: They have not sufficiently established that disclosure would lead to specific injury, and their assertion that the information is more accessible from the Defendant raises doubts about its confidentiality.

Motion to Quash Subpoena under Rule 45

Application: The court denied the motion to quash the subpoena, finding that the movants failed to demonstrate undue burden or irrelevance of the requested documents.

Reasoning: The movants failed to prove that the subpoena is oppressive.

Relevance of Subpoenaed Documents

Application: The court held that the requested documents concerning agreements between Graveley Roofing and Jackel Services are relevant for calculating damages owed to the plaintiffs.

Reasoning: The requested information is relevant for documenting agreements between Graveley Roofing and Jackel, which is necessary for calculating damages owed to Plaintiffs.

Undue Burden in Compliance with Subpoena

Application: The court found that the movants did not demonstrate that compliance with the subpoena would pose an undue burden, as Ms. Graveley had sufficient time to produce the required documents.

Reasoning: Ultimately, the movants have not demonstrated that the subpoena imposes an undue burden, leading to the denial of their Motion to Quash.