Lugo v. Concentrix Corporation

Background

Plaintiff Emmanuel A. Lugo is representing himself (proceeding pro se) in a lawsuit against Concentrix Corporation in the U.S. District Court for the District of Minnesota. On November 26, 2025, Lugo filed a Motion to Compel Discovery — a type of motion asking the court to order the opposing party to provide information or documents the moving party believes it is entitled to receive. The motion concerned Concentrix's initial disclosures provided under Federal Rule of Civil Procedure 26(a)(1), which requires parties to proactively share the names and contact information of persons likely to have relevant knowledge, copies of documents they may use to support their case, and any applicable insurance agreements.

Procedural Deficiencies

Under District of Minnesota Local Rule 7.1(b)(1), a party filing a motion must simultaneously file a Memorandum in Support and a Meet & Confer Statement. Lugo did not file those documents when he filed the motion on November 26, 2025; he filed them five days later on December 1, 2025 — only eight days before the scheduled December 9 hearing. Because of these deficiencies, the court canceled the hearing and ordered Concentrix to respond by December 8, 2025.

Beyond the timing problem, the court found that Lugo's meet-and-confer efforts were substantively inadequate. Local Rule 7.1(a) requires parties to make a good-faith effort to resolve disputes before filing a motion. The court noted that email exchanges generally do not satisfy this requirement. When Lugo did file his meet-and-confer statement, he cited written communications with opposing counsel and a September 30, 2025 conference — but according to a sworn declaration from Concentrix's counsel, that conference was about a proposed protective order, not the discovery deficiencies Lugo raised in his motion. The court found it likely that Lugo made material misrepresentations to the court about the nature of that meeting in order to avoid compliance with the meet-and-confer rule.

History of Rule Violations

The court detailed a pattern of noncompliance by Lugo in this case: - On July 3, 2025, he was admonished for failing to meet and confer before filing a motion. - On July 28, 2025, he was ordered to stop filing documents not permitted by the Federal Rules of Civil Procedure or the Local Rules, and multiple motions were denied for failure to meet and confer. - The court had previously denied Lugo's request to waive the meet-and-confer requirement entirely.

The court characterized Lugo's continued violations, paired with apparent awareness of those violations, as showing a "troubling lack of respect for the Court and opposing counsel."

Substantive Analysis (in a Footnote)

Although the procedural deficiencies were alone sufficient to deny the motion, the court also addressed the underlying merits. Rule 26(a)(1)(A) initial disclosures are designed to give parties a baseline understanding of the case — not to compel disclosure of every potentially relevant document or witness. The court noted that the information Lugo seeks is better pursued through Requests for Production or other targeted discovery tools later in the process. Accordingly, the court found the motion also lacked substantive merit.

Ruling and Sanctions Warning

Magistrate Judge John F. Docherty denied the Motion to Compel Discovery. In addition, the court imposed a prospective sanction framework: for every future filing by Lugo that violates the Federal Rules of Civil Procedure or the Local Rules, the court stated it will (1) summarily deny the relief requested, and (2) order Lugo to pay Concentrix $100 to compensate for attorney time wasted. The court stated it will address Lugo's concerns if he files compliant documents.

Note on Self-Represented Litigants

The court reiterated that pro se litigants — people who represent themselves without an attorney — are held to the same procedural rules as licensed attorneys appearing before the court.