Tudor v. State Farm General Insurance Company

Background

All discovery matters had been referred to Magistrate Judge Peter H. Kang. The court considered discovery status reports, administrative motions to seal, and letter briefs concerning discovery disputes. The court held a Discovery Management Conference on September 9, 2026, and issued this order to record its directives from that conference.

The court explained that Federal Rule of Civil Procedure 26 permits discovery of nonprivileged information relevant to a claim or defense and proportional to the needs of the case. Although relevance is broad, discovery may be limited when it is cumulative, duplicative, or obtainable from a more convenient, less burdensome, or less expensive source. The party seeking discovery bears the burden of showing relevance, while the party resisting discovery must specifically explain its objections.

Court’s rulings and directives

Joint filings. The parties were ordered to exchange the first drafts of their sections for any joint filing at least two days before the filing deadline, preferably earlier. A draft section first sent on the afternoon before the filing deadline would not be accepted. The parties were also ordered to submit joint reports at least five business days before each Discovery Management Conference.

Confidentiality of Exhibits B and G. State Farm sought to maintain the confidentiality designation under the protective order for Exhibits B and G, which had been filed with an earlier joint discovery report. Exhibit B listed the titles, identification numbers, types, employees, and transcript pages for training materials. Exhibit G listed 89 documents by title and date. State Farm submitted a declaration from a manager in its Claims Training–P&C Department stating that the compilations could provide competitors an unfair advantage by revealing information about State Farm’s training procedures.

The court found that State Farm provided sufficient evidence to maintain the confidentiality designation for the compilations. State Farm’s motion to retain confidentiality was GRANTED. The ruling applied only to Exhibits B and G as compilations. It did not automatically make the titles of the underlying documents confidential when considered separately, and it did not extend to the underlying documents themselves.

Electronically stored information protocol. The parties had not finalized their proposed protocol for handling electronically stored information, despite exchanges and meet-and-confer efforts. The court provided guidance, including that the protocol should be neutral between the parties, while explaining that this guidance did not decide whether a particular electronic-discovery request was proportional or otherwise proper.

The parties were ordered to continue communicating and meeting and conferring promptly and reasonably, and to submit a joint proposed electronic-discovery protocol by September 23, 2026. If disputes remained, they were required to file by that date a jointly prepared redline showing competing language, counsel declarations explaining the substantive differences from the court’s model protocol, and a further joint discovery letter brief explaining each party’s position. Plaintiff’s motion to adopt her proposed electronic-discovery protocol, docketed at 141, was DENIED WITHOUT PREJUDICE.

Document production and interrogatories. State Farm was ordered to complete production of personnel files by September 18, 2026. Tudor was ordered to select the final, third year of water-initiative documents by September 23, 2026; the previously selected years of 2016 and 2023 could be changed only for good cause. State Farm was ordered to contact the potential custodians Tudor identified and either confirm that they had no responsive electronically stored information or include them as custodians in the electronic searches by September 23, 2026. The parties were ordered to continue meeting and conferring promptly and reasonably about any remaining dispute concerning State Farm’s responses to Set One Interrogatories.

Depositions. Because Tudor was waiting for document production before noticing depositions, the court directed the parties to avoid additional delay. State Farm was ordered to provide, by Friday, September 18, 2026, the dates when each identified witness and attorney would be unavailable for depositions. Tudor was ordered to provide the same information for the counsel who would take those depositions. After identifying unavailable dates, the parties were ordered to take diligent and appropriate steps to reserve deposition dates, particularly when only a small number of dates appeared available. The court directed counsel not to wait for all electronically stored information and other documents to be produced before scheduling depositions.

Conclusion

The next Discovery Management Conference was set for October 23, 2026, at 2:00 p.m., in person in Courtroom F. The parties were required to file their next joint discovery report on October 16, 2026. The order stated that it resolved docket entries 126, 127, 128, 131, 134, 135, 140, 141, and 142, and incorporated the other rulings, directives, and deadlines stated orally at the conference to the extent they were not expressly discussed in the written order.