Patel v. Dorsey
- Wise
- 5:25-cv-01262
- U.S. District Court · Northern District of California
- 2
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
Viraj Patel v. Jack Dorsey: Judge Wise denied defendants’ request to overturn a magistrate judge’s discovery order requiring production of certain DOJ-related documents.
Defendants, whose motion for relief was denied; the ruling concerns their production of specified DOJ-related documents.
What happened
In Viraj Patel v. Jack Dorsey, et al., defendants challenged a magistrate judge’s order about documents connected to a Department of Justice investigation. The order required defendants to reproduce certain nonprivileged documents they had provided to the Department of Justice, with specified exclusions.
The court considered whether the magistrate judge’s discovery order was clearly wrong or violated the law. It concluded that the documents were likely relevant because the investigation overlapped with the issues in the case, and that the burden of producing them was proportionate to the case’s needs.
Judge Wise denied defendants’ motion for relief from the magistrate judge’s August 24, 2026, pretrial order. The decision addressed discovery only and did not decide the underlying claims.
The detailed version
- Patel v. Dorsey · No. 5:25-cv-01262
- Wise
- Sept. 10, 2026
Background
Defendants moved for relief from an August 24, 2026, nondispositive pretrial order issued by Magistrate Judge DeMarchi. The challenged order concerned plaintiff’s requests for documents that defendants previously provided to, or received from, the Department of Justice (DOJ) concerning the DOJ’s investigation of allegations raised in a March 2023 Hindenburg report.
Judge DeMarchi ordered defendants to reproduce to plaintiff all nonprivileged documents in the DOJ collection that defendants had provided to the DOJ. The order excluded materials defendants had received from the DOJ and transaction-level customer data. Judge DeMarchi found that the documents were likely relevant because of the significant overlap between the DOJ investigation and the claims and defenses in this action. The judge also found that the burden of reproducing the collection was not disproportionate to the case’s needs.
Legal standard and analysis
Under 28 U.S.C. § 636(b)(1)(A), a district court may reconsider a magistrate judge’s order on a nondispositive pretrial matter only if the order is clearly erroneous or contrary to law. The court explained that this standard permits reversal only when the court has a definite and firm conviction that a mistake was made.
The court held that the challenged order was neither clearly erroneous nor contrary to law. It concluded that the requested documents fell within the scope of discovery allowed by Federal Rule of Civil Procedure 26(b)(1) because they were likely relevant to the case. The court also agreed with the magistrate judge’s assessment that defendants’ production burden was proportionate to the need for the documents.
Disposition
The court DENIES defendants’ motion for relief from the August 24, 2026, pretrial order of Magistrate Judge DeMarchi. Judge Wise’s order addresses the discovery dispute and does not resolve the underlying claims or defenses.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.