WeRide Corp. v. Huang
- Edward Davila
- 5:18-cv-07233
- U.S. District Court · Northern District of California
- 2
In WeRide Corp. v. Huang, Judge Davila denied ZZX and AllRide’s motion for relief from a discovery order overruling their general Chinese-law objection.
Defendants ZZX and AllRide were affected because the court denied their request to obtain relief from the magistrate judge’s discovery order; the order therefore remained in effect.
What happened
In WeRide Corp. v. Huang, defendants ZZX and AllRide challenged a magistrate judge’s order requiring responses to the plaintiffs’ discovery requests.
They argued that their general objection based on Chinese law should not have been overruled because they had not withheld documents on that basis and the issue was not ready for decision. They also argued that the magistrate judge had not sufficiently considered certain international-discovery factors.
Judge Davila denied the motion. He concluded that the magistrate judge reasonably overruled the general objection because ZZX and AllRide had not identified specific documents or provided supporting expert testimony or other authority, and they had not raised the international-discovery factors in their earlier briefing.
The detailed version
- WeRide Corp. v. Huang · No. 5:18-cv-07233
- Edward Davila
- Sept. 18, 2019
Background
Defendants ZZX and AllRide sought relief under Federal Rule of Civil Procedure 72(a) from Magistrate Judge Cousins’s non-dispositive pretrial order granting the plaintiffs’ motion to compel discovery responses. The challenged order had overruled a general objection to the plaintiffs’ discovery requests based on possible Chinese-law restrictions.
Arguments and analysis
Rule 72(a) permits a party to ask the district judge to modify or set aside a magistrate judge’s non-dispositive order if it is clearly erroneous or contrary to law. The court noted that magistrate judges have broad discretion in resolving discovery disputes, and that their decisions are generally overturned only when they abuse that discretion.
ZZX and AllRide argued that the Chinese-law objection was not ripe because they had not withheld any documents based on it. The court rejected that argument. The magistrate judge had found that, although the document requests had been outstanding for months, ZZX and AllRide had not identified any specific documents subject to Chinese law or provided expert testimony or other authority supporting the objection. The district court concluded that the magistrate judge’s ruling was supported by sound reasoning and the parties’ conduct during discovery.
ZZX and AllRide also argued that the magistrate judge had not sufficiently considered the factors governing international discovery. The district court noted that they had not raised those factors in their briefing before the magistrate judge, even though the plaintiffs had raised them twice. The court held that they could not decline to address an issue before the magistrate judge and then complain that the judge had not sufficiently considered it.
Disposition
The court denied ZZX and AllRide’s motion for relief from the non-dispositive pretrial order. Judge Edward Davila did not modify or set aside the magistrate judge’s discovery ruling.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.