Raynaldo v. American Honda Motor Co., Inc.
- Haywood Gilliam
- 4:21-cv-05808
- U.S. District Court · Northern District of California
- 2
In Raynaldo v. American Honda, Judge Gilliam terminated a discovery letter and ordered further discussions before the parties could submit another dispute.
Ronald Raynaldo and the other plaintiffs, and American Honda Motor Co., Inc., because the parties were ordered to meet and confer further about Plaintiffs’ document requests.
What happened
In Raynaldo v. American Honda Motor Co., Inc., Plaintiffs and Defendant submitted a joint letter about Plaintiffs’ requests for documents. The court said the letter did not follow the court’s standing-order requirements.
The court also said Defendant appeared to be improperly limiting discovery about an alleged parasitic-drain defect to documents containing specific F-CAN search terms. It explained that relevant battery-investigation documents might not contain those terms and criticized Defendant’s objections and use of general objections.
Judge Haywood Gilliam ordered the parties to meet and confer further and try to narrow or resolve the dispute. The court terminated the pending discovery letter; if the dispute could not be resolved, the parties were ordered to file another joint discovery letter, with a separate letter allowed for electronic-discovery search-term issues.
The detailed version
- Raynaldo v. American Honda Motor Co., Inc. · No. 4:21-cv-05808
- Haywood Gilliam
- May 21, 2024
Background
Plaintiffs and American Honda Motor Co., Inc. filed a joint discovery letter concerning Plaintiffs’ requests for production of documents. The court noted that the letter did not comply with the court’s standing order. The parties disputed the scope of discovery, including whether Defendant could limit Plaintiffs’ requests to materials concerning the allegedly defective F-CAN system.
Court’s observations
After a preliminary review, the court stated that Defendant appeared to be improperly narrowing the requests. The court explained that documents concerning battery investigations might contain information about the alleged parasitic-drain defect even if they did not include the specific F-CAN search terms.
The court also addressed discovery responses under Federal Rule of Civil Procedure 34(b)(2)(B), which governs responses to requests for documents. It stated that, unless the requesting party agrees otherwise, responsive documents must be produced with the responses or otherwise produced, and that merely promising production at an uncertain future date does not satisfy the discovery obligation.
The court further instructed Defendant to use more carefully tailored objections. It stated that neither of the example requests appeared vague, ambiguous, overbroad, unduly burdensome, or otherwise improper under Rule 26, which governs the scope and limits of discovery. The court also stated that general objections should not appear in discovery responses, either as an introductory statement or repeated in multiple responses.
Ruling
The court ordered the parties to meet and confer further to narrow the dispute. It directed them to review the Northern District of California’s professional-conduct and electronic-discovery guidelines. If the parties could not resolve the dispute, they were ordered to file another joint discovery letter. Any request for additional pages had to be made by stipulation, and disputes about electronic evidence and search terms could be presented in a separate letter from disputes about the general document requests.
The court terminated the May 17, 2024 joint discovery letter and stated that the order resolved Docket No. 103. This was a discovery-management order; the opinion did not decide the parties’ underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.