Peterson-Rojas v. Dakota County

Background

Maija Peterson-Rojas sued Dakota County, John Galloway, and Letty Galloway. The complaint asserted Title VII and Minnesota Human Rights Act discrimination claims against Dakota County; defamation and interference with economic advantage claims against all defendants; and Minnesota Data Practices Act claims against John Galloway and Dakota County.

Dakota County served interrogatories and a request for production of documents. Peterson-Rojas answered the interrogatories but did not respond to the document request. The County also argued that several interrogatory answers were deficient. Its counsel attempted to address the issues with Peterson-Rojas’s counsel, but received no response.

The Galloway Defendants served interrogatories, a document request, and requests for authorizations. Peterson-Rojas did not respond to any of those requests, and no documents were served. The Galloway Defendants also attempted to resolve the issues with her counsel without receiving a response.

Court’s analysis

The court explained that discovery may cover nonprivileged information relevant to a claim or defense and proportional to the case’s needs. Under the Federal Rules of Civil Procedure, parties generally have 30 days to respond to interrogatories and document requests. A motion to compel allows a party to ask the court to require the opposing party to provide missing or inadequate discovery.

The court reviewed Peterson-Rojas’s answers to the County’s interrogatories and found them deficient. It said the answers were nonresponsive, sometimes omitted specifically requested information, and often copied paragraphs from the complaint. The court also found that Peterson-Rojas had not justified her boilerplate objections and had not responded to the County’s motion.

The court further found that Peterson-Rojas had not produced any documents for the County and had not responded to the County’s document request. As to the Galloway Defendants, the court found that Peterson-Rojas had not answered any interrogatories or produced any documents.

Ruling

Judge Tony N. Leung granted Dakota County’s Motion to Compel Discovery Against Plaintiff. The order required Peterson-Rojas, within 14 days, to fully answer interrogatories 5, 6, 9, 10, 11, 12, 14, 19, 20, 21, and 22 and to serve responses to the County’s request for production of documents.

Judge Leung also granted the Galloway Defendants’ Joint Motion to Compel Discovery Against Plaintiff. Within 14 days, Peterson-Rojas was required to respond to their Set I interrogatories, Set I request for production of documents, and requests for authorizations.

The court did not award a specific amount of expenses or attorney fees in this order. Instead, it directed the County and the Galloway Defendants each to file an affidavit describing the time spent on their motion, requested attorney-fee rate, expenses, and other relevant facts within 14 days. Peterson-Rojas could file objections within seven days after each affidavit. The order also warned that failure to comply could lead to remedies or sanctions, including costs, attorney fees, limitations on evidence, striking pleadings, dismissal with prejudice, or default judgment.