Syntel Sterling Best Shores Mauritius Limited v. The Trizetto Group, Inc.

Background

Syntel Sterling Best Shores Mauritius Limited and Syntel, Inc., together called “Syntel,” filed two motions in limine under Federal Rules of Evidence 401, 402, and 403. A motion in limine asks the court to decide before trial whether particular evidence or arguments may be presented to the jury. Syntel sought to prevent The TriZetto Group, Inc. and Cognizant Technology Solutions Corp. from referring to discovery proceedings, disputes, orders, and sanctions, and from presenting evidence about the existence or contents of the Preclusion Order and related materials.

Ruling

The court ordered that the parties could not refer at trial to discovery disputes or the court’s discovery orders, including the Preclusion Order. The court found that evidence of those disputes and orders had little, if any, value and could unfairly prejudice the jury against Syntel or confuse the jury by suggesting that evidence had been hidden from it.

The court did not exclude evidence about the events underlying the disputes and orders. That included evidence of Syntel’s alleged failure to produce evidence of its alleged theft leading to the Preclusion Order, as well as evidence of Syntel’s alleged attempts to conceal its actions. The court found that this evidence was relevant to Defendants’ claims, particularly their counterclaims for trade secret misappropriation, and that its value outweighed the risk of unfair prejudice. The court distinguished ordinary damaging evidence—which tends to prove a claim or affect witness credibility—from unfair prejudice, such as misleading the jury or appealing improperly to its emotions.

Disposition

Judge Lorna G. Schofield ordered that Syntel’s motions in limine Nos. 3 and 4 were GRANTED in part and DENIED in part. The parties could not reference discovery disputes or the court’s discovery orders, but evidence of the events underlying those disputes and orders was not precluded. The Clerk of Court was directed to close the motions at Docket Nos. 689 and 694.