Hertz Global Holdings, Inc. v. National Union Fire Company of Pittsburgh
- Alison Nathan
- 1:19-cv-06957
- U.S. District Court · Southern District of New York
- 3
In Hertz Global Holdings v. Nat. Union Fire Ins., Judge Oetken granted Defendants’ request to pause discovery while their motion to dismiss was pending.
The ruling temporarily pauses Hertz’s discovery efforts against Defendants while Defendants’ motion to dismiss is pending. It does not pause the entire case or automatically change the parties’ deadlines.
What happened
In Hertz Global Holdings, Inc. v. Nat. Union Fire Ins. Co. of Pittsburgh, et al., Defendants asked the court to pause discovery until the court decided their motion to dismiss Hertz’s second amended complaint. Hertz opposed the request.
The court found good cause for a pause because the motion to dismiss could resolve the entire case, which involved only one breach-of-contract claim. The court also found that Hertz’s broad discovery request would impose significant obligations on Defendants and that a short delay would not significantly harm Hertz.
Judge Oetken granted Defendants’ request to stay discovery. He did not stay the entire case, and the planned mediation would not change deadlines unless the court later said otherwise.
The detailed version
- Hertz Global Holdings, Inc. v. National Union Fire Company of Pittsburgh · No. 1:19-cv-06957
- Alison Nathan
- Nov. 12, 2020
Background
Defendants asked the Court to stay, or temporarily pause, discovery while their motion to dismiss Hertz’s Second Amended Complaint was pending. Hertz opposed the request. The order resolves Docket Number 77.
Legal standard
The Court explained that Federal Rule of Civil Procedure 26(c) permits a district court to stay discovery when the party requesting the stay shows good cause. Courts generally consider the breadth of the requested discovery, the burden of responding, the prejudice to the opposing party, and the strength of the pending motion to dismiss.
Reasons for the decision
The Court found good cause. Hertz asserted only one claim—breach of contract—in its Second Amended Complaint, so a successful motion to dismiss was likely to resolve the case. The Court also found that Hertz’s discovery request was substantial. Although Hertz described the request as one document request and one deposition notice, the Court agreed with Defendants that the request was broad enough to impose significant discovery obligations, including preparing a corporate witness to address fourteen topics.
The Court concluded that Hertz would not suffer significant prejudice from a short delay. It reasoned that the requested discovery primarily involved documents and testimony from corporate witnesses who would rely heavily on documents when preparing for their depositions. The Court therefore found little risk that memories would fade in a way that would unfairly harm Hertz, and it identified no other significant prejudice.
Ruling
Judge J. Paul Oetken granted Defendants’ request to stay discovery while the motion to dismiss was pending. The Court did not stay the entire case. It also stated that the parties’ planned November 30, 2020 mediation would not affect deadlines unless the Court otherwise ordered.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.