Caicedo v. The Anthem Companies, Inc.

Background

Caicedo served discovery requests on The Anthem Companies on April 21, 2022. Anthem responded that it would not provide responses because, in its view, the discovery period had not begun. The parties submitted their competing positions at the court’s request.

The court had previously declined to enter a case-management plan until after resolving Caicedo’s motion for conditional collective certification. Caicedo argued that the court had not expressly stayed discovery and that she was entitled to pursue discovery concerning her individual claims and proposed class claims. She also argued that waiting could cause evidence and witness information to become harder to obtain.

Anthem argued that the court’s earlier decision necessarily delayed discovery because the certification ruling would determine whether the case proceeded only on Caicedo’s claims or also included other workers. Anthem characterized Caicedo’s requests for information, documents, and depositions across seven job positions as overly broad and costly before the court had defined the case’s scope.

Ruling

The court ordered that discovery was stayed pending resolution of Caicedo’s motion for conditional collective certification. Judge Valerie Caproni explained that the certification decision would determine the applicable scope of fact discovery and that allowing discovery beforehand would be inefficient and wasteful. The court also directed the clerk to close the open motion at docket entry 45.

The opinion addresses discovery timing and case management; it does not decide the merits of Caicedo’s underlying claims or her motion for conditional collective certification.