Lateral Recovery, LLC v. Queen Funding, LLC

What the filing concerns

The text is a letter from counsel for defendants Queen Funding, LLC and Yehuda Klein requesting a conference with the court about discovery disputes. The letter says the parties met and conferred by telephone on November 15, 2022, but the disputes remained unresolved.

Discovery disputes

The plaintiff sought a deposition of Yehuda Klein and a deposition of Queen Funding, LLC under Federal Rule of Civil Procedure 30(b)(6), which permits an organization to be questioned through a designated representative about specified topics. Defendants argued that the revised notice did not describe the topics with reasonable particularity and lacked clear limits. Queen Funding, LLC requested a protective order, which is a court order limiting discovery to protect a party from undue burden or expense.

Defendants characterized the action as a closed-ended civil Racketeer Influenced and Corrupt Organizations Act matter that was not brought as a class action. They argued that the plaintiff’s proposed discovery about other entities and Queen Funding, LLC’s other clients was unrelated to the allegations in this case and was not proportional to the case’s needs. The letter also raised a demand for supplemental discovery, allegedly unrevised responses to defendants’ discovery requests, and the plaintiff’s failure to provide a privilege log during the four months after its document production.

Court’s action

The document states that Judge Lorna G. Schofield ordered the plaintiff to file a response of no more than three pages by December 2, 2022. The text does not state that the court granted or denied the requested conference, protective order, depositions, or other discovery relief. It also does not decide the underlying civil RICO allegations.