Case Law

The Court Denies the Plaintiff’s Patently Overbroad Discovery Requests

Michigan

Rockwell Med., Inc. v. Richmond Bros., 2017 U.S. Dist. LEXIS 57313 (E.D. Mich. Apr. 14, 2017) The plaintiff moved the court to sustain the plaintiff’s objection to a previous ruling that denied the plaintiff’s motion for expedited discovery and a temporary injunction. The injunction would require the defendants to undergo four depositions and answer five requests for documents within fifteen days. The court originally turned the discovery dispute over to Magistrate Judge Mona K. Majzoub, who found the plaintiff’s requests and proposed timeline “vexatious and harassing” and too broad to satisfy the proportionality requirement of FRCP 26(b)(1). The plaintiff objected to Judge Majzoub’s ruling and brought the present action, arguing that expedited discovery is normally allowed in conjunction with preliminary injunction motions. Additionally, the plaintiff argued that the accelerated timeline was necessary to obtain the requested information before the defendant held its annual shareholder meeting sometime within the following two months. The defendants countered that there was ample support for the magistrate’s decision. The court discussed the proportionality requirement of Rule 26(b)(1), and analyzed the factors that courts must weigh in considering discovery requests. The court found the plaintiff’s “exceedingly broad” list of requests to be an “immense [burden that] doubtless outweighs its likely benefit.” Specifically, the court highlighted one question that presented an extensive and verbose list of words and phrases defining the word “document”. Finally, the court held that a shortened timeline does not give a party permission to disregard the Federal Rules of Civil Procedure.

Keywords: proportionality, discovery, expedited, injunction, overly broad, discovery requests