Sandifer v. Hoyt Archery, Inc.

7 Citing cases

  1. Hardy v. N.J. Manufacturers Ins. Co.

    Civil Action 22-153-SDD-RLB (M.D. La. Apr. 11, 2023)

    The responding party has no obligation to respond and object to written discovery if the response and objection would not be due until after the discovery deadline.”); see also Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) (“Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline.”); Dixon v. Greyhound Lines, Inc., No. 13179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 204)

  2. Nelson v. Landry

    Civil Action 20-837-JWD-RLB (M.D. La. Mar. 16, 2023)

    This Court has expressly held that discovery requests served prior to the discovery deadline that require compliance after the discovery deadline are untimely. See, e.g., Hall v. State of Louisiana, No. 12-657, 2014 WL at 2560715, at *1 (M.D. La. June 6, 2014) (discovery requests served on party 14 days before discovery deadline were untimely as the party had 30 days to respond to such discovery requests); see also Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) (“Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline.”); Dixon v. Greyhound Lines, Inc., No. 13-179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014)

  3. Nelson v. Landry

    No. 20-837-JWD-RLB (M.D. La. Sep. 16, 2022)   Cited 1 times

    This Court has expressly held that a subpoena served before the discovery deadline is nevertheless untimely if the date of compliance is beyond the discovery deadline. See, e.g., Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) (“Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline.”); Dixon v. Greyhound Lines, Inc., No. 13179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014) (“Although it was served 6 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the September 2, 2014 deadline.”); see also Hall v. State of Louisiana, No. 12-657, 2014 WL at 2560715, at *1 (M.D. La. June 6, 2014) (discovery requests served on party 14 days before discovery deadline were untimely as the party had 30 days to respond to such discovery requests).

  4. Durham v. Amikids Baton Rouge, Inc.

    CIVIL ACTION NO. 17-343-JWD-RLB (M.D. La. Aug. 26, 2018)

    This Court has also expressly held that a subpoena served before the discovery deadline is nevertheless untimely if the date of compliance is beyond the discovery deadline. See, e.g., Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) ("Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline."); Dixon v. Greyhound Lines, Inc., No. 13-179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014) ("Although it was served 6 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the September 2, 2014 deadline."). As stated above, a Rule 45 subpoena cannot be used to shorten the 30-day deadline to respond to discovery requests provided to a party.

  5. Laird v. State Farm Fire & Cas. Co.

    CIVIL ACTION NO. 16-707-JWD-RLB (M.D. La. Jul. 20, 2017)

    This Court has expressly held that a subpoena served before the discovery deadline is nevertheless untimely if the date of compliance is beyond the discovery deadline. See, e.g., Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) ("Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline."); Dixon v. Greyhound Lines, Inc., No. 13-179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014) ("Although it was served 6 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the September 2, 2014 deadline."); see also Hall v. State of Louisiana, No. 12-657, 2014 WL at 2560715, at *1 (M.D. La. June 6, 2014) (discovery requests served on party 14 days before discovery deadline were untimely as the party had 30 days to respond to such discovery requests). Considering that defendant Michael Rojas did not seek an extension of the non-expert discovery deadline prior to the issuance and service of the instant subpoena, and in advance of the expiration of the applicable deadline, the Court does not find good cause for extending the discovery deadline with regard to the instant

  6. Mcmillan v. J.P. Morgan Chase Bank, N.A.

    CIVIL ACTION NO. 15-500-SDD-RLB (M.D. La. Feb. 2, 2017)   Cited 2 times

    This Court has expressly held that discovery requests served prior to the discovery deadline that require compliance after the discovery deadline are untimely. See, e.g., Hall v. State of Louisiana, No. 12-657, 2014 WL at 2560715, at *1 (M.D. La. June 6, 2014) (discovery requests served on party 14 days before discovery deadline were untimely as the party had 30 days to respond to such discovery requests); see also Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) ("Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline."); Dixon v. Greyhound Lines, Inc., No. 13-179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014) ("Although it was served 6 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the September 2, 2014 deadline.").

  7. Mcmillan v. J.P. Morgan Chase Bank, N.A.

    CIVIL ACTION NO. 15-500-SDD-RLB (M.D. La. Jan. 25, 2017)   Cited 1 times
    Holding that a motion to quash filed the seventh day after the close of discovery was timely filed pursuant to Local Rule 26 because it sought to quash subpoenas duces tecum served by the plaintiff on the day of the fact discovery deadline

    This Court has expressly held that a subpoena served before the discovery deadline is nevertheless untimely if the date of compliance is beyond the discovery deadline. See, e.g., Sandifer v. Hoyt Archery, Inc., No. 12-322, 2015 WL 3465923, at *2 (M.D. La. June 1, 2015) ("Although it was served 4 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the March 31, 2015 deadline."); Dixon v. Greyhound Lines, Inc., No. 13-179, 2014 WL 6474355, at *3 (M.D. La. Nov. 19, 2014) ("Although it was served 6 days before the expert discovery deadline, the subpoena was untimely as it required compliance outside of the September 2, 2014 deadline."); see also Hall v. State of Louisiana, No. 12-657, 2014 WL at 2560715, at *1 (M.D. La. June 6, 2014) (discovery requests served on party 14 days before discovery deadline were untimely as the party had 30 days to respond to such discovery requests). Moreover, a Rule 45 subpoena cannot be used to shorten the 30-day deadline to respond to discovery requests provided to a party.