Courts have held financial records to be relevant and discoverable in cases alleging unfair business practices. See Upchurch v. USTNET, Inc., 158 F.R.D. 157, 160 (D. Or. 1994) (finding documents “indicating [defendant's] financial condition” relevant to claims of tortious interference with contract and prospective advantage and unfair competition); W. Air Charter v. Schembari, 2018 WL 6537158, *5 (C.D. Cal. Apr. 9, 2018) (finding plaintiff's “balance sheet, income statement, and statement of cash flows” relevant to punitive damages on counterclaim of intentional interference with prospective economic advantage). Here, Crossroads' bank statements are relevant to Jim Hawk's claims of misappropriation of trade secrets, tortious interference with businesses relations and employee relationships, unjust enrichment, and unfair competition.
See, e.g.,Simon v. Whichello, 2006 WL 2042154, *3-4 (N.D.Ind. July 18, 2006) (holding bank statements and loan documents for three years following stock sale were relevant to allegations of misrepresentation regarding the stock value and company's financial condition, because the " reveal[ed] the financial status of the business and the changes, if any, in that condition." ); Data-Link Sys., Inc. v. Data Line Serv., Inc., 148 F.R.D. 225, 227-228 (N.D.Ind.1992) (holding plaintiff's request for " [a]ll monthly and annual financial statements ... income statements, balance sheets and cash flow statements ... that in any way relate to Defendant's revenues, profits or losses derived directly or indirectly from the MeraBank Account," was not overly broad); Upchurch v. USTNET, Inc., 158 F.R.D. 157, 160 (D.Or.1994) (granting plaintiff's motion to compel discovery of defendant's financial condition from October 1, 1992 to October 19, 1994, because the requested information was relevant to defendant's counterclaims for tortious interference with contract and unfair competition). Additionally, Hudson contends in his response that Yessenow failed to make a good faith effort to resolve this discovery dispute as required by Local Rule 37.1, because he failed to explain how the discovery sought related to any claims or defenses at issue in this case.