Dettmering v. VBit Technologies Corp.; Eichler v. VBit Technologies Corp.

Summary

The court granted in part and denied in part plaintiffs’ motion concerning discovery from defendant Katie Vo. It ordered Vo to supplement her written discovery responses with documents and emails relating to Truist Bank accounts by January 9, 2026, but denied the request to reopen discovery, pursue discovery on discovery, and recover expenses. The memorandum order was issued in connection with consolidated actions alleging that a Bitcoin mining business operated as a Ponzi scheme.

Holdings

1. Katie Vo must supplement her interrogatory and document-production responses with documents and emails within her possession, custody, or control relating to the materials produced by Truist Bank, including emails she originated, received, or on which she was copied.
2. Plaintiffs did not establish good cause to reopen fact discovery.
3. Plaintiffs were not entitled to compel discovery concerning Katie Vo's methods for searching and producing discovery.
4. Plaintiffs were not entitled to an award of reasonable expenses incurred in bringing the motion.

Questions Presented

1. Whether Katie Vo was required under Federal Rule of Civil Procedure 26(e)(1) to supplement her written discovery responses with documents and emails relating to the Truist Bank materials.
2. Whether Plaintiffs had shown good cause to reopen fact discovery after the discovery deadline.
3. Whether Plaintiffs could obtain discovery concerning Katie Vo's methods for searching and producing discovery.
4. Whether Plaintiffs were entitled to reasonable expenses incurred in bringing the motion.

Disposition

other