Eniola Famuyide v. Chipotle Mexican Grill, Inc., and Chipotle Services, LLC

Summary

The United States District Court for the District of Minnesota addresses competing motions concerning a Rule 30(b)(6) deposition in Eniola Famuyide’s action against Chipotle entities. The Court denies Chipotle Services, LLC’s motion for a protective order and grants Plaintiff’s motion to compel and for sanctions, except for the requested evidentiary sanctions. The order discusses the parties’ obligations under Rules 26, 30, and 37 and Local Rule 7.1, including preparation of corporate witnesses, meet-and-confer requirements, and monetary sanctions.

Holdings

1. The motion for a protective order was denied in its entirety. The disputed topics were reasonably particular and within the permissible scope of discovery; Defendants did not establish that the topics were unreasonably cumulative, duplicative, irrelevant, or disproportionate.
2. Defendants failed to meet and confer in good faith before filing the protective-order motion as to Topics 5, 6, 8, 14, and 15, after withdrawing their objections and later reversing position without notifying Plaintiff.
3. Defendants were ordered to designate and make available one or more adequately prepared corporate witnesses for a second Rule 30(b)(6) deposition on Topics 4-6, 8, 11-19, and 21-24.
4. Topics 21 and 22, concerning Defendants' steps to preserve evidence, were within the permissible scope of discovery because Defendants' discovery compliance had reasonably been called into question and an adequate factual basis existed for the inquiry.
5. The Jerome Consent Decree imposed nationwide obligations on Chipotle Services, LLC, including at the Rochester, Minnesota restaurant, because it required Chipotle to maintain specified anti-discrimination policies nationwide.
6. Plaintiff was entitled to reasonable expenses and attorney's fees incurred in bringing the motion to compel and in traveling to the August 12, 2025 deposition, plus additional case-management sanctions. Evidentiary sanctions were denied at that time.

Questions Presented

1. Whether Defendants' motion for a protective order should be granted because the Rule 30(b)(6) topics were insufficiently particular, irrelevant, disproportionate, cumulative, or duplicative.
2. Whether Defendants failed to meet and confer in good faith before seeking protection as to topics for which they had previously withdrawn objections.
3. Whether Defendants were required to produce adequately prepared corporate witnesses for a second Rule 30(b)(6) deposition.
4. Whether Plaintiff was entitled to evidentiary, monetary, and other sanctions for Defendants' conduct during the deposition process.
5. Whether discovery into Defendants' preservation efforts and EEOC consent decrees was permissible under the circumstances.

Disposition

other