Christina MacLaren; and Elijah MacLaren v. PHH Mortgage Corporation

Summary

The United States District Court for the District of Oregon denies Plaintiffs Christina MacLaren and Elijah MacLaren’s motions for reconsideration. The court declines to reconsider its discovery rulings under Federal Rule of Civil Procedure 60(b)(2) and rejects reconsideration of its Findings and Recommendation under Rule 60(b)(1) and (6).

Holdings

1. The statements did not warrant reconsideration because plaintiffs failed to show that the evidence was of such magnitude that earlier production would likely have changed the court's discovery rulings.
2. Even if the court reconsidered its prior discovery rulings, the CFO's statements did not justify sanctions, an additional deposition, or a different result.
3. Rule 60(b)(6) did not apply because plaintiffs' assertions of overlooked evidence and legal error were based on mistake, a ground specifically covered by Rule 60(b)(1).
4. Plaintiffs did not establish a substantive mistake of law or fact warranting relief under Rule 60(b)(1); disagreement with the court's ruling was insufficient.

Questions Presented

1. Whether statements made by PHH's chief financial officer constituted newly discovered evidence warranting reconsideration of the court's discovery orders under Rule 60(b)(2).
2. Whether those statements justified reconsidering the denial of discovery sanctions or permitting plaintiffs to depose the chief financial officer.
3. Whether plaintiffs could obtain relief under Rule 60(b)(6) based on alleged overlooked evidence or legal error in the Findings and Recommendation.
4. Whether plaintiffs' disagreement with the Findings and Recommendation established a substantive mistake warranting relief under Rule 60(b)(1).

Disposition

other