Richard Cora v. Amgen Manufacturing Limited

Summary

The United States District Court for the District of Puerto Rico partially grants and partially denies Amgen Manufacturing Limited’s motion to compel discovery responses from Plaintiff Richard Cora. The Court compels supplemental responses concerning mitigation efforts, financial accounts, medical history and treatment, medications, damages, and related records, while limiting a request for personal notes, diaries, and chronicles to materials facially relevant to the claims.

Holdings

1. Discovery is governed by relevance and proportionality under Rule 26(b)(1), and a court may compel responses when a party fails to provide discovery within that scope after the required good-faith conferral.
2. A responding party must answer interrogatories separately and fully, based on a reasonable inquiry, and must state under oath when responsive information is unavailable and describe the efforts made to obtain it.
3. When a plaintiff affirmatively places physical or emotional conditions in controversy by seeking damages for them, discovery concerning relevant medical history, providers, treatment, medications, and medical records is permissible if appropriately limited and proportional.
4. A party's offer to authorize the opposing party to obtain records from a third party does not substitute for a substantive interrogatory response or relieve the party of the obligation to produce responsive documents within the party's possession, custody, or control.
5. Requests for diaries, notes, agendas, calendars, and social-media materials may be compelled only to the extent the materials exist and contain information facially relevant to the claims; wholesale or unfettered production is disproportionate and impermissible.
6. Discovery requests may be denied as cumulative or duplicative when the requesting party is already receiving substantial information that provides a comprehensive view of the claimed financial condition.

Questions Presented

1. Whether Amgen was entitled to compel supplemental responses to interrogatories concerning Cora's mitigation efforts, financial accounts, medical history, treatment, medications, and categories of damages.
2. Whether Amgen was entitled to compel production of medical, prescription, financial, tax, employment-search, communications, and damages-supporting documents under Federal Rule of Civil Procedure 26(b)(1).
3. Whether requests for personal diaries, agendas, calendars, social-media materials, and similar private writings were overbroad or disproportionate and therefore required limitation.
4. Whether Cora's offer to authorize Amgen to obtain Department of Veterans Affairs records relieved him of his obligation to provide substantive interrogatory answers or produce documents within his possession, custody, or control.
5. Whether certain financial requests were cumulative or duplicative under Federal Rule of Civil Procedure 26(b)(2)(C).

Disposition

other