Autoport (Michigan) Ltd. v. Universal Protection Service, LLC

Summary

The United States District Court for the Eastern District of Michigan denied Universal Protection Service, LLC’s motion for reconsideration of an order denying an extension of the discovery deadline. The court held that the defendant failed to show a qualifying mistake, good cause, or excusable neglect, and had not explained its failure to diligently pursue depositions during the nine-month discovery period.

Holdings

1. Defendant did not establish that the court made a mistake, that correcting any alleged mistake would change the outcome, or that the prior ruling was mistaken based on the record and law before the court.
2. Defendant failed to establish good cause or excusable neglect because it did not diligently pursue the depositions during the nine-month discovery period and did not timely seek relief before the deadline expired.
3. A settlement conference is not a vehicle for addressing discovery failures or a substitute for timely motion practice, and counsel's expectation that it would revive lapsed discovery rights did not establish good cause or excusable neglect.

Questions Presented

1. Whether Defendant demonstrated grounds for reconsideration under E.D. Mich. LR 7.1(h)(2)(A).
2. Whether any alleged error concerning the timeliness of Defendant's post-deadline motion would have changed the prior ruling.
3. Whether Defendant established good cause and excusable neglect for extending discovery after the deadline.

Disposition

other