NRRM, LLC, doing business as CarShield, et al. v. Pelican Investment Holdings, LLC, et al.

Summary

The United States District Court for the Eastern District of Missouri granted in part and denied in part motions concerning expedited discovery and a protective order in litigation alleging false advertising, unfair competition, tortious interference, and trade secret misappropriation. The court authorized limited expedited discovery between CarShield and Pelican concerning issues relevant to CarShield’s pending preliminary-injunction motion, and ordered a separate protective order adopting Plaintiffs’ proposed terms for access to attorneys-eyes-only materials. The court also granted CarShield’s unopposed request for a preliminary-injunction hearing, scheduled for April 2, 2026.

Holdings

1. CarShield demonstrated good cause for limited, expedited discovery because the discovery was relevant to its false-advertising claim and preliminary-injunction motion, would create a more complete record for the hearing, and the interests of justice outweighed potential prejudice to Pelican.
2. AAS was not entitled to expedited discovery because it was not a party to the pending motion for a preliminary injunction.
3. Defendants demonstrated sufficient grounds for entry of a protective order, but failed to show specific harm or prejudice that justified rejecting CarShield's proposal allowing one qualified in-house attorney to access attorneys-eyes-only materials.
4. CarShield was entitled to a hearing on its pending motion for a preliminary injunction.

Questions Presented

1. Whether CarShield and AAS showed good cause for expedited discovery before the Rule 26(f) conference to support CarShield's pending preliminary-injunction motion.
2. Whether AAS was entitled to expedited discovery even though it was not a party to the pending preliminary-injunction motion.
3. Whether defendants demonstrated good cause for a protective order and for restricting access to attorneys-eyes-only materials more than plaintiffs proposed.
4. Whether CarShield was entitled to a hearing on its pending motion for a preliminary injunction.

Disposition

other