William Morgan v. Imani Express, LLC, and Muez Gebrehiwot Hagdu

Summary

The United States District Court for the Eastern District of Oklahoma grants in part and denies in part Plaintiff William Morgan’s motion to compel and grants Defendant Imani Express, LLC’s motion to compel in a vehicle-accident action. The order addresses discovery concerning ownership and dispatch records, mechanical failure, driver and personnel records, medical records, financial information, damages computations, non-retained expert disclosures, and claimed injuries. The parties are ordered to supplement discovery and produce documents consistent with the order within 21 days of entry.

Holdings

1. Discovery requests seeking nonprivileged information relevant and proportional to the claims or defenses must be answered or supplemented, and objections must be overruled where the requested information falls within Federal Rule of Civil Procedure 26(b)(1)'s scope.
2. Imani Express's motion to compel was not untimely under the circumstances, despite being filed after the discovery deadline.
3. A plaintiff must supplement initial disclosures to provide a computation of each category of damages claimed, including amounts for economic and noneconomic damages, consistent with Rule 26(a)(1)(A)(iii).
4. A party identifying non-retained treating physicians as expert witnesses must disclose the subject matter of each physician's expected testimony and a summary of the facts and opinions to which each physician is expected to testify; merely incorporating medical records by reference is insufficient.
5. An interrogatory requiring Plaintiff to identify and describe permanent scars, disfigurements, disabilities, and discomforts allegedly caused by the accident was sufficiently specific and relevant, and Plaintiff was required to answer it.

Questions Presented

1. Whether Plaintiff was entitled to compel additional discovery from Hagdu and Imani Express concerning accident history, alleged brake malfunction, affirmative defenses, vehicle ownership, dispatch records, mechanical-failure claims, compensation, employment and driver records, vehicle-condition reports, other accidents, medical records, and financial information.
2. Whether Imani Express's motion to compel was untimely because it was filed after the discovery deadline.
3. Whether Plaintiff was required to supplement his initial disclosures with a computation of damages by category under Federal Rule of Civil Procedure 26(a)(1)(A)(iii).
4. Whether Plaintiff's disclosures for seven non-retained treating physicians satisfied Federal Rule of Civil Procedure 26(a)(2)(C).
5. Whether Plaintiff was required to answer an interrogatory concerning permanent scars, disfigurements, disabilities, and discomforts allegedly resulting from the accident.

Disposition

other