Andrew Forrest v. Meta Platforms, Inc.

Summary

The United States District Court for the Northern District of California resolves a discovery dispute concerning Andrew Forrest’s request to serve 77 requests for admission on Meta Platforms, Inc. after the deadline for first-phase fact discovery. The court finds that Forrest did not establish good cause or diligence for most of the requests, but permits requests for admission 6 through 17 because they concerned data sources disclosed shortly before the discovery deadline. The permitted requests are deemed served as of December 5, 2025, and Meta must respond under Federal Rule of Civil Procedure 36.

Holdings

1. Plaintiff failed to establish good cause because most of the requests did not depend on information disclosed near the discovery deadline and plaintiff did not explain why they could not have been served earlier.
2. The court permitted plaintiff to obtain responses to requests for admission 6 through 17 because those requests concerned specific data sources that Meta produced and explained only a few weeks before the discovery deadline.

Questions Presented

1. Whether plaintiff established good cause and diligence sufficient to modify the discovery deadline and serve requests for admission after the close of first-phase discovery.
2. Whether requests for admission concerning recently produced and explained data sources should be permitted despite the discovery deadline.

Disposition

other