In re Meta Pixel Healthcare Litigation

Summary

The United States District Court for the Northern District of California denied plaintiffs’ request to depose former Meta employee Dinkar Jain after the close of fact discovery. The court found that plaintiffs had not acted diligently and had not made the particularized showing required to establish that Jain possessed unique relevant knowledge warranting an additional deposition.

Holdings

1. Plaintiffs were not entitled to take Jain's deposition after the fact-discovery deadline because they failed to show diligence in attempting to obtain the deposition during the discovery period or that Meta interfered with their ability to do so.
2. Plaintiffs failed to make the particularized showing of need required to obtain leave for Jain's deposition.

Questions Presented

1. Whether plaintiffs should be permitted to take Dinkar Jain's deposition after the close of fact discovery.
2. Whether plaintiffs made the required particularized showing of need for an additional individual fact-witness deposition beyond the applicable limit.
3. Whether the court should require Meta to reimburse Jain's counsel for travel expenses to India to defend the deposition.

Disposition

other