Cheria Brown v. Equifax Information Services, LLC

Summary

The court memorializes rulings from a February 2, 2026 telephonic status conference in a consumer dispute involving Equifax. It denies Equifax’s motion to dismiss without prejudice, denies or partially grants several discovery-related motions, sets May 4, 2026 as the discovery deadline, and orders the parties to address remaining discovery disputes. The court also denies Plaintiff Brown’s motion to compel Equifax’s representative to travel to Ohio for a deposition, finding that she failed to establish good cause for that relief under Federal Rule of Civil Procedure 26(c).

Holdings

1. A party seeking a protective order or other protection concerning the time or place of a deposition must establish good cause under Federal Rule of Civil Procedure 26(c)(1) through a particular and specific demonstration of annoyance, embarrassment, oppression, undue burden, or expense; Brown's conclusory reliance on her pro se status did not satisfy that burden.
2. Equifax's motion to dismiss was denied without prejudice, subject to refiling as a motion for summary judgment if appropriate.

Questions Presented

1. Whether Equifax's motion to dismiss should be denied without prejudice subject to possible refiling as a motion for summary judgment.
2. Whether discovery should be stayed or Brown should be permitted to defer responding to discovery pending resolution of the motion to dismiss.
3. Whether the discovery deadline should be extended and what discovery obligations the parties should undertake.
4. Whether Brown established good cause under Federal Rule of Civil Procedure 26(c)(1) to require an Equifax representative to travel to Ohio for a deposition.

Disposition

other