Jade Pruitt v. Mary Jackson, et al.

Pruitt · United States District Court for the Western District of Kentucky · May 15, 2026 · No. 5:22-cv-00139-BJB-LLK

Summary

The United States District Court for the Western District of Kentucky partially granted and partially denied Plaintiff Jade Pruitt’s motion to compel discovery. The court denied requests to depose Werner Enterprises’ vice president and to obtain specified training materials, finding insufficient demonstrated relevance to the surviving claims. The court granted the motion as to supplemental responses concerning recently discovered potentially relevant documents.

Holdings

  1. The court denied the motion to compel Hamm's deposition because Pruitt failed to show that Hamm had personal knowledge of relevant facts or that her deposition was otherwise relevant.
  2. The court denied the motion to compel production of the requested training materials because Pruitt failed to demonstrate their relevance to the surviving negligent hiring and negligence per se claims.
  3. The court granted the motion to compel supplemental responses and required production of the relevant portions of the recently discovered materials, including Jackson's skill evaluation, the pre-trip inspection guide, and the orientation PowerPoint.

Questions Presented

  1. Whether Pruitt demonstrated sufficient relevance and proportionality to compel the deposition of Jamie Hamm as a fact witness.
  2. Whether Pruitt demonstrated that the requested training materials were relevant to the surviving negligent hiring and negligence per se claims.
  3. Whether Werner should be required to supplement its discovery responses regarding recently discovered potentially relevant materials.

Disposition

other

Cases Cited (9)

  • In re Air Crash Disaster, 86 F.3d 498, 516 (6th Cir. 1996)(followed)
  • Lavado v. Keohane, 992 F.2d 601, 604 (6th Cir. 1993)(followed)
  • Veritiv Operating Company v. Phoenix Paper Wickliffe, LLC, 2023 WL 2975868, at *6 (W.D. Ky. Apr. 17, 2023)(followed)
  • Guiden v. Leatt Corp., 2013 WL 12234612, at *2 (W.D. Ky. Apr. 30, 2013)(followed)
  • Grayiel v. AIO Holdings, LLC, 2017 WL 11592083, at *3 (W.D. Ky. May 2, 2017)(followed)
  • Smith v. Gen. Mills, Inc., No. C2 04-705, 2006 U.S. Dist. LEXIS 19093, at *17-18 (S.D. Ohio Apr. 13, 2006)(not_followed)
  • James v. Wash Depot Holdings, Inc., 240 F.R.D. 693, 695 (S.D. Fla. 2006)(followed)
  • In re Hines Furlong Line, Inc., 2026 WL 613025, at *3 (W.D. Ky. Mar. 4, 2026)(followed)
  • Nix, 11 F. App'x at 500(not_followed)

Cited In (0)

No citing cases on record yet.

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