Liguria Foods, Inc. v. Griffith Laboratories, Inc.

320 F.R.D. 168 (2017)

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Liguria Foods, Inc. v. Griffith Laboratories, Inc.

United States District Court for the Northern District of Iowa
320 F.R.D. 168 (2017)

Facts

Liguria Foods, Inc. (plaintiff), a pepperoni and dried-sausage manufacturer, brought suit against Griffith Laboratories, Inc. (defendant), a manufacturer of food seasonings, for claims related to the premature spoliation of pepperoni containing Griffith Laboratories’ seasoning. During the course of the litigation, the district-court judge reviewed the parties’ written discovery responses and observed that both sides had submitted numerous boilerplate objections. These objections stated generic legal grounds for the objection—such as relevance, overbreadth, burden, or privilege—without explaining how the requests were deficient, how responding would cause specific harm, or why a privilege applied. In response, the judge issued a show-cause order requiring all attorneys who signed the responses to appear and explain why they should not be sanctioned. In their written and oral responses, counsel for both parties candidly admitted that their objections were boilerplate. However, they argued that the objections were not made in bad faith and were instead intended to preserve their rights during ongoing discussions about the scope of discovery. Counsel emphasized that discovery had been conducted in a cooperative and professional manner, with most disputes resolved without court intervention, and they pledged to comply with proper discovery practices in the future.

Rule of Law

Issue

Holding and Reasoning (Bennett, J.)

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