Squires v. Toyota Motor Corp., Slip Copy (2021) — Memorandum Opinion and Order (Exhibit C, Document 171-3)

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         EXHIBIT C
  Case 1:20-cv-00658-LMB-IDD                  Document 171-3
Squires v. Toyota Motor Corp., Slip Copy (2021)
                                                                      Filed 08/03/21          Page 2 of 6 PageID#
                                                     4354

                                                               J. Hagman, Cafferty Clobes Meriwether & Sprengel LLP,
                                                               Chicago, IL, for Plaintiff Donna Sue Scott.
                  2021 WL 1837540
    Only the Westlaw citation is currently available.          Thomas M. Melsheimer, Ahtoosa Dale, Elyse J. Lyons,
             United States District Court,                     Michael Brett Johnson, Natalie Lynn Arbaugh, Winston &
            E.D. Texas, Sherman Division.                      Strawn LLP, Taj Jamar Clayton, Kirkland & Ellis LLP,
                                                               Dallas, TX, Anna Rebecca Skupin, Clyde Moody Siebman,
   William SQUIRES, Jesse Badke, Ahmed                         Elizabeth Siebman Forrest, Siebman Forrest Burg & Smith
   Khalil, Michelle Nidever, John Murphy,                      LLP, Sherman, TX, for Defendants.
     Kevin Neuer, Nicholas Williams, and
   Donna Sue Scott, on behalf of themselves
                                                               MEMORANDUM OPINION AND ORDER
  and all others similarly situated, Plaintiffs,
                       v.                                      AMOS L. MAZZANT, UNITED STATES DISTRICT
                                                               JUDGE
      TOYOTA MOTOR CORP., Toyota
    Motor North America, Inc., and Toyota                       *1 Pending before the Court is Plaintiffs’ Motion to Compel
                                                               Depositions of Toyota Employees (Dkt. #100). Having
    Motor Sales, U.S.A., Inc., Defendants.
                                                               considered the motion and the relevant pleadings, the Court
                                                               finds that Plaintiff's motion should be denied.
           CIVIL ACTION NO. 4:18-CV-00138
                          |
                  Signed 05/07/2021
                                                               BACKGROUND
Attorneys and Law Firms
                                                               On March 1, 2018, Plaintiffs William Squires, Jesse Badke,
William B. Chaney, Andrew K. York, London Ryynanen             Ahmed Khalil, Dominick Viscardi, Michelle Nidever, John
England, Gray Reed & McGraw LLP, Dallas, TX, Bryan L.          Murphy, Kevin Neuer, Nicholas Williams, and Lawrence
Clobes, Cafferty Clobes Meriwether & Sprengel LLP, Glen        Baker filed this suit (Dkt. #1). On May 23, 2018, Plaintiffs
L. Abramson, Jeffrey L. Osterwise, Berger & Montague PC,       filed their First Amended Complaint (Dkt. #15). Plaintiffs are
Philadelphia, PA, Daniel O. Herrera, John Scheflow, Nickolas   current and former owners and lessees of Fourth Generation
J. Hagman, Cafferty Clobes Meriwether & Sprengel LLP,          Model Years 2016-17 Toyota Prius vehicles (“Prius”) (Dkt.
Chicago, IL, for Plaintiffs William Squires, Jesse Badke,      #15 ¶ 1). Plaintiffs allege the Prius contains a defect that
Ahmed Khalil, Michelle Nidever.                                causes the windshields of the vehicle to unexpectedly crack in
                                                               foreseeable driving conditions (Dkt. #15 ¶ 2). Plaintiffs seek
Glen L. Abramson, Jeffrey L. Osterwise, Berger & Montague
                                                               to certify a nation-wide class action on behalf of themselves
PC, Philadelphia, PA, London Ryynanen England, William B.
                                                               and other current and former owners of the Prius (Dkt. #15
Chaney, Gray Reed & McGraw LLP, Dallas, TX, Nickolas
                                                               ¶¶ 1, 137–46).
J. Hagman, Cafferty Clobes Meriwether & Sprengel LLP,
Chicago, IL, for Plaintiffs John Murphy, Kevin Neuer.
                                                               On January 4, 2021, Plaintiffs filed the present motion (Dkt.
Jeffrey L. Osterwise, Berger & Montague PC, Philadelphia,      #100). On January 25, 2021, Toyota filed a response (Dkt.
PA, London Ryynanen England, William B. Chaney, Gray           #110).1 On February 3, 2021, Plaintiffs filed a reply (Dkt.
Reed & McGraw LLP, Dallas, TX, Nickolas J. Hagman,             #118). On February 10, 2021, Toyota filed a sur-reply (Dkt.
Cafferty Clobes Meriwether & Sprengel LLP, Chicago, IL,        #119).
for Plaintiff Nicholas Williams.

William B. Chaney, Andrew K. York, London Ryynanen
England, Gray Reed & McGraw LLP, Dallas, TX, Bryan L.          LEGAL STANDARD
Clobes, Cafferty Clobes Meriwether & Sprengel LLP, Glen
                                                               Under Federal Rule of Civil Procedure 26(b)(1), parties “may
L. Abramson, Jeffrey L. Osterwise, Berger & Montague PC,
                                                               obtain discovery regarding any non[-]privileged matter that
Philadelphia, PA, Daniel O. Herrera, John Scheflow, Nickolas


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is relevant to any party's claim or defense....” Fed. R. Civ.         Civ. P. 26(g). This rule “simply requires that the attorney
P. 26(b)(1). “Information within this scope of discovery need         make a reasonable inquiry into the factual basis of his
not be admissible in evidence to be discoverable.” Fed. R.            response, request, or objection.” Fed. R. Civ. P. 26(g) advisory
Civ. P. 26(b)(1). The Court's scheduling order requires that the      committee note (1983).
parties produce, as part of their initial disclosure, “documents
containing, information ‘relevant to the claim or defense of          The federal rules follow a proportionality standard for
any party.’ ” (Dkt. #39 at p. 4). Moreover, the Local Rules           discovery. Fed. R. Civ. P. 26(b)(1). Under this requirement,
of the Eastern District of Texas provide further guidance             the burden falls on both parties and the court to consider
suggesting that information is “relevant to any party's claim or      the proportionality of all discovery in resolving discovery
defense [if]: (1) it includes information that would not support      disputes. Fed. R. Civ. P. 26(b)(1), advisory committee note
the disclosing parties’ contentions; ... (4) it is information that   (2015). This rule relies on the fact that each party has a unique
deserves to be considered in the preparation, evaluation or           understanding of the proportionality to bear on the particular
trial of a claim or defense....” LOCAL RULE CV-26(d). It is           issue. Id. For example, a party requesting discovery may have
well established that “control of discovery is committed to the       little information about the burden or expense of responding.
sound discretion of the trial court.” Freeman v. United States,       Id. “The party claiming undue burden or expense ordinarily
556 F.3d 326, 341 (5th Cir. 2009) (quoting Williamson v. U.S.         has far better information—perhaps the only information—
Dep't of Agric., 815 F.2d 368, 382 (5th Cir. 1987)).                  with respect to that part of the determination.” Id.

Rule 37 of the Federal Rules of Civil Procedure allows a
discovering party, on notice to other parties and all affected
                                                                      ANALYSIS
persons, to “move for an order compelling disclosure or
discovery.” Fed. R. Civ. P. 37(a)(1). The moving party bears          Plaintiffs ask the Court to compel the dispositions of
the burden of showing that the materials and information              two Toyota employees: Seiho Yonezawa (“Yonezawa”) and
sought are discoverable. Export Worldwide, Ltd. v. Knight,            Norihiro Kamo (“Kamo”) (collectively, the “Deponents”). In
241 F.R.D. 259, 263 (W.D. Tex. 2006). Once the moving party           support of their request, Plaintiffs assert both that they could
establishes that the materials requested are within the scope of      not have identified the Deponents until late 2019, and that
permissible discovery, the burden shifts to the party resisting       the Deponents possess unique information Plaintiffs’ need.
discovery to show why the discovery is irrelevant, overly             Further, Plaintiffs contend that the Deponents’ testimony will
broad, unduly burdensome or oppressive, and thus should not           inform class certification and expert proceedings. According
be permitted. Id.                                                     to Plaintiffs, Toyota Motor Company (“TMC”) deleted
                                                                      documents that may shed light on the Deponents’ analyses
 *2 Federal Rule of Civil Procedure 34 governs requests for           and thought processes, thus necessitating depositions. Finally,
production of documents, electronically stored information,           Plaintiffs note that Japanese law prohibits the Deponents from
and tangible things. Rule 34 requires responses to “either            appearing within Japan.
state that inspection and related activities will be permitted as
requested or state with specificity the grounds for objecting         Toyota first responds that the Court does not have jurisdiction
to the request, including the reasons.” Fed. R. Civ. P. 34(b)(2)      to compel the Deponents. Regarding an agreement, Toyota
(B). “An objection [to the entire request] must state whether         argues that, contrary to Plaintiffs’ argument, it did not agree
any responsive materials are being withheld on the basis of           to present all Toyota employees located in Japan for a
that objection.” Fed. R. Civ. P. 34(b)(2)(C). On the other hand,      deposition in Dallas. Toyota further claims that, in any event,
“[a]n objection to part of a request must specify the part and        the pandemic justifies departing from any such agreement.
permit inspection of the rest.” Fed. R. Civ. P. 34(b)(2)(C).          Toyota asserts that the Deponents have limited knowledge
                                                                      about the investigation of the Prius windshields, and other
After responding to each request with specificity, the                U.S.-based witnesses with more relevant knowledge are
responding attorney must sign their request, response, or             readily available for deposition.
objection certifying that the response is complete and correct
to the best of the attorney's knowledge and that any objection
is consistent with the rules and warranted by existing law            I. Location of Depositions
or a non-frivolous argument for changing the law. Fed. R.



                © 2021 Thomson Reuters. No claim to original U.S. Government Works.                                                 2
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As an initial matter, the parties do not dispute that the              25, 2019) (citations omitted). “If the deponent must be
depositions may not presently be taken in Japan. Obtaining             compelled, the party seeking to compel the deposition
evidence in Japan in civil matters is governed by, among               must use the appropriate international means.” Id. (citations
other sources, the U.S.-Japan bilateral Consular Convention            omitted). “If the party seeking to compel the deposition of
of 1963 (the “Treaty”).2 Article 17 of the Treaty requires             an unwilling, non-citizen, non-party living abroad does not
depositions to either take place in the U.S. Consulate or the          act in accordance with the appropriate international means
U.S. Embassy—both of which are currently closed due to the             and controlling laws, a federal district court, alone, cannot
                                                                       compel the deposition.” Rubaroc, 2019 WL 7905457, at *2
COVID-19 pandemic.3 Neither location is taking reservations
                                                                       (first citing DiRienzo v. Philip Servs. Corp., 294 F.3d 21, 30
until further notice. Thus, the Deponents would necessarily
                                                                       (2d Cir. 2002); and then citing EFCO Corp. v. Aluma Sys.
have to travel outside Japan to partake in the requested
                                                                       USA, Inc., 145 F. Supp. 2d 1040, 1048 (S.D. Iowa 2000)).
depositions.

                                                                       No facts indicate that the Deponents are willing to appear
II. Court's Subpoena Power                                             voluntarily. In fact, quite the opposite can be inferred by
 *3 A party's access to discovery is, as a general rule,               Toyota's response to Plaintiffs’ motion to compel. Further,
incredibly broad. See Fed. R. Civ. P. 26(b)(1). However, the           Plaintiffs do not argue that they employed the appropriate
Federal Rules of Civil Procedure do place certain limitations          international means. As such, and after noting that the
on the availability of discovery. Relevant to the present action,      Deponents neither live within 100 miles of the Court nor
Rule 45 limits the Court's subpoena power. “A subpoena                 could sit for a deposition within 100 miles of their homes, the
may command a person to attend a ... deposition” only                  Court recognizes that it does not have subpoena power under
in two circumstances: (1) “within 100 miles of where the               Rule 45 to compel the depositions of Deponents. That finding
person resides, is employed, or regularly transacts business in        alone does not end the Court's analysis, however. The Court
person[;] or” (2) “within the state where the person resides,          must also determine what effect, if any, the agreement made
is employed, or regularly transacts business in person, if the         between the parties regarding the modification of discovery
person ... is a party or a party's officer; or ... is commanded to     (the “Agreement”) has on the Court's ability to compel the
attend a trial and would not incur substantial expense.” Fed. R.       Deponents to sit for a remote deposition—despite the inability
Civ. P. 45(c)(1). More directly: “a district court cannot use its      of the Court to do so under the Rules.5
subpoena power to compel a witness to travel more than 100
miles.” West Wind Africa Line, Ltd. v. Corpus Christi Marine
Servs. Co., 834 F.2d 1232, 1237 (5th Cir. 1988). Moreover,             III. Parties’ Agreement
“[i]t is well settled that ‘[t]he deposition of a corporation by its   Plaintiffs rely heavily—if not solely—on the Agreement.
agents and officers should ordinarily be taken at its principle        Plaintiffs assert that “the question here is whether this
place of business,’ especially when ... the corporation is the         Court has jurisdiction to enforce an agreement regarding
defendant.” Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Cir.          depositions against a party over whom the Court clearly has
1979) (quoting 8 Charles Wright & Arthur R. Miller, Federal            jurisdiction” (Dkt. #118 at p. 4). Further, “Plaintiffs request
Practice and Procedure § 2112 (1970)).                                 the Court order Toyota to abide by its Agreement” (Dkt. #118
                                                                       at p. 4).
Here, Plaintiffs seek to depose “two TMC employees who
played central roles in Toyota's investigation” (Dkt. #100 at           *4 Toyota “disputes that the Agreement extends to
p. 2). Plaintiffs concede, however, that the witnesses are non-        production of individual fact witnesses,” and “the Court need
                                                                       not resolve the question of scope to resolve this motion—
party fact witnesses (see Dkt. #100 at p. 14).4 Further, no
                                                                       it need only ascertain whether ‘good cause’ is shown on the
dispute exists that the Deponents are citizens of and reside in
                                                                       record” (Dkt. #119 at p. 3). Put another way: “the scope [of
Japan—over 6,000 miles from Texas.
                                                                       the Agreement] is irrelevant since the Agreement, even if
                                                                       applicable, would by its own terms excuse, upon a showing of
“When a potential deponent is not a citizen of the United
                                                                       good cause, any obligation to produce the foreign witnesses
States, the deponent may appear voluntarily or when
                                                                       during the pandemic” (Dkt. #119 at p. 3).
compelled through the appropriate international means of
obtaining discovery.” Rubaroc, USA, Inc. v. RubCorp, L.L.C.,
No. 4:19-cv-080-SDJ, 2019 WL 7905457, at *2 (Nov.


                 © 2021 Thomson Reuters. No claim to original U.S. Government Works.                                               3
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Plaintiffs classify the Agreement as one formed pursuant to         Japan following conclusion of the depositions. While the
                                      6
Texas Rule of Civil Procedure 11. However, Toyota does              number of positive COVID-19 cases necessarily fluctuate
not appear to contest the validity of the Agreement—rather,         as vaccines become available and people recover, the week
Toyota disputes the scope. The Court will therefore begin by        of April 19, 2021 alone saw 5,733,169 confirmed cases
considering whether, assuming the Agreement is valid and            globally. See World Health Organization, WHO Coronavirus
enforceable as to the Deponents, good cause exists to modify        (COVID-19) Dashboard, https://covid19.who.int/ (updated
the Agreement.                                                      April 28, 2021). That is an increase of 457,415 cases
                                                                    from the week before. See WHO Coronavirus (COVID-19)
On approximately April 25, 2018, the parties entered into an        Dashboard. The climbing infection rate, coupled with the
agreement that modified discovery and service obligations           emergency declaration reimposed by the Deponents home
(see Dkt. #110, Exhibit 3). Specifically, the Agreement stated      country of Japan, support a finding that good cause exists to
that “in the spirit of cooperation, TMC would be willing,           modify the Agreement.
for purposes of this action only, to forego the formalities
of the Hague Service Convention and voluntarily appear in            *5 Further, Plaintiffs have not exhausted all their options
exchange for Plaintiffs’ agreement to the following terms           to attempt to obtain the information sought by the
and conditions regarding deadlines and discovery in this            Deponents. Plaintiffs claim that the “Deponents possess
action” (Dkt. #110, Exhibit 3 at p. 2). Of particular relevance,    unique information” that “will inform class certification and
Plaintiffs agreed that “[a]ny TMC deposition [would] be             expert proceedings” (Dkt. #100 at p. 5, 8). Plaintiffs also
scheduled with at least 60 days’ written notice, and any TMS        contend that “the only relevant question is whether there
and/or TMNA deposition [would] be scheduled with at least           exists less burdensome means of securing their testimony, or
30 days’ written notice” (Dkt. #110, Exhibit 3 at p. 2). Further,   an adequate substitute therefore, which does not necessitate
Plaintiffs agreed that “[a]ny such deposition [would] occur in      international travel” (Dkt. #100 at p. 13). Plaintiffs assert that
the Dallas/Plano area at a location of TMC's, TMS’ and/or           such does not exist, yet they have not attempted other means
TMNA's choosing” (Dkt. #110, Exhibit 3 at p. 2). Both parties       not involving the Deponents.
expressly “reserve[d] all of their respective rights to serve and
object to discovery requests[,]” and the right “to seek relief      Considering the growing concern over the state of the
from the Court, on a showing of good cause, to modify [the]         pandemic, and the declarations submitted by the Deponents,
agreement” (Dkt. #110, Exhibit 3 at p. 2).                          the Court finds that lesser alternatives presently exist for
                                                                    Plaintiffs to garner the information sought. Notably, Toyota
The issue before the Court does not involve a desire for            has offered two U.S.-based witnesses, Brad Wyatt (“Wyatt”)
in-person depositions—as has previously been discussed by           and Richard Yamashita (“Yamashita”), for deposition by
district courts and likely was the intent of the parties in 2018.   Plaintiffs. Toyota asserts that Wyatt and Yamashita have the
Rather, the issue revolves around the safety of non-citizen,        same, or more, information sought by the Deponents. Further,
non-party witnesses in traveling out of, and back into, Japan.      the Deponents expressly disclaimed having knowledge on the
Of particular concern, Japan reimposed a state of emergency         particular topics Plaintiffs wish to explore (see Dkt. #110,
—effective April 25, 2021—for Tokyo, Osaka, Hyogo, and              Exhibit 9); (see also Dkt. #110, Exhibit 10). To that effect,
Kyoto prefectures. See U.S. Embassy & Consulates in Japan,          Kamo asserts that “the U.S.-based employees were more
COVID-19 Information, https://jp.usembassy.gov/covid-19-            involved in the investigation” into Prius windshields from
                                                                    2016 through 2017 (Dkt. #110, Exhibit 9 at p. 1). Yamashita
information/ (updated April 27, 2021).7 Further, travel is
                                                                    claims that he cannot answer the questions Plaintiffs desire to
still restricted, and Japan is taking severe precautionary
                                                                    ask (Dkt. #110, Exhibit 10 at p. 2).
measures to ensure that COVID-19 does not further spread
into the country. See Japan, Coronavirus (COVID-19)
                                                                    Plaintiffs’ argument that Rule 30(b)(6) depositions of U.S.-
Adivisory        Information,   https://www.japan.travel/en/
                                                                    based employees will not “satisfy Plaintiffs’ needs” because
coronavirus/#measures_government (updated April 28,
                                                                    “Plaintiffs do not seek to examine the Deponents concerning
2021). While Plaintiffs seek remote depositions, which do
                                                                    Toyota's policies, procedures, or institutional knowledge”
limit the physical contact that individuals have with one
                                                                    is, at present, unpersuasive. Plaintiffs claim the “personal
another, these depositions cannot occur in Japan. Thus, the
                                                                    experiences” of the Deponents prevent a Rule 30(b)(6)
Deponents will have to travel to either a non-U.S. country
                                                                    deposition from being effective, but yet the Deponents have
or Hawaii. The Deponents will then have to travel back to


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disclaimed that personal experience. While the Court does           Plaintiffs to try other discovery methods while the pandemic
not attempt to determine the credibility of the Deponents, it       is still a significant concern to [Deponents]” (Dkt. #119 at p.
still takes into account their declarations and the statements      6) (emphasis added).
contained therein. Those declarations, combined with the
current state of the COVID-19 pandemic, support requiring           Considering all circumstances described above, the Court
Plaintiffs to seek the desired information elsewhere before         finds good cause to modify the Agreement. The Deponents
compelling the Deponents to fly to either the United States or      will therefore not be required to sit for a remote deposition
another country in order to sit for a remote deposition.            until other means of discovery have been utilized and are
                                                                    found to be ineffective. Inherent in the Court's ruling is,
“The legal system must persevere while taking into account          upon that later showing of ineffectiveness of other discovery
the health and safety of all those made part of the process.”       means, Plaintiffs may again seek an order compelling the
Gonzelez v. Irontiger Logistics, No., 2020 WL 6218560,              Deponents to travel and sit for depositions.
at *2 (S.D. Tex. Oct. 22, 2020). Delaying the depositions
of the specific Deponents while the pandemic is still
rampant, and escalating, is both prudent and necessary.             CONCLUSION
Importantly, however, discovery will be not halted by the
delay; rather, Plaintiffs have the opportunity to explore the        *6 It is therefore ORDERED that Plaintiffs’ Motion to
same information through other identified witnesses. The            Compel Depositions of Toyota Employees (Dkt. #100) is
Court is not precluding the depositions of the Deponents if         hereby DENIED.
the need arises after other means of discovery have been
exhausted and shown inadequate. In fact, Toyota does not
                                                                    All Citations
appear to seek the extreme remedy of an outright prohibition
of the depositions: “Toyota ... requests this Court ... require     Slip Copy, 2021 WL 1837540


Footnotes
1      “Toyota” collectively refers to Toyota Motor Company (“TMC”), Toyota Motor Sales, U.S.A., Inc. (“TMS”), and Toyota
       Motor North America, Inc. (“TMNA”).
2      Japan is not a country to the Hague Convention on the Taking of Evidence Abroad in Civil and Commercial Matters.
3      See Embassy of Japan in the United States of America, To Attend Deposition Taking by U.S. Counsul, https://
       www.us.emb-japan.go.jp/english/html/travel_and_visa/visa/other-deposition.html.
4      Plaintiffs specifically state that “[o]nly through a live fact-witness deposition, that Plaintiffs expect to take remotely, can
       Plaintiffs effectively examine the deponents” (Dkt. #100 at p. 14).
5      The Court assumes without deciding that Plaintiffs’ argument that “[t]he Agreement supersedes Plaintiffs’ obligation to
       seek international discovery[,]” (Dkt. #118 at p. 3), is meritorious.
6      Plaintiffs further claim that such Rule 11 agreement is enforceable as a “substantive agreement under Fifth Circuit
       precedent” (Dkt. #118 at p. 3) (citing Condit Chem. & Grain Co., Inc. v. Helena Chem. Corp., 789 F.2d 1101, 1102 (5th
       Cir. 1986)).
7      The state of emergency is set to expire on May 11, 2021, but no guarantees exist that the declaration will not be extended
       further. See COVID-19 Information.


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                                                                                                   Government Works.




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