ABIRA MEDICAL LABORATORIES LLC D/B/A GENESIS DIAGNOSTICS v. UPMC HEALTH PLAN INC.
2:24-cv-00227
| E.D. Pa. | Jun 4, 2025Background
- UPMC Health Plan Inc. and University of Pittsburgh Medical Center moved for sanctions and contempt against Abira Medical Laboratories (Genesis Diagnostics) for failure to comply with discovery orders.
- The Court had previously ordered Plaintiff to correct deficiencies in its interrogatory and production responses by May 1, 2025, and to produce four individuals for deposition between May 7 and 14, 2025.
- Plaintiff did not timely provide corrected discovery responses and delayed depositions, citing logistical difficulties due to a large volume of records from a closed laboratory.
- Defendants argued that Plaintiff's repeated failures and delays warranted sanctions under Federal Rule of Civil Procedure 37(b).
- At a hearing, the Court found Plaintiff's justifications inadequate, but noted the parties later agreed to deposition dates and that Plaintiff eventually provided responses, albeit late.
- The Court granted in part and denied in part the motion: Defendants were awarded attorney’s fees and reasonable expenses for the motion, but more severe sanctions (e.g., default judgment) were denied at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to timely correct discovery responses | Delay due to closed lab and volume of records | Responses were late, inadequate, and unjustified | Not substantially justified; sanctions granted |
| Failure to produce witnesses for deposition | Witnesses unavailable, but parties agreed on new dates | Plaintiff ignored clear court order and set dates | Issue resolved, but further noncompliance may yield more sanctions |
| Appropriateness of default judgment | Plaintiff’s delays not willful or in bad faith | Severe sanction warranted given noncompliance | Default judgment denied as premature |
| Award of attorney’s fees for motion | Plaintiff opposed | Defendants requested as justified and necessary | Attorney’s fees and expenses granted |
Key Cases Cited
- Bowers v. NCAA, 475 F.3d 524 (3d Cir. 2007) (district courts have discretion in imposing Rule 37 discovery sanctions)
- Vallejo v. Santini-Padilla, 607 F.3d 1 (1st Cir. 2010) (upholding sanctions where party delayed and promised to produce documents later)
- Hildebrand v. Allegheny County, 923 F.3d 128 (3d Cir. 2019) (default judgment under Rule 37 is a last resort)