ABN Corporation v. Groupe Pelm International Corporation
3:23-cv-00004
| N.D. Cal. | Jul 15, 2025Background
- This case is pending in the Northern District of California and involves ABN Corporation and others (Plaintiffs) against Groupe PELM International Corporation, Christian Pellegrini, Victoria Brieant, and the Law Office of Victoria E. Brieant (Defendants).
- The litigation was stayed due to the need to resolve a disqualification of counsel issue; the stay was lifted after disqualification, and default was entered against Groupe PELM.
- Defendant Pellegrini, based in Canada, has not yet appeared, and there is a pending Order to Show Cause regarding his default.
- The Brieant Defendants were previously counsel for GP Defendants but are now represented by separate counsel and are not in default.
- The current order resolves several discovery disputes involving requests to compel responses, assertions of privilege, and the effect of default status on discovery duties.
- The court declined to resolve privilege issues or compel discovery against defaulted parties or those whose status remains uncertain, and ordered logistical steps for parties to resolve unresolved discovery issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Canadian/Quebec blocking statutes bar discovery | Defendants are subject to jurisdiction, so U.S. rules apply | Blocking statutes require letters rogatory for discovery | Blocking statutes do not preclude U.S. discovery; argument rejected |
| Compelling discovery from defaulted party (Groupe PELM) | Sought to compel discovery | Party in default; not required to respond | Denied; defaulted parties are treated as non-parties |
| Compelling discovery from Pellegrini (not yet appeared) | Sought to compel discovery | Not appeared; status uncertain | Denied without prejudice; can be raised if he appears |
| Compelling Brieant Defendants to provide verifications/logs | Sought compliance, questioned privilege log | Claimed attorney-client privilege applies | Brieant must promptly provide verifications; privilege issues stayed |
| Removing confidentiality/designation on witness | N/A | Sought to remove confidentiality | Denied as defendant is in default |
| Compelling discovery from Williams (plaintiff's counsel) | N/A | Sought to compel further responses | Denied as defendant is in default |
Key Cases Cited
- Jules Jordan Video, Inc. v. 144942 Canada Inc., 617 F.3d 1146 (9th Cir. 2010) (Defaulted parties are treated as non-parties for discovery purposes)
