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Aspen American Insurance v. Landstar Ranger, Inc.
3:24-cv-00721
M.D. Fla.
May 28, 2025
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Background

  • Landstar Ranger, Inc. (Defendant) filed a motion to compel three depositions to occur on June 2, 2025, in a dispute with Aspen American Insurance Company (Plaintiff).
  • Defendant failed to comply with Local Rule 3.01(g), which requires parties to properly confer before filing certain motions.
  • Defendant first sought to coordinate deposition dates only 14 days before the close of discovery, sending a scheduling email on May 19, 2025.
  • Plaintiff noticed its own depositions on June 2, 2025, shortly after Defendant’s email, which caused overlapping/competing scheduling.
  • Defendant then unilaterally noticed depositions for June 2, 2025, on May 22, which did not provide the required 14 days’ notice under Local Rule 3.04.
  • The Court ruled without requiring a response due to the time-sensitive nature but found the motion deficient both procedurally and substantively.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of conferral under Local Rule 3.01(g) Defendant did not properly confer Emails met the conferral requirement Defendant failed to properly confer
Compliance with 14-day notice requirement for depositions Plaintiff’s notices complied with the rule Defendant’s May 22 notice was sufficient as 14 days Defendant’s notice was only 11 days before the deposition; insufficient notice
Scheduling coordination and professional conduct Both parties could have acted professionally Plaintiff did not cooperate in scheduling Defendant’s failure to coordinate did not excuse rule violations
Time sensitivity designation of the motion No specific argument No specific argument Motion not designated time-sensitive, but addressed expeditiously by Court

Key Cases Cited

  • None. (No cases with official reporter citations suitable for bluebook hyperlinking were cited in the opinion.)
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Case Details

Case Name: Aspen American Insurance v. Landstar Ranger, Inc.
Court Name: District Court, M.D. Florida
Date Published: May 28, 2025
Docket Number: 3:24-cv-00721
Court Abbreviation: M.D. Fla.