Fruitstone v. Spartan Race Inc., 1:20-cv-20836

Plaintiff Aaron Fruitstone filed a nationwide class action and later amended to add a Massachusetts Chapter 93A claim; Defendant is Spartan Race Inc.
The Court entered a Scheduling Order on April 6, 2020; parties’ Joint Scheduling Report anticipated possible amendment to add Massachusetts law.
Defendant moved to transfer or dismiss and separately moved to stay discovery pending resolution of that Underlying Motion; the Court denied the Underlying Motion on May 28, 2020 (making that stay request moot).
Defendant alternatively sought modification of the Scheduling Order to require phased discovery: Plaintiff-specific discovery first and a stay of class discovery until Plaintiff’s individual claims were resolved.
Spartan argued the Massachusetts claim greatly expanded discovery scope (potentially worldwide) and that resolving individual claims first could avoid burdensome class discovery.
Fruitstone responded that the Massachusetts claim was anticipated, mirrors existing Florida claims, and that the Scheduling Order (agreed to by the parties) already rejected phased discovery; the Court found no good cause to modify the Scheduling Order and denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether discovery should be stayed pending resolution of Defendant's Motion to Transfer or Dismiss	Fruitstone argued this request became moot after the Court denied the Underlying Motion	Spartan sought the stay while the Underlying Motion was pending	Moot — Court had already denied the Underlying Motion, so stay request as to that motion is denied as moot
Whether the Scheduling Order should be modified to require phased discovery and to stay class discovery until Plaintiff’s individual claims are resolved	Fruitstone argued Defendant knew of the potential MA claim, initial complaint already sought nationwide relief, and parties agreed to standard (non-phased) discovery	Spartan argued the MA Chapter 93A claim broadened discovery (potentially worldwide), so phased discovery would avoid unnecessary class discovery and promote efficiency	Denied — Court found no good cause to modify the Scheduling Order; parties had anticipated the MA claim and agreed to the current discovery plan