Sharon Hoffman v. Goli Nutrition, Inc.
2:23-cv-06597
| C.D. Cal. | Aug 25, 2025Background
- Plaintiffs (Sharon and Odelya Hoffman, RGL Holdings, RGL Management, and Vitamin Friends) sued multiple defendants including Goli entities, VMG defendants, MeriCal, and DLA Piper asserting eight claims, including a DTSA claim by Vitamin Friends.
- After motions to dismiss, the remaining claims included Vitamin Friends’ DTSA claim against Goli, VMG, and MeriCal, and malpractice/fee-related claims against DLA Piper.
- VMG defendants moved to bifurcate discovery to first resolve whether Vitamin Friends owns the alleged trade secrets (a threshold issue for DTSA standing).
- VMG argued ownership is dispositive of standing, bifurcation would conserve resources and not prejudice plaintiffs; plaintiffs opposed as unnecessary and prejudicial.
- The Court concluded ownership/standing is a dispositive, discrete issue, that phased discovery promotes judicial economy and only minimally prejudices plaintiffs.
- The Court granted bifurcation limited to Vitamin Friends’ DTSA standing and directed the parties to submit a joint timetable for that discovery by September 2, 2025.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether discovery should be bifurcated to resolve Vitamin Friends’ ownership of trade secrets (DTSA standing) first | Bifurcation unnecessary and prejudicial; would delay unrelated discovery | Ownership is a threshold, dispositive issue; phased discovery conserves resources and limits costs | Granted: Court ordered bifurcated discovery on ownership/standing first |
| Whether bifurcation promotes judicial economy | Opp.: VMG could pursue discovery without bifurcation; no need to narrow discovery | Bifurcation avoids costly merits discovery if standing lacking; limited scope and witnesses | Court: judicial economy favors bifurcation; limited universe of evidence supports phasing |
| Whether bifurcation would unduly prejudice plaintiffs | Bifurcation would block discovery against DLA Piper and impede case progress | Bifurcation limited to DTSA claim; does not foreclose discovery on other claims or DLA Piper | Court: prejudice minimal; bifurcation will not preclude discovery on other claims |
Key Cases Cited
- Ellingson Timber Co. v. Great N. Ry. Co., 424 F.2d 497 (9th Cir.) (Rule 42(b) permits deferring costly discovery by ordering separate proceedings on segregable issues)
- Hirst v. Gertzen, 676 F.2d 1252 (9th Cir.) (favoring resolution of an easier dispositive issue before addressing more difficult questions)
- Drennan v. Md. Cas. Co., 366 F. Supp. 2d 1002 (D. Nev.) (bifurcation appropriate when resolving a single issue could be dispositive of the case)
- Karpenski v. Am. Gen. Life Cos., 916 F. Supp. 2d 1188 (W.D. Wash.) (party seeking bifurcation bears burden to show it will promote judicial economy or avoid prejudice)