United States v. Peters
2:24-cv-00287
E.D. Cal.May 22, 2025Background
- The United States sued Matthew Peters and various pharmacy and management entities, alleging False Claims Act violations, unjust enrichment, and payment by mistake.
- On March 20, 2025, the Court ordered defendant Peters to fully comply with discovery requests, including the production of documents without objection.
- Despite previous court orders and discovery agreements, Peters and the affiliate entities failed to provide adequate responses or produce required documents.
- Plaintiff alleges significant deficiencies in discovery, including selective and incomplete searches, improper withholding, and noncompliance with a prior agreement.
- The Court previously warned Peters that failure to participate in discovery could lead to sanctions, including the possibility of default judgment or contempt.
- The Court heard arguments on May 21, 2025, and found ongoing deficiencies, ordering further compliance, a sworn declaration, supplemental briefing, and set an order to show cause hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Compliance with Discovery Orders | Peters and entities failed to fully respond and produce documents as required | Claimed all available documents were produced; order only applied to Peters individually | Order applied to Peters and entities; must comply fully |
| Adequacy of Document Search | Search was superficial, limited to Peters, not diligent or broad enough | Only Peters had relevant documents; other custodians not reasonable | Search must cover all agreed sources, broader than Peters alone |
| Breach of Discovery Agreement | Defendants breached commitment to conduct diligent, multi-custodian search | Did not agree to all search terms; complied as reasonably possible | Defendants bound by agreement, must comply and expand search |
| Withholding of Documents | Peters withheld responsive documents already produced in other forums | Produced everything available; some documents destroyed | Production incomplete; all responsive documents must be produced |
Key Cases Cited
- Hallett v. Morgan, 296 F.3d 732 (9th Cir. 2002) (trial courts have broad discretion to deny or permit discovery)
- Connecticut Gen. Life Ins. Co. v. New Images of Beverly Hills, 482 F.3d 1091 (9th Cir. 2007) (affirming default judgment as sanction for discovery violations)
- Leon v. IDX Sys. Corp., 464 F.3d 951 (9th Cir. 2006) (discussing sanctions for discovery abuses)
- Olivia v. Sullivan, 958 F.2d 272 (9th Cir. 1992) (sanctions are within court's discretion for discovery violations)
