Alley v. MTD Products, Inc.

When Plaintiff inflated his snow-blower tire, the rim exploded, injuring Plaintiff’s hand. After $6,000 in medical bills, Plaintiff sued the Defendants for $100,000 in damages. Defendants produced information from prior cases involving the same model, including the claimants’ and attorneys’ names and where the cases were filed. Defendants’ counsel said most of those lawsuits involved similar injuries from exploding tire rims. Defendants also produced product recall records that showed knowledge of the defect. Plaintiff’s attorney nonetheless asked Defendants to produce all documents from the prior lawsuits, including expert reports, deposition transcripts, and discovery. Plaintiff’s attorney also filed a Rule 30(b)(6) notice to depose Defendants’ records custodians, seeking their identities, and to question them about nine listed topics about Defendants’ document storage and retrieval systems. Defendants requested a protective order to prevent the additional discovery and submitted an affidavit from its national discovery counsel explaining that the costs would likely exceed $100,000. Plaintiff’s attorney countered that he needed the additional discovery to prove Defendants’ knowledge and recover punitive damages and that its production would not unduly burden Defendants.