Lugo v. Concentrix Corporation
- Eric Tostrud
- 0:25-cv-02585
- U.S. District Court · District of Minnesota
- 4
In Lugo v. Concentrix Corporation, Magistrate Judge Docherty denied self-represented plaintiff Emmanuel A. Lugo's motion to compel discovery because Lugo repeatedly violated court rules requiring a good-faith meeting with opposing counsel before filing motions, and warned that future rule violations will result in automatic denial of relief plus a $100 fine payable to Concentrix.
Self-represented (pro se) litigants in the District of Minnesota, particularly those who fail to comply with local rules requiring a genuine meet-and-confer with opposing counsel before filing motions. Also relevant to parties in employment or other civil disputes against corporations who seek to compel discovery.
What happened
In Lugo v. Concentrix Corporation (Case No. 25-cv-2585), self-represented plaintiff Emmanuel A. Lugo filed a motion asking the court to force Concentrix Corporation to provide more information during the pretrial information-sharing process known as discovery. The case is pending in the United States District Court for the District of Minnesota.
The court found that Lugo had a persistent pattern of ignoring court rules, particularly the requirement that parties make a genuine effort to talk through their disagreements with the opposing side before filing any motion. In this instance, Lugo filed his motion before completing that required conversation, filed the necessary supporting documents late, and his eventual 'meet and confer' statement relied only on emails and a meeting that actually concerned a different topic. Concentrix's lawyer certified that the disputed discovery issues were never substantively discussed. The court noted that Lugo may have misrepresented to the court that the required meeting took place, and found his motion also lacked merit on the substance, because the type of detailed information he sought is better requested through formal discovery tools like Requests for Production rather than through complaints about initial required disclosures.
Magistrate Judge John F. Docherty denied the motion and issued a firm warning: going forward, any document Lugo files that violates the Federal Rules of Civil Procedure or the Local Rules of the District of Minnesota will be automatically denied, and Lugo will be ordered to pay Concentrix $100 to compensate for attorney time wasted on improper filings. The court emphasized that self-represented litigants must follow the same rules as attorneys.
The detailed version
- Lugo v. Concentrix Corporation, No. 25-cv-2585 (ECT/JFD)
- Magistrate Judge John F. Docherty
- December 11, 2025
Background and Procedural History Plaintiff Emmanuel A. Lugo, proceeding pro se (representing himself without an attorney), filed a Motion to Compel Discovery on November 26, 2025 (Dkt. No. 65), seeking to require defendant Concentrix Corporation to supplement its initial disclosures made under Federal Rule of Civil Procedure 26(a)(1). Rule 26(a)(1) requires parties to automatically disclose, without being asked, the names and contact information of persons likely to have relevant information, copies of documents the party may use to support its claims or defenses, and any applicable insurance agreements.
Procedural Deficiencies The motion was filed without the supporting documents required by District of Minnesota Local Rule 7.1(b)(1), specifically a Memorandum in Support and a Meet and Confer Statement. Those documents were not filed until December 1, 2025 — eight days before the scheduled December 9 hearing — in violation of the rule requiring simultaneous filing. As a result, the court canceled the hearing, ordered Concentrix to respond by December 8, 2025, and decided the motion on the written record.
Meet and Confer Requirement Local Rule 7.1(a) requires parties to meet and confer — meaning have a genuine, good-faith discussion — with opposing counsel before filing any motion. The court found Lugo had not complied with this requirement. His Meet and Confer Statement referenced only written (email) communications and a September 30, 2025 conference that Concentrix's counsel certified (via a declaration, Dkt. No. 76) was actually about the parties' proposed protective order, not the discovery deficiencies Lugo raised. The court noted that email exchanges are generally insufficient to satisfy the meet-and-confer requirement under Minnesota district court precedent (citing Management Registry, Inc. v. A.W. Companies, Inc., 2019 WL 2024538, and Cattanach v. Burlington N. Santa Fe, LLC, 2014 WL 11429037), and that the court's own practice guidelines state that neither perfunctory conversations nor letter or email campaigns satisfy the rule.
The court stated it was 'likely' that Lugo made 'substantial misrepresentations' to the court to avoid compliance with the meet-and-confer requirement.
Pattern of Rule Violations The court recounted a pattern of prior violations in this same case: (1) admonishment on July 3, 2025 for failing to meet and confer before filing a motion; (2) an order on July 28, 2025 to stop filing documents not permitted by the rules; and (3) multiple prior motions denied for failure to properly meet and confer, even after the court denied Lugo's request to waive that requirement.
Substantive Ruling (in footnote) The court also found the motion substantively without merit. It explained that Rule 26(a)(1) initial disclosures are designed to give parties a baseline understanding of the case, not to compel production of every potentially relevant document or witness. The court stated that the more detailed information Lugo sought would be better pursued through formal discovery devices such as Requests for Production.
Disposition The Motion to Compel Discovery (Dkt. No. 65) was denied.
Sanctions Warning Going Forward The court imposed a prospective sanction framework: for every future filing by Lugo that violates the Federal Rules of Civil Procedure or the Local Rules, (1) the requested relief will be summarily denied, and (2) Lugo will be ordered to pay Concentrix $100 to compensate for attorney time wasted. The court stated it would address Lugo's substantive concerns if he complies with applicable rules.
Reviewer note from the AI+
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