Motion-Secondary: Boger Ronald Vs Ideavillage Products Corp

On September 16, 2022 a Motion-Secondary was filed involving a dispute between Ronald Boger, and Anand Khubani, Donald Beshada, Esquire, Ideavillage Productscorp, for Complex Commercial in the District Court of Passaic County.

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FERRARA LAW GROUP, P.C.
Ralph P. Ferrara, Esquire (ID #024521985)
Kevin J. Kotch (ID #050341993)
1 Holtec Drive, Suite G102
Marlton, NJ 08053
P: (609) 571-3738
F: (609) 498-7440
Attorneys for Plaintiff

RONALD BOGER,
SUPERIOR COURT OF NEW JERSEY
Plaintiff, LAW DIVISION

v.
PASSAIC COUNTY
IDEAVILLAGE PRODUCTS CORP.,
ANAND KHUBANI and DONALD DOCKET NO. PAS-L-002323-22
BESHADA,

Defendants. OPPOSITION TO MOTION FOR
RECONSDERATION AND MOTION FOR
PROTECTIVE ORDER

Plaintiff Ronald Boger provides the following opposition to the Motion for

Reconsideration of this Court’s order compelling discovery filed by IdeaVillage Products Corp.

and Anand Khubani as well as to the Motion for Protective Order filed by Donald Beshada.

FACTUAL BACKGROUND

On January 19, 2024, this Court granted Plaintiff Boger filed his cross-motion to compel

discovery. More specifically, the Court ordered that Khubani and IdeaVillage: (1) “shall produce

communications between them pursuant to Document Request Nos. 5 and 9”; (2) “shall provide

a full and complete response to Interrogatory Nos. 5, 10, 11 and 12 and shall not simply refer to

documents”; and (3) “shall provide full and complete responses to Interrogatory Nos. 3 and 4....”

Jan. 19, 2024 Order (Exhibit A, hereto). This Court went on to state:

In New Jersey, it is “well-established principle that requests for discovery are to be
liberally construed and accorded the broadest possible latitude to ensure that the
ultimate outcome of litigation and will depend on the merits in light of the available
facts.” Piniero v. Div. of State Police, 404 N.J. Super. 194, 204 (App. Div. 2008).
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The requests are relevant and the Plaintiff is entitled to complete responses.

The parties shall attempt to amicably resolve discovery disputes in the future.

Jan. 19, 2024 Order (Exhibit A, hereto).

Defendants Khubani and IdeaVillage filed the instant motion for reconsideration primarily

on the paragraph involving the attorney-client privilege issue and then threw in the rest of the

Order at the end of their brief. Defendants did not “attempt to amicably resolve discovery

disputes....”; they filed their motion.

Defendant Beshada filed a motion for protective order that he need not produce documents

or information exchanged between Beshada and Khubai.

On February 7, 2024, the Court sua sponte entered the following order:

WHEREAS, the Court did not intend to compel the production of
documents and/or communications that are protected by the attorney/client
privilege and has not ruled upon same; and for good cause

* * *

ORDERED that Paragraph 2 of the Court’s Order dated January 19, 2024,
compelling the Defendants Khubani and Idea Village to « .. produce
communications between them pursuant to Document Request No. 5 and 9” is
hereby vacated; and it is further

ORDERED that all other paragraphs of the aforementioned Order shall
remain in full force and effect; and

ORDERED that any issues related to communications between the
Defendant, Beshada and any client and/or former client may be argued further in
the Motion for Reconsideration filed by the Defendants and/or the Motion for a
Protective Order filed by the Defendant, Donald
Beshada

February 7, 2024 Order (Exhibit B, hereto).
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STANDARD OR REVIEW

The Court may grant a motion for reconsideration of an interlocutory order only upon its

sound discretion and when it is in the interests of justice. R. 4:42-2; see Lawson v. Dewar, 468

N.J. Super. 128, 134 (App. Div. 2021). While this standard is lesser than that applied to a final

order, it is not an invitation to rebrief an issue only after defeat. The courts are wary of new

arguments on a motion for reconsideration, which could lead to an endless series of motions for

reconsideration trying new argument each time. See Medina v. Pitta, 442 N.J. Super. 1, 18 (App.

Div. 2015) (“Filing a motion for reconsideration does not provide the litigant with an opportunity

to raise new legal issues that were not presented to the court in the underlying motion.”). It is well-

settled that reconsideration “is not appropriate merely because a litigant is dissatisfied with a

decision of the court or wishes to reargue a motion.” Palombi v. Palombi, 414 N.J. Super. 274, 288

(App. Div. 2010).

ARGUMENT

I The Attorney-Client Privilege Issue.

There is no privilege (as between the parties) where they are both represented by the same

attorney. See Pinnacle Surety Services, Inc. v. Manion Stigger, LLP, 370 F. Supp. 3d 745, 751

(W.D. Ky. 2019) (“The attorney-client privilege does not shield communications between one

client and counsel from the other joint clients.”). In a dispute between them, there is no attorney-

client privilege for communications between them and their attorney. F.D.I.C. v. Ogden Corp.,

202 F.3d 454, 461 (1* Cir. 2000). These matters are still privileged via-a-vis the rest of the world,

which can be protected via a discovery protective order such as we have in this case. Id.
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Plaintiff has alleged that Donald Beshada, Esquire was representing both Anand Khubani

and Ronald Boger in the negotiation of Boger’s agreement with Khubani and Idea Village. Under

these circumstances, there is no privilege. The ABA had noted:

With regard to the attorney-client privilege, the prevailing rule is that, as between
commonly represented clients, the privilege does not attach. Hence, it must_be
assumed that if litigation eventuates between the clients, the privilege will not
protect any such communications, and the clients should be so advised.

ABA, Rule 1.7 Conflict of Interest: Current Clients - Comment § 30 (emphasis added). The

Commentary goes on to note that:

As to the duty of confidentiality, continued common representation will almost
certainly be inadequate if one client asks the lawyer not to disclose to the other
client information relevant to the common representation. This is so because the
lawyer has an equal duty of loyalty to each client, and each client has the right to
be informed of anything bearing on the representation that might affect that client's
interests and the right to expect that the lawyer will use that information to that
client's benefit.

Id. 31. Although Khubani has argued that “the Court is not bound to follow the comments

accompanying each of the rules,” the bookends of the quote offer something quite different:

[T]he Court has recognized that for assistance in interpreting these rules, reference
should be made to the ABA comments. Accordingly, while the Court is not bound
to follow the comments accompanying each of the rules, they do agree that they
should be considered in interpreting RPC 4.2.

In re Environmental Ins. Declaratory Judgment Action, 252 N.J. Super. 510, 517 (Law Div. 1991)

(emphasis supplied). They have offered no material changes to Rule 1.7, or reasons why the

comments should not be followed. As Beshada was representing both Khubani and Boger,

Plaintiff has a right to have access to the communications between Khubani and Beshada relating

to the agreement and the arbitration provision.

This is the crux of the dispute. Plaintiff contends that Beshada represented him and

Khubani in connection with the negotiation of the agreement. IdeaVillage says not. This must be
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decided before we can address the arbitration provision. If Plaintiff is correct, then Plaintiff is

entitled to the production from Khubani/IdeaVillage and also Beshada.

The discovery sought goes directly to the enforceability of the arbitration provision. In

Document Request No. 5 and 9 to Khubani and IdeaVillage, Plaintiff sought communications

between defendants Khubani and Donald Beshada, including about the “drafts of agreements

and/or agreement” (No. 5) and “the arbitration provision in the 2019 Agreement” (No. 9). The

document requests to Beshada contain similar requests. Response to Document Requests to

Beshada Nos. 5, 9 (Fiteni Certification, Exh. 3). The interrogatories to Beshada also request details

of conversations he had with Khubani regarding the agreement and the arbitration provision.

Response to Interrogatory Nos. 16, 17, 18 (Fiteni Certification, Exh. 3) Responses to these

requests will show the progress of the negotiations and the state of mind of Beshada (was he aware

that Boger was relying on him, etc.).

Protective Order, There is a protective order in place to address IdeaVillage/Khubani’s

and Beshada’s concerns.

Privilege Log. At the very least, IdeaVillage/Khubani and Beshada have to provide a

privilege log setting forth the documents responsive to these requests.

Il. The Remainder Of Arguments In IdeaVillage And Khubani’s Brief.

IdeaVillage and Khubani suggest in a page that the Court should grant reconsideration of

the remainder of the January 19, 2024 Order. This is simply an attempt at a second bite of the

apple. In this Court’s February 7, 2024 Order, this Court said that “all other paragraphs of the

aforementioned [January 19, 2024] Order shall remain in full force and effect...” Feb. 7, 2024

Order (Exhibit B, hereto). To the extent any reply is warranted, Plaintiff incorporates by reference
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pages 5 through 7 in Plaintiff's Memorandum of Law in Opposition to Motion to Compel and in

Support of Cross-Motion to Compel, filed January 11, 2024. Exhibit C, hereto.

CONCLUSION

For the reasons set forth above, Plaintiff should be entitled to the production of

communications between IdeaVillage/Khubani and Beshada.

FERRARA LAW GROUP, P.C.

BY:_/s/ Ralph P. Ferrara
RALPH P. FERRARA, ESQUIRE
Attorney for Plaintiff
Dated: February 8, 2024
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Exhibit A
PAS-L-002323-22 02/08/2024 3:48:56 PM Pg2of3 Trans ID: LCV2024357917
PAS-L-002323-22 01/19/2024 Pg1of2 Trans ID: LCV2024166614

RONALD BOGER,
SUPERIOR COURT OF NEW JERSEY
Plaintiff, LAW DIVISION

¥.
PASSAIC COUNTY
IDEAVILLAGE PRODUCTS CORP.,
ANAND KHUBANI and DONALD DOCKET NO. PAS-L-002322-22
BESHADA,
Defendants. ORDER

AND NOW, this 19th day of January, 2024, upon consideration of Plaintiff Ronald

Boger for Cross-Motion to Compel, and the Court having considered the submissions of the

parties, as well as any oral argument from counsel for the parties; and for good cause shown;

a It is hereby ORDERED that Plaintiff's Cross-Motion to Compel is GRANTED;

and

(2) It is further ORDERED that the Defendant Khubani and IdeaVillage shall produce

communications between them pursuant to Document Request Nos. 5 and 9; and

(3) It is further ORDERED that the Defendant Khubani and IdeaVillage shall provide

a full and complete response to Interrogatory Nos. 5, 10, 11 and 12 and shall not simply refer to

documents; and

(4) It is further ORDERED that the Defendant Khubani and IdeaVillage shall provide

full and complete responses to Interrogatory Nos. 3 and 4; and
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PAS-L-002323-22 01/19/2024 Pg2of2 Trans ID: LCV2024166614

6) It is further ORDERED that a copy of this ORDER shall be served on all parties

within seven (7) days of the date hereof.

/s/ Darren J. Del Sardo
HON. DARREN J. DEL SARDO, P. J. Cv.

OPPOSED

In New Jersey, it is “well-established principle that requests for discovery are to be
liberally construed and accorded the broadest possible latitude to ensure that the ultimate
outcome of litigation will depend on the merits in light of the available facts.” Piniero v. Div. of
State Police, 404 N.J. Super. 194, 204 (App. Div. 2008).

The requests are relevant and the Plaintiff is entitled to complete responses.

The parties shall attempt to amicably resolve discovery disputes in the future.
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Exhibit B
PAS-L-002323-22 02/08/2024 3:48:56 PM Pg2of3 Trans ID: LCV2024357917
PAS-L-002323-22 02/07/2024 Pg 1of2 Trans ID: LCV2024341827

PREPARED BY THE COURT

RONALD BOGER SUPERIOR COURT OF NEW JERSEY

Plaintiff,
PASSAIC COUNTY: LAW DIVISION

Vv.
DOCKET NO.: PAS-L- 2323-22
IDEA VILLAGE PRODUCTS CORP.,
et al.
CIVIL ACTION
Defendant.
ORDER

THIS MATTER, having been opened by the Court to Amend the Order previously

entered on January 19, 2024 (bearing Transaction ID Number LCV2024166614) relative to the

Cross Motion to Compel Discovery filed by the Plaintiff;

WHEREAS, the Court entered an Order dated January 19, 2024, compelling the

Defendants Khubani and Idea Village to “...produce communications between them pursuant to

Document Request No. 5 and 9”; and

WHEREAS, Document Requests No. 5 seeks “All communications between Khubani

and Donald Beshada, Esquire regarding drafts of agreements and/or agreements”; and

WHEREAS, Document Request No. 9 requests “All communications between Khubani

and Donald Beshada, Esquire regarding the arbitration provision in the 2019 Agreement”; and

WHEREAS, the Court did not intend to compel the production of documents and/or

communications that are protected by the attorney/client privilege and has not ruled upon same;

and for good cause
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PAS-L-002323-22 02/07/2024 Pg2of2 Trans ID: LCV2024341827

IT IS on this 7th day of February, 2024;

ORDERED that Paragraph 2 of the Court’s Order dated January 19, 2024, compelling

the Defendants Khubani and Idea Village to “...produce communications between them pursuant

to Document Request No. 5 and 9” is hereby vacated; and it is further

ORDERED that all other paragraphs of the aforementioned Order shall remain in full

force and effect; and

ORDERED that any issues related to communications between the Defendant, Beshada

and any client and/or former client may be argued further in the Motion for Reconsideration filed

by the Defendants and/or the Motion for a Protective Order filed by the Defendant, Donald

Beshada; and it is further

ORDERED that a copy of the within Order shall be deemed served upon all parties upon

upload onto eCourts.

/s/ Darren J. Del Sardo

HON. DARREN J. DEL SARDO, P. J. Cv.
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Exhibit C
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RONALD BOGER,
SUPERIOR COURT OF NEW JERSEY
Plaintiff, LAW DIVISION

Vv.
PASSAIC COUNTY
IDEAVILLAGE PRODUCTS CORP.,
ANAND KHUBANI, and DONALD DOCKET NO. PAS-L-002323-22
BESHADA,

Defendants. MEMORANDUM OF LAW IN
OPPOSITION TO MOTION TO COMPEL
AND IN SUPPORT OF CROSS-MOTION
TO COMPEL

Plaintiff Ronald Boger submits this Memorandum of Law in Opposition to the Motion to

Compel filed by Defendants IdeaVillage Products Corp. and Anand Khubani and in support of

his Cross-Motion to Compel Discovery.

FACTUAL BACKGROUND

Defendants’ motion to compel is an attempt to stall discovery. Plaintiff, on two separate

occasions, noticed Defendants depositions. On each occasion, Defendants failed to respond and

then, when pressed, responded that they were not available.

Defendants request for production and interrogatories go well beyond the limitation that

discovery should be about the arbitration provision. They take the position that everything about

Boger is somehow related to this one provision. Their follow up letters echo this broad

interpretation of discovery. They offer a broad shotgun approach; there is no understanding

about what is really important and really relevant to the inquiry now before the Court.

Notwithstanding, Plaintiff has produced all of the documents he has and has supplemented his

1
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interrogatory responses. Certification of Ralph P. Ferrara, Esquire (“Ferrara Cert.”), Exhs. A, B.

Defendants’ motion is moot.

Plaintiff served interrogatories and document requests on Defendants. Defendants

responded. Ferrara Cert., Exhs. C, D. Interestingly, the documents produced by Defendants

included agreements negotiated by Boger, none of which contained_an_ arbitration provision.

Plaintiff wrote that their responses were deficient. Ferrara Cert., Exh. E. Defendants responded

with little additional information and simply to say Plaintiff was wrong. Ferrara Cert., Exh. F.

Plaintiff files this cross-motion seeking further responses to interrogatories and document

requests.

LEGAL ARGUMENT

I Defendants’ Motion To Compel Responses To Document Request Is Moot.

When Plaintiff left his employment at Ideavillage, he left reams of files related to his

work there. He did not take them (or copies of them). He was retiring. Defendants express

shock that he only has 19 pages of documents relevant to this dispute. They shouldn’t be. The

documents were Ideavillage’s and he would have no further use of them. He left them at his

employer — Defendant Ideavillage. Plaintiff produced all of the documents that he has. He has

no more. Plaintiff has amended his responses to the document requests to reflect this. As such,

Defendants’ motion to compel the production of document is moot.

Il. Defendants’ Motion To Compel Interrogatory Responses.

Defendant uses a shot gun approach to discovery. They have propounded interrogatories

well beyond the scope of the discovery which is limited to the arbitration provision in the 2019

Compensation Agreement. And then they insist that every detail, however insignificant, be

responded to. Plaintiff will address the interrogatories highlighted in Defendant’s motion.
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Interrogatories Nos. 8 & 9: Plaintiff's answers fail to provide the requested information
regarding any person with purported knowledge related to the 2019 Compensation.
Agreement.

Plaintiff identified himself and his wife Jolene Boger and put their knowledge.

Interrogatory Nos. 10 & 12: Plaintiff's answers fail to identify his job duties and
reporting relationships during his employment with IdeaVillage.

Plaintiff has amended his response to include an extensive listing of his responsibilities

which should more than satisfy the request.

Interrogatory No. 13: Plaintiff's answer fails to identify the written or verbal agreements
he negotiated and/or executed on behalf of IdeaVillage.

Defendants requests a listing of each and every agreement he negotiated on behalf of

IdeaVillage. This goes well beyond the limited discovery at issue here, which is related to the

arbitration provision in the agreement. Notwithstanding this objection, Plaintiff noted that he

was involved in numerous oral and written agreements, identified those agreements produced by

Defendants and noted that Don Beshada was involved also. This more than satisfies this request.

Interrogatory No. 16: Plaintiff's answer fails to identify the law firm and address of the
attorney that Plaintiff retained regarding the negotiation of the 2019 Compensation
Agreement.

Plaintiff identified the attorney by name. The attorney was a neighbor.

Interrogatory Nos. 18 & 19: Plaintiff's answers fail to provide requested information
regarding any person present during conversations and/or negotiations regarding the 2019
Compensation Agreement.

Plaintiff has identified the individuals involved and has incorporated the portion of the

complaint, where the details were set out. This is more than sufficient.

Interrogatory Nos. 21 & 22: Plaintiff's answers fail to state whether Plaintiff was aware
that Donald Beshada, Esq. represented IdeaVillage in negotiation of the 2019
Compensation Agreement and/or whether Mr. Beshada ever made any representations to
Plaintiff regarding the existence of an attorney-client relationship.

Plaintiff has set forth the representations and actions of Donald Beshada.
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Interrogatory No. 23: Plaintiffs answer fails to identify any alleged statements against
interests made by Defendants or their current or former employees.

Plaintiff stands on his original response. Plaintiff responded, after objections, that

“Plaintiff was told by Beshada that when Plaintiff spoke to Khubani at the Breakers, Khubani

was stepping away and secretly calling Beshada for advice.” No further response is required.

Interrogatory Nos. 25 & 26: Plaintiff's answers fail to identify any facts supporting or
refuting his contentions that (1) he is not a sophisticated business person and (2) he did
not have equal bargaining power to IdeaVillage in connection with the negotiations of the
2019 Compensation Agreement.

Plaintiff has objected to these requests. Plaintiff has also, like Defendants, identified the

documents produced including those produced by Defendants. By way of example, Defendants

produced a number of agreements that Plaintiff had worked on, none of which contain an

arbitration provision.

Interrogatory No. 29: Plaintiff's answer fails to identify all computers and other
electronic devices used by Plaintiff since he began working for IdeaVillage.

Plaintiff stands by his original response. Plaintiff responded that in 2019, when the

agreement at issue was reached including the arbitration provision, he used a corporate laptop

and server storage. Defendants request goes well beyond the limited discovery permitted.

Interrogatory Nos. 30-32: Plaintiff's answers fail to provide the requested information
regarding the e-mail addresses, e-mail accounts, and/or social media accounts used by
Plaintiff between the start of his employment with IdeaVillage and present.

Plaintiff has identified the email addresses which he used and his social media user name.

This responds to the objections made.
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Il. Cross-Motion To Compel Responses To Document Requests And Interrogatories.

A Documents Between Khubani and Beshada

In Document Request Nos. 5 and 9, Plaintiff sought communications between defendants

Anand Khubani and Donald Beshada. More specifically, Plaintiff sought communications

“regarding the drafts of agreements and/or agreement” and the “arbitration provision in the 2019

Agreement.” Plaintiff has alleged that Donald Beshada, Esquire was representing both Anand

Khubani and Ronald Boger in the negotiation of Boger’s agreement with Khubani and Idea

Village. Under these circumstances, there is no privilege.

The ABA had noted:

With regard to the attorney-client privilege, the prevailing rule is that, as between
commonly represented clients, the privilege does not attach. Hence, it must be
assumed that if litigation eventuates between the clients, the privilege will not
protect any such communications, and the clients should be so advised.

ABA, Rule 1.7 Conflict of Interest: Current Clients - Comment {| 30. The Commentary goes on

to note that:

As to the duty of confidentiality, continued common representation will almost
certainly be inadequate if one client asks the lawyer not to disclose to the other
client information relevant to the common representation. This is so because the
lawyer has an equal duty of loyalty to each client, and each client has the right to
be informed of anything bearing on the representation that might affect that
client's interests and the right to expect that the lawyer will use that information to
that client's benefit.

Id. § 31. As Beshada was representing both Khubani and Boger, Plaintiff has a right to have

access to the communications between Khubani and Beshada relating to the agreement and the

arbitration provision.

B Defendants Reliance On “See Documents” Is Unfounded.

In Interrogatory No. 5, 10, 11 and 12, Defendants provided the non-responsive “see all

documents.” Defendants’ response to Interrogatory No. 5 is “see all documents produced by
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Defendants in response to Plaintiff's Demand for the Production of Documents.” Plaintiff's

interrogatories 10, 11 and 12 seek facts that support their contention that “Boger was a

sophisticated businessperson”, “had experience in contracting, especially with arbitration

provisions” and that “Boger and Khubani had an equality of bargaining power.” Plaintiff's

Interrogatories 10, 11, and 12 (Ferrara Cert, Exh. D). Defendants’ response to Interrogatory Nos.

10, 11 and 12 states:

Defendants refer to the documents previously produced in this matter and
appended to various courts submissions. Defendants reserve the right to rely
upon all pleadings, documents, depositions transcripts, and other discovery
produced by any party or third party. Answering further, and subject to the
foregoing objections, see all documents produced by Defendants.

Defendants may not simply point Plaintiff to the entire production of documents and other

documents and claim that there might be something in there somewhere. R. 4:17-4(d).

Defendants may only designate documents only where the effort in discerning an answer

is equally upon either side. For example, where there is a question about how many widgets a

company sold in a particular year. A responding party can point the other party to their

document production where they produce documents for sales of all products for a particular

year. From these documents, either side can determine the number of widgets sold. Plaintiff's

interrogatories do not seek an objective fact (sales of widgets), but instead seeks a subjective

interpretation of the facts (e.g., facts that support their contention that Plaintiff was sophisticated

businessperson). This is not something that is apparent from reviewing the documents; it is

something that comes from Defendants’ mind. Therefore, Defendants’ response to see

documents produced is non-responsivie.
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Cc. Other Interrogatory Responses.

Interrogatory No. 3,4

In Interrogatory No. 3, 4, Plaintiff sought information regarding admissions and

declarations against interest. Defendants replied that you were not aware of any “other than

those made by Plaintiff throughout the pendency of this litigation.” This non-response is

insufficient. Defendant must provide a list of the admission and declarations against interest that

Defendants believe were made by Plaintiff throughout the pendency of this litigation.

CONCLUSION

For the reasons set forth above, this Court should deny Defendants’ Motion to Compel

and grant Plaintiff's Cross-Motion to Compel.

FERRARA LAW GROUP, P.C.

BY:_/s/ Ralph P. Ferrara
RALPH P. FERRARA, ESQUIRE
Attorney for Plaintiff
Dated: January 11, 2024

Case Info

Judge

DARREN J DELSARDO Track Judge’s New Case

Case No.

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Document Filed Date

February 08, 2024

Case Filing Date

September 16, 2022

County

Parties

Anand Khubani Defendant
Christine A Amalfe Attorney for the Defendant
Donald Beshada, Esquire Defendant
Ideavillage Productscorp Defendant
Jason Andrew Meisner Attorney for the Defendant
Joseph P Fiteni Attorney for the Defendant
Joshua Allen Zielinski Attorney for the Plaintiff
Ralph Peter Ferrara Attorney for the Plaintiff
Ronald Boger Plaintiff
THOMAS SCRIVO Attorney
MICHAEL BURKE Attorneys for Defendants
PATRICK JENNINGS Attorneys for Defendants
William Patrick Attorney
Kristin Jones Attorney
John Lamb Attorney
JARED DRILL Attorney

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Motion-Secondary: Boger Ronald Vs Ideavillage Products Corp

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