Fearless Ties 4, LLC v. Johnson, et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 0:25-CV-61354-ARTAU/AUGUSTIN-BIRCH
FEARLESS TIES 4, LLC,
Plaintiff,
v.
BRYAN S. JOHNSON, et al.,
Defendants.
________________________________________/
ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL
This cause comes before the Court on Plaintiff Fearless Ties 4, LLC’s Motion to Compel,
to which Defendants Bryan S. Johnson and Nicholas Koutsodontis responded and Plaintiff
replied.1 DE 45; DE 51; DE 52. The Court has carefully considered the briefing and the record
and is otherwise fully advised in the premises.
The Court set a hearing on the Motion to Compel for January 26, 2026, at 10:30 a.m.
DE 44. However, upon review of the briefing, the Court concludes that a hearing is unnecessary
to resolve the Motion to Compel. The Court therefore CANCELS the January 26 hearing. For
the following reasons, the Motion to Compel [DE 45] is GRANTED.
Plaintiff asks the Court to compel Defendants’ full responses to Request for Production
#’s 2, 3, 6, 8, 12, 13, and 19 and full answers to Interrogatory #’s 4, 5, and 6. 	Defendant
Koutsodontis did not object to Request for Production #’s 2 and 3. 	DE 45-2 at 3. 	Defendant
Johnson’s response to Request for Production # 2 stated that the Request “is objected to on the
1 Defendants failed to respond to the Motion to Compel in a timely manner and then, when they did respond, filed a
response that violates the Court’s three-page limitation for briefing on a discovery motion. See DE 42 at 3; DE 46;
DE 47; DE 51. The parties are advised that failure to follow the Court’s procedures in the future may lead to sanctions.
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grounds that,” but the response then cut off, such that Defendant Johnson did not provide any
ground for objection. Id. at 24. Defendant Johnson did not object to Request for Production # 3.
Id. 	Having failed to provide any grounds for objections, any objections are waived under this
District’s Local Rules, and Defendants must fully respond to Request for Production #’s 2 and 3.
See S.D. Fla. L.R. 26.1(e)(2)(A) (“Any ground not stated in an objection within the time provided
by the Federal Rules of Civil Procedure, or any extensions thereof, shall be waived.”).
Defendants’ objections to the remaining Requests for Production that are at issue (Request
for Production #’s 6, 8, 12, 13, and 19) are wholly boilerplate objections that violate the Local
Rules because they do not state with specificity the grounds for objection. DE 45-2 at 4–5, 7, 25–
26, 28; see S.D. Fla. L.R. 26.1(e)(2)(A) (“Where an objection is made to any interrogatory or
subpart thereof or to any production request under Federal Rule of Civil Procedure 34, the
objection shall state with specificity all grounds.”). To the extent Defendants objected based on
confidentiality, confidentiality alone is not a basis to withhold discovery. 	See Adelman v. Boy
Scouts of Am., 276 F.R.D. 681, 692 (S.D. Fla. 2011) (“It is well settled that there is no absolute
privilege for trade secrets or other confidential information.” (quotation marks omitted)); Kaye v.
Fountaine Pajot, S.A., No. 07-61284-CIV, 2008 WL 11422469, at *3 n.4 (S.D. Fla. Jan. 7, 2008)
(noting that “it is well settled that confidentiality does not act as a bar to discovery and is generally
not grounds to withhold documents from discovery” (quotation marks omitted)). 	If the parties
seek entry of a Confidentiality Order, they must confer on the language of such an Order and move
for its entry. 	Defendants’ objections to Request for Production #’s 6, 8, 12, 13, and 19 are
overruled, and Defendants must fully respond to those Requests.
Defendants objected to Interrogatory #’s 4 and 5 based on irrelevance, overbreadth, and
burdensomeness. DE 45-2 at 11, 32. Those Interrogatories ask for information about Hits Only
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Music Entertainment, LLC’s (“Hits Only”) revenue and intellectual property and are directly
relevant to Plaintiff’s allegations that Defendant misled Plaintiff about Hits Only’s assets in order
to induce Plaintiff to invest in Hits Only. 	E.g., DE 16 ¶¶ 39–50 (allegations in the Amended
Complaint). 	To the extent that Defendants believe the Interrogatories are answered through
documents produced to Plaintiff, Defendants may point Plaintiff to the specific responsive
documents. 	Defendants’ objections to Interrogatory #’s 4 and 5 are overruled, and Defendants
must fully answer those Interrogatories.
Finally, Defendant Koutsodontis’ objections to Interrogatory # 6 are wholly boilerplate
objections that violate the Local Rules because they do not state with specificity the grounds for
objection. 	DE 45-2 at 11; see S.D. Fla. L.R. 26.1(e)(2)(A). 	Defendant Johnson provided some
information to substantiate his overbreadth objection. DE 45-2 at 32. Interrogatory # 6 asks about
agreements regarding music distribution rights and is directly relevant to Plaintiff’s allegations
that Defendants misled Plaintiff about their rights to music in order to induce Plaintiff to invest in
Hits Only. 	E.g., DE 16 ¶¶ 15–16, 40 (allegations in the Amended Complaint). 	Again,
confidentiality alone is not a basis to withhold discovery. Defendants’ objections to Interrogatory
# 6 are overruled, and Defendants must fully answer the Interrogatory.
Accordingly, Plaintiff’s Motion to Compel [DE 45] is GRANTED. 	Defendants must
supplement their responses and answers as required under this Order within 14 days of the date
of this Order.
DONE AND ORDERED in Chambers at Fort Lauderdale, Florida, this 23rd day of
January, 2026.
___________________________________
PANAYOTTA AUGUSTIN-BIRCH
UNITED STATES MAGISTRATE JUDGE
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