ABN Corporation et al v. Groupe Pelm International Corporation et al

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
ABN CORPORATION, et al.,
Plaintiffs,
v.
GROUPE PELM INTERNATIONAL
CORPORATION, et al.,
Defendants.
Case No. 23-cv-00004-RFL
ORDER DENYING MOTION FOR
RELIEF FROM NON-DISPOSITIVE
PRETRIAL ORDER OF
MAGISTRATE JUDGE
Re: Dkt. No. 186
Magistrate Judge Cisneros recently compelled Defendants Victoria Brieant and her law
office (collectively, “Brieant”) to produce certain documents over which they asserted the
attorney-client privilege. (See Dkt. No. 184 (the “MJ Order”).) Brieant now moves to vacate the
MJ Order and requests that the undersigned direct Judge Cisneros to conduct an in camera
review of the documents in question. (See Dkt. No. 186 (the “Motion”).) The Motion is
DENIED.
Brieant’s Role. The record sufficiently supports Judge Cisneros’s determination that the
dominant purpose of Brieant’s retention in the subject transaction was to serve as a business
agent or conduit, rather than to provide legal services. Indeed, Brieant described her retention as
limited to “only two very narrow issues: (1) to verify proof of funds and (2) to facilitate
communications with [counsel for the counterparty] concerning an inspection of the product.”
(See Dkt. No. 165 at 3.) Christian Pelligrini explained in a declaration that he and Brieant agreed
that her “method of verifying a buyer’s funds” would be to “ask[] the buyer’s legal counsel to”
make specified verbal and written representations. (See Dkt. No. 109, Ex. A ¶ 4.) Brieant
submits no evidence indicating that she was engaged to analyze anything about the legal
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sufficiency of those representations.
Brieant also objects to Judge Cisneros’s description of her as a “partner.” That term,
however, is properly used to describe Brieant’s communications with a negotiating partner (i.e.,
the counterparty) and not to suggest that she had an ownership interest in the subject transaction.
In any event, characterizing Brieant as a partner is not necessary to the MJ Order’s conclusion.
Production Procedures. There is nothing improper about the procedures ordered by
Judge Cisneros. Moreover, nothing in the MJ Order precludes a subsequent in camera review, if
appropriate, of documents withheld based on any remaining claims of privilege.
Conclusion. For the foregoing reasons, the Motion is DENIED. The deadlines set in the
MJ Order remain in effect.
IT IS SO ORDERED.
Dated: November 6, 2025
RITA F. LIN
United States District Judge
Case 3:23-cv-00004-RFL Document 188 Filed 11/06/25 Page 2 of 2