“Judges are not like pigs, hunting for truffles buried in the record.”

That’s what the court wrote in Khal Anshei Tallymawr, Inc. v. Township of Toms River, 2025 WL 934761 (D.N.J. Mar. 27, 2025)(citation omitted).

The opinion opens with the following:

Over four years into litigation, Defendants have failed to produce complete discovery responses. If the Court were writing on a blank slate to address this shortcoming now that would be one thing. But Defendants’ failure here flies in the face of multiple Court Orders and multiple extensions, all of which provided clear deadlines for the completion of Defendants’ production. Each deadline was missed. And it is the Court’s understanding that to date Defendants’ production remains incomplete. This is inexcusable and, under the circumstances, sanctionable.

The question was, what sanction is appropriate?

The court first addressed procedural issues, writing: “This is not the first time the undersigned has written on procedural violations in this litigation. And while the Court should not be required to spill so much ink on such issues, procedure matters, particularly where, as here, it is not being followed and has caused disputes.”

As an initial matter, the Court is troubled by Plaintiffs’ failure to provide proper exhibit citations. It is not the job of the Court to follow the breadcrumbs dropped by counsel to find the correct supporting documents for Plaintiffs’ arguments, particularly given the number of exhibits attached to their briefing. C.f. Doebler Pa. Hybrids, Inc. v. Doebbler, 442 F.3d 812, 820 n.8 (3d Cir. 2006) (“Judges are not like pigs, hunting for truffles buried in the record”); Perkins v. City of Elizabeth, 412 F. App’x 554, 555 (3d Cir. 2011) (“a court is not obliged to scour the record to find evidence that will support a party’s claims”). And yet, rather than refer the Court directly to exhibits, Plaintiffs require the Court to scour the record to locate the appropriate materials. Perhaps most problematic is the fact that Plaintiffs are seeking sanctions based on Defendants’ allegedly insufficient discovery responses but fail to attach each response they take issue with, instead referring the Court to the previously filed motions to compel….  Plaintiffs’ approach has made the Court’s review of their arguments unnecessarily difficult.

The Court further notes that Plaintiffs continued to ignore procedure by submitting a 16-page reply brief containing 99 pages of exhibits without seeking prior leave of court….

And this is not the first time that Plaintiffs have inundated the Court with impermissible, lengthy filings.

Id. at *3 (emphasis added).  The court wrote that it “could strike Plaintiffs’ impermissible reply brief in its entirety but considers it despite Plaintiffs’ disregard for the Rules.”

Plaintiff sought game-ending sanctions, or at least an adverse inference.  However, on the merits, “the Court finds that Plaintiffs have demonstrated the appropriateness of holding Defendants in contempt of court for violating multiple Court Orders and will award limited attorneys’ fees for having to file these motions. The Court rejects Plaintiffs’ alternative forms of relief because Plaintiffs have not shown that the threshold requirement that a sanction be ‘just’ has been met.” Id. at *3, 9 (citing Fed.R.Civ.P. 37(b)(2)).