CHICAGO (LN) — A federal judge ordered JPMorgan Chase Bank to produce internal policies it had stonewalled for years, ruling Wednesday that a Seventh Circuit reversal in a defamation suit brought by Dr. Padma Rao effectively breathed new life into discovery requests the bank had buried under boilerplate objections.
Rao sued Chase and banker Kiefer Krause in 2021, alleging defamation after Krause told a probate court representative that Rao had illegally used her power of attorney to name herself the payable-on-death beneficiary on her late mother's Chase accounts — a conclusion, Rao says, that Krause reached by reviewing the wrong signature cards.
The Seventh Circuit reversed summary judgment in October 2025, finding that a reasonable jury could infer Krause should have known Chase's own policy prevented a power-of-attorney agent from designating herself as a POD beneficiary. The appeals court held that evidence of Chase's POD designation policy creates genuine, material issues of fact as to Krause's recklessness and whether he abused a qualified privilege.
That holding put Chase's internal policies squarely at the center of the remanded case — and squarely in conflict with the bank's years-old refusal to produce them.
Rao had sought Chase's POD designation policies in written discovery back in May 2022. Chase objected on relevance, vagueness, undue burden, and confidentiality grounds, and Rao never moved to compel before discovery closed on February 15, 2023. After the Seventh Circuit's October 2025 reversal, Rao's counsel wrote to Chase demanding supplementation; Chase refused, and Rao filed her motion to compel days later.
U.S. District Judge Mary M. Rowland acknowledged the legal tension directly. Under the weight of authority, a party that objects to discovery and goes unchallenged typically has nothing to supplement under Rule 26(e). Rowland wrote that it is not entirely clear whether this particular set of circumstances fits neatly within Rule 26(e)(1)(A). But she found that Rule 26(e)(1)(B) independently authorizes a court to order supplementation, and that the spirit of the Seventh Circuit's mandate — which requires the district court to follow its express or implied rulings — demanded production.
On Chase's remaining objections — vagueness, overbreadth, undue burden, disproportionality, and confidentiality — Rowland was blunt. The objections were cursory and generally unexplained, she wrote, and courts in the Northern District of Illinois treat such unadorned boilerplate as tantamount to no objections at all.
The ruling is narrow. Rowland limited Chase's required production to POD designation policies and procedures for only the specific years identified in Rao's motion — the year Krause conducted his investigation and the year of the alleged fraudulent conduct — rather than any broader sweep of bank records.
Chase must produce the supplemental responses by May 6, 2026.