Delgado v. Donald J. Trump For President, Inc.
- Analisa Torres
- 1:19-cv-11764
- U.S. District Court · Southern District of New York
- 3
Delgado v. Donald J. Trump For President, Inc.: Magistrate Judge Parker denied Delgado’s request to reconsider a discovery-search order.
Delgado’s request for additional discovery was denied; the defendants were not required by this order to conduct the requested additional searches.
What happened
In Delgado v. Donald J. Trump For President, Inc., the court had ordered the Campaign to search certain people’s emails and text messages for discrimination complaints using specified search terms.
Delgado asked the court to expand the search after defendants said no one had been called the “HR Director” during the 2020 campaign and to include complaints from independent contractors. Defendants responded that the request was late and that their search had already included people who received 1099 forms, producing about 400 additional pages.
Magistrate Judge Katharine H. Parker denied Delgado’s request for reconsideration. The judge concluded that Delgado had not identified overlooked controlling decisions or new evidence, and that additional discovery was not proportional to the needs of the case.
The detailed version
- Delgado v. Donald J. Trump For President, Inc. · No. 1:19-cv-11764
- Analisa Torres
- June 7, 2024
Background
On May 14, 2024, the court ordered Defendant Donald J. Trump for President, Inc. (the “Campaign”) to search certain individuals’ emails and text messages for written complaints involving gender discrimination, sexual harassment, or pregnancy discrimination. The individuals and search terms were based on Delgado’s earlier submissions identifying people who might have received complaints.
On May 29, 2024, Delgado filed a letter asking the court to modify that order. She asserted that defendants had admitted that the Campaign did not have an “HR Director” during the 2020 campaign cycle. She requested additional search terms and asked that the search include complaints made by independent contractors, not only complaints made by employees.
Defendants opposed the request as untimely and argued that Delgado had not met the standard for reconsidering the prior order. Defendants also represented that their search was not limited to employees and included people who received 1099 forms. They said the search produced an additional 400 pages of documents.
Court’s reasoning
The court treated Delgado’s letter as a motion for reconsideration under Local Rule 6.3. The court explained that reconsideration is an extraordinary remedy and generally requires the moving party to identify an overlooked controlling decision or data that could change the prior result. It may also be justified by an intervening change in controlling law, new evidence, clear error, or a need to prevent manifest injustice. A motion should not be used simply to relitigate an issue already decided.
The court found that Delgado had not identified an overlooked controlling decision or new evidence. The statement that no one held the title “HR Director” was not new evidence relevant to the May 14 order because that order did not limit the search to a person with that title. Instead, it directed defendants to search the individuals Delgado had identified as possible recipients of discrimination complaints. The court also noted that it had carefully considered the search terms, which had resulted in additional document production.
Disposition
The court concluded that Delgado had sufficient information about other complaints to prosecute her case and that additional searches and discovery were not proportional to the needs of the case. Judge Katharine H. Parker ordered that Delgado’s motion for reconsideration of the May 14, 2024 order was DENIED.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.