Reid v. A-Plus Care HHC Inc.
- John Cronan
- 1:23-cv-01163
- U.S. District Court · Southern District of New York
- 6
In Reid v. A-Plus Care HHC Inc., Judge Aaron partly granted and partly denied the request to extend fact discovery, setting August 16, 2024 as the final deadline.
The ruling affects Louise Reid and the defendants in the wage-and-hour case by setting August 16, 2024 as the final court-supervised fact-discovery deadline and denying their request for an indefinite extension.
What happened
Louise Reid brought a wage-and-hour case against A-Plus Care HHC Inc. and other defendants under the Fair Labor Standards Act and New York Labor Law. The court had set July 1, 2024 as the fact-discovery deadline after several earlier extensions.
The defendants, with Reid’s consent, asked to postpone the discovery deadline indefinitely until settlement discussions ended. The court found that settlement discussions alone did not establish a sufficient reason for another extension, and that neither side had shown diligence in the discovery process.
The court denied the request for an indefinite extension but granted a third and final extension through August 16, 2024. Judge Stewart D. Aaron stated that discovery after that date would not take place under the court’s supervision.
The detailed version
- Reid v. A-Plus Care HHC Inc. · No. 1:23-cv-01163
- John Cronan
- June 28, 2024
Background
Louise Reid filed a wage-and-hour action against A-Plus Care HHC Inc., Frederick Bakalinsky, Sofia Bakalinsky, and Spiros Botos. The opinion states that Reid asserted claims under the Fair Labor Standards Act and New York Labor Law, among other claims.
The court initially set February 28, 2024 as the deadline for completing fact discovery. After the parties requested more time, the court extended the deadline to May 28, 2024 and later extended it to July 1, 2024. The May 23 extension order stated that no further extensions would be granted without good cause and only for limited purposes.
On June 27, 2024, the defendants filed a letter motion in which the defendants and Reid jointly requested that the discovery deadline be postponed indefinitely until settlement discussions ended.
Legal standard
Federal Rule of Civil Procedure 16(b)(4) allows a scheduling order to be changed only for good cause and with the judge’s consent. The opinion explains that good cause depends on the diligence of the party seeking the extension and that courts have broad discretion to manage and enforce discovery deadlines.
Analysis and ruling
The court denied the parties’ joint request for an indefinite extension. It found that the parties had not shown good cause because settlement discussions, by themselves, were not enough to justify extending the deadline. The court also found that neither party had demonstrated diligence in the discovery process.
Despite those findings, the court exercised its discretion to grant a third and final extension of the fact-discovery deadline until August 16, 2024. The court stated that any discovery after that date would not be conducted under its supervision.
The defendants’ letter motion was GRANTED IN PART and DENIED IN PART. Fact discovery was ordered to conclude on August 16, 2024.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.