Hamrit v. Citigroup Global Markets, Inc.
- John Cronan
- 1:22-cv-10443
- U.S. District Court · Southern District of New York
- 3
In Hamrit v. Citigroup Global Markets, Judge Cronan denied Hamrit’s discovery requests, including further production, a privilege log, and sanctions.
Plaintiff Houssam Eddine Hamrit and the defendants in the discovery dispute, including Citigroup Global Markets, Inc.
What happened
In Hamrit v. Citigroup Global Markets, Inc., Plaintiff Houssam Eddine Hamrit asked the court to require Defendants to produce additional documents, provide a privilege log, and address outstanding discovery requests.
Defendants said they had produced documents responsive to one request, and Hamrit acknowledged receiving them. The court also noted that Defendants had said they were not withholding documents based on privilege. It found that other requests were either outside the limited discovery allowed on whether the parties had agreed to arbitration, unlikely to produce relevant evidence on that question, or too broad and burdensome.
Judge John P. Cronan denied the request for production responsive to Request No. 10 as moot and without prejudice, denied the request for sanctions, denied the request for a privilege log, and denied the request for further production. The court also found that no conference was necessary.
The detailed version
- Hamrit v. Citigroup Global Markets, Inc. · No. 1:22-cv-10443
- John Cronan
- Aug. 26, 2024
Background
Plaintiff Houssam Eddine Hamrit asked the Court to intervene in a discovery dispute. He requested an order requiring the Citigroup Defendants to produce documents responsive to his production requests and, if Defendants claimed privilege, to provide a privilege log. He also suggested that the Court impose sanctions and asked for a telephone conference if necessary.
Federal Rule of Civil Procedure 26(b)(1) permits discovery of nonprivileged information that is relevant to a claim or defense and proportional to the needs of the case. The Court explained that discovery relevance is broad, but the information must be reasonably calculated to lead to admissible evidence.
Court’s Analysis
Defendants represented that they had produced documents responsive to Request No. 10 after Hamrit sent his letter, and that Hamrit had acknowledged receiving the production. The Court therefore denied Hamrit’s request to compel production responsive to Request No. 10 without prejudice as moot.
The Court denied Hamrit’s request for sanctions because there was no basis for imposing them. It denied the request for a privilege log as unnecessary because Defendants had previously disavowed withholding materials on the basis of privilege.
The remaining disputed requests concerned documents that Hamrit said Defendants had not produced. The Court found that no further relief was warranted. For requests within the limited discovery authorized by an earlier order—discovery concerning whether Hamrit entered into an arbitration agreement with Defendants—Defendants represented that they had either produced responsive documents or did not possess, control, or have custody of responsive documents. The Court found that the other requests were not reasonably calculated to lead to admissible evidence about whether an arbitration agreement was formed, or were overbroad and unduly burdensome.
Disposition
The Court denied Hamrit’s request for further production. It also denied the request for sanctions and denied the request for a privilege log. The Court found that no telephone conference was necessary and stated that the parties should appear for the previously scheduled final pretrial conference on October 15, 2024. Judge John P. Cronan signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.