Monroque v. Lionsgate Television Inc.

Background

Geraldine Imoya Monroque, proceeding without a lawyer, applied for appointed counsel on February 18, 2025. The court explained that such a request requires consideration of the apparent merits of the claims, the plaintiff’s ability to pay for a private lawyer, efforts to obtain a lawyer, the availability of counsel, and the plaintiff’s ability to handle the case without assistance. The court concluded that a more developed record was needed to determine whether Monroque’s claims had enough potential merit to support appointing counsel.

The order also addressed discovery, which is the pretrial exchange of information and documents. After a February 6 conference, the court had ordered Monroque to identify any challenge to Lionsgate’s discovery responses, state whether she sought permission to use written questions, sign and return medical-record authorization forms, and produce documents responsive to specified requests for production concerning her employment history.

Medical Records and Employment Documents

Monroque objected to producing medical records and employment history on relevance and privacy grounds. The court acknowledged that she has a privacy interest in her medical records but held that, by asserting claims under the Americans with Disabilities Act, she placed at issue whether she has a disability covered by that statute. The court stated that she bears the burden of proving that element of her claims. It therefore held that Lionsgate may obtain records from her medical providers relating to her autoimmune condition and vaccination history.

The court also noted Lionsgate’s assertion that Monroque had not completed and returned the medical-record authorization forms or made supplemental production of documents reflecting her work history. The court warned that failing to provide the medical-record authorizations could result in dismissal of any disability claim and that failing to provide employment records could prevent her from pursuing front-pay or back-pay claims.

Rulings

The court ordered as follows:

- Monroque’s February 18, 2025 application for counsel was denied without prejudice to renewal when a potentially meritorious claim can be demonstrated. - Monroque’s February 18, 2025 letter requesting reconsideration of the February 7, 2025 order was denied. The court found that the letter did not identify controlling authority the court had overlooked and largely repeated arguments previously rejected. - Monroque’s request for an extension of time to comply with the February 7, 2025 order was denied. - Monroque was ordered to comply fully with the February 7, 2025 order by March 7, 2025.

This was an order about appointed counsel, reconsideration, and discovery compliance; it did not decide the ultimate merits of Monroque’s claims against Lionsgate Television, Inc.