Singh v. The Trustees of Columbia University in the City of New York
- Vargas
- 1:23-cv-09846
- U.S. District Court · Southern District of New York
- 2
In Singh v. Columbia University, Judge Vargas said Singh must seek permission to reopen discovery before moving to compel.
The order affects pro se plaintiff Harinder Jeet Singh and The Trustees of Columbia University in the City of New York by setting the procedure and deadlines for seeking to reopen fact discovery and pursue motions to compel.
What happened
In Singh v. The Trustees of Columbia University in the City of New York, pro se plaintiff Harinder Jeet Singh said he intended to ask the court to require the defendant and a third party to provide more discovery. The deadline for completing fact discovery was March 31, 2025.
Singh argued that he could still seek an order requiring discovery because he had served his discovery requests before the deadline. The court disagreed, explaining that such a motion must be filed during the court-ordered discovery period unless the period is reopened.
Judge Jeannette A. Vargas allowed Singh to file a motion to reopen discovery by April 29, 2025. The motion must address six good-cause factors, including his diligence and whether the requested discovery is likely to produce relevant evidence; the court did not decide whether to compel discovery.
The detailed version
- Singh v. The Trustees of Columbia University in the City of New York · No. 1:23-cv-09846
- Vargas
- Apr. 15, 2025
Background
The court received the parties’ joint status letter. Pro se plaintiff Harinder Jeet Singh stated that he intended to file a motion to compel discovery from The Trustees of Columbia University in the City of New York and a third party. The defendant opposed that plan because the deadline for completing fact discovery had passed.
The order states that the fact-discovery deadline was March 31, 2025. It also states that, on December 23, 2025, the court granted an extension and warned that it was unlikely to grant further extensions.
Court’s Analysis
Singh argued that he could still file a motion to compel because he had served the relevant discovery requests before the discovery deadline. The court rejected that argument. It explained that a motion to compel must be brought during the period set by the court for fact discovery.
After the deadline passes, a party seeking to file a motion to compel must show good cause to modify the discovery schedule and reopen discovery. The court identified six factors relevant to good cause: (1) how soon trial is expected; (2) whether the request is opposed; (3) possible prejudice to the opposing party; (4) the moving party’s diligence in seeking discovery; (5) whether the need for more discovery could have been anticipated given the time available; and (6) whether the discovery is likely to produce relevant evidence.
Ruling and Deadlines
Judge Jeannette A. Vargas permitted Singh to file a motion to reopen discovery for the purpose of pursuing motions to compel by April 29, 2025. The motion should address all six factors, especially Singh’s diligence and the likelihood that the requested discovery will lead to relevant evidence. The defendant’s opposition was due May 13, 2025, and Singh’s reply was due May 20, 2025. The order did not decide whether discovery should be compelled or whether discovery would be reopened.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.