Gonzalez v. Baxter Property Management Corp.

Background

Plaintiff Rosaura Gonzalez, through counsel, and Defendants jointly sought an informal conference under Judge Halpern’s individual practice. Gonzalez sought an order requiring Defendants to produce documents concerning her disability-discrimination claims, search for and produce responsive electronically stored information, and disclose the search terms, custodians, and time period used for that search.

Gonzalez’s counsel said the parties had conferred on April 17, 2025, and exchanged later correspondence but had not resolved the issues. Gonzalez also sought discovery concerning disability-related requests and complaints by other employees, particularly where the same decision makers were involved in her termination. She asked that electronic discovery be produced by May 23, 2025, so she could review it before a June 16, 2025 deposition deadline.

Plaintiff’s position

Gonzalez argued that Defendants’ discovery responses used general objections such as “overbroad” and “vague and ambiguous” without enough explanation. She contended that the objections violated Federal Rule of Civil Procedure 34, which requires specific grounds for objections and a statement about whether responsive materials are being withheld. She also argued that Defendants improperly objected to relevant requests, interpreted requests narrowly, and failed to produce documents concerning other employees’ disability-related complaints.

Defendants’ position

Defendants maintained that their responses complied with the Federal Rules of Civil Procedure. They said they had produced relevant documents for most requests, identified corresponding stamped pages, and explained when requested documents did not exist. Defendants also said that no documents were being withheld based on their objections and that search terms for electronic discovery would be provided after data collection was complete. They argued that Gonzalez’s request for court intervention on electronic discovery was premature. Defendants further stated that some interrogatory information was protected by attorney-client privilege or the attorney work-product doctrine, or was not relevant or proportional to the case.

Ruling

The court’s order states: “Application granted.” Judge Halpern scheduled an in-person discovery conference for June 9, 2025, at 11:00 a.m. at the White Plains Courthouse, in a courtroom to be determined. The order did not decide whether particular discovery responses were adequate or whether Defendants had to produce the requested materials.