K.A. v. City Of New York
- Laura Swain
- 1:16-cv-04936
- U.S. District Court · Southern District of New York
- 4
In K.A. v. City of New York, Judge Willis denied Defendants’ request to pause discovery because they did not show good cause.
The City of New York and Sidney Wilson must continue with discovery, and all parties must submit a new proposed case-management plan by June 26, 2025.
What happened
In K.A. v. City of New York, the City and Sidney Wilson asked the court to pause discovery while other motions and issues remained pending.
The Defendants argued that discovery would be burdensome, that a representative for L.J.’s estate had not yet been appointed, and that their claims might be dismissed. The Plaintiffs opposed another delay, pointing out that the court had previously denied a stay and that L.J. died during an earlier stay.
Judge Jennifer E. Willis denied the motion because the Defendants offered only general statements about burden, had not shown the required good cause, and had not met the strict standard for reconsidering the court’s earlier decision. The parties must discuss and submit a new case-management plan by June 26, 2025.
The detailed version
- K.A. v. City Of New York · No. 1:16-cv-04936
- Laura Swain
- May 29, 2025
Background
The City of New York and Sidney Wilson moved to stay, or pause, discovery. The case also involved pending motions to dismiss and to amend the complaint. The Defendants cited several reasons for a stay: L.J.’s daughter had not yet been appointed as a special personal representative of L.J.’s estate; the pending motions could affect the case; Wilson intended to file another motion concerning the prosecution of claims against released parties; claims against Corizon had been dismissed; and the remaining claims were more likely to be dismissed. The Defendants also argued that the Plaintiffs were seeking broad and burdensome discovery.
The Plaintiffs argued that the court had already denied a stay in 2022 and that the Defendants had not shown changed circumstances, a strong likelihood that the claims lacked merit, undue discovery burdens, or unfair prejudice. They also argued that another delay would prejudice them because L.J. died while the case had been stayed for more than six years.
Legal Standard
Discovery is not ordinarily paused merely because a motion has been filed. Under Federal Rule of Civil Procedure 26(c), a court may issue a protective order, including a discovery stay, for good cause to prevent annoyance, embarrassment, oppression, or undue burden or expense. The party seeking the stay must provide a particular and specific factual showing rather than general or conclusory statements. Relevant considerations include the scope of the requested discovery, the burden of responding, prejudice to the opposing party, and the strength of the motion supporting the requested stay.
The court also explained that reconsideration of an earlier order requires a strict showing that the court overlooked controlling law or factual matters previously presented. Reconsideration is not available simply to relitigate an issue that has already been decided.
Ruling
The court denied the Defendants’ motion to stay discovery. It found that the Defendants made only conclusory statements about why discovery would be burdensome and did not provide specific facts establishing good cause. The court also had previously directed the parties to continue discovery while the motion to dismiss was pending, and the Defendants did not satisfy the requirements for reconsidering that prior direction. Finally, the court found that further delay would prejudice the Plaintiffs, as shown by L.J.’s death during the previous stay.
The parties were directed to meet and confer and provide a new proposed case-management plan by June 26, 2025. The Clerk was requested to close Docket Number 251.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.