Camp v. New York City Health & Hospitals Corporation
- Vargas
- 1:24-cv-01344
- U.S. District Court · Southern District of New York
- 4
In Camp v. New York City Health and Hospitals Corporation, Judge Vargas granted in part and denied in part a request to reopen discovery for depositions by July 9, 2025.
Eric Camp and the defendants are affected: fact discovery was reopened only for fact depositions through July 9, 2025, and the parties must file a joint status letter by July 23, 2025.
What happened
In Camp v. New York City Health and Hospitals Corporation, fact discovery closed on June 4, 2025. The parties jointly asked to extend it until October 31 after depositions had not been scheduled and the defendants served discovery requests shortly before the deadline.
The court found that the parties had already had ample time to complete discovery and that the defendants had not acted diligently. The court also found that Eric Camp should not be harmed by delays caused by the defendants.
Judge Vargas granted in part and denied in part the request to reopen discovery. The parties may complete fact depositions by July 9, 2025, and must file a joint status letter by July 23, 2025.
The detailed version
- Camp v. New York City Health & Hospitals Corporation · No. 1:24-cv-01344
- Vargas
- June 17, 2025
Background
The court treated the parties’ motion for an extension of time to complete discovery as a motion to reopen discovery. The case-management plan initially set March 4, 2025, as the deadline for completing fact discovery. After Eric Camp moved to compel discovery, the court extended that deadline to June 4, 2025, and ordered the defendants to provide outstanding discovery responses. The court later denied Camp’s motion for sanctions but ordered the parties to comply with their discovery obligations.
Fact discovery closed on June 4,
- On June 9, the parties jointly requested an extension until October 31,
- The motion stated that the defendants had served their first interrogatories and document requests on June 2, two days before discovery closed and more than seven months after the deadline for serving such requests. The parties had apparently not scheduled depositions. The motion also noted that defense counsel would begin family leave on July 9 and that Camp’s counsel would be on vacation from June 19 through July
- The opinion states that the motion offered no explanation for the delay in serving the defendants’ discovery requests or for not taking depositions during June.
Legal Standard
A district court may amend a scheduling order and reopen discovery when there is good cause. The party seeking to reopen discovery must show that the needed discovery was not missed because of its own lack of diligence. Courts also consider the explanation for missing the deadline, diligence in seeking a schedule change, the importance of the additional discovery, the opportunity already available to conduct discovery, possible prejudice, and how soon trial is expected.
Court’s Analysis
The court found that the parties had nine months to conduct fact discovery and that the court had already granted one extension. It concluded that this was ample time to complete discovery in this discrimination action involving one plaintiff.
The court found that the defendants had not been diligent and that their document requests and interrogatories were untimely. In contrast, the court found that Camp had timely submitted discovery requests, moved to compel when the defendants did not respond, and tried in May to schedule depositions before the discovery deadline. The court concluded that Camp should not be prejudiced by delays caused by the defendants. It also stated that defense counsel had not explained why another attorney could not cover the case during the family leave.
Ruling
The court granted in part and denied in part the motion to reopen discovery. It extended the deadline for fact discovery to July 9, 2025, but only for the limited purpose of conducting fact depositions. The parties must file the required post-fact-discovery joint status letter by July 23, 2025. The Clerk of Court was directed to terminate ECF No. 42.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.