Castillo v. Albert Einstein College of Medicine Inc
- Paul Engelmayer
- 1:24-cv-00984
- U.S. District Court · Southern District of New York
- 8
In Castillo v. Albert Einstein College of Medicine Inc., Judge Engelmayer granted Castillo’s motion to compel discovery about wage claims under federal and New York law.
Rinaldys Castillo, the proposed class and collective of workers, and the defendant entities involved in responding to the ordered discovery.
What happened
In Castillo v. Albert Einstein College of Medicine Inc., Rinaldys Castillo claims that the defendants failed to pay overtime and other wages, and failed to provide required wage statements, to him and other workers. The case involves claims under the federal Fair Labor Standards Act and New York law, and Castillo is seeking to represent a larger group of workers.
Castillo asked the defendants to provide information about electronically stored information, potential witnesses and decision-makers, database searches, and systems used to communicate about or track workers’ schedules and hours. The defendants argued that some requests were premature, burdensome, overbroad, or already answered.
Judge Engelmayer granted Castillo’s discovery requests. He allowed the defendants to suggest limited changes to the proposed electronic-information process, ordered them to provide a complete list of relevant custodians and an organizational chart, directed them to run and disclose initial searches using Castillo’s proposed terms, and ordered them to identify relevant systems, devices, methods, and knowledgeable people.
The detailed version
- Castillo v. Albert Einstein College of Medicine Inc · No. 1:24-cv-00984
- Paul Engelmayer
- June 30, 2025
Background
Rinaldys Castillo sued Albert Einstein College of Medicine Inc. and Montefiore Health Systems, Inc., Montefiore Medical Center, and Montefiore Medicine Academic Health System, Inc. Castillo brings claims individually and on behalf of a proposed class and collective under the Fair Labor Standards Act (FLSA) and New York Labor Law. He alleges that he and other workers regularly worked more than 40 hours per week without receiving required overtime pay. He also alleges that the defendants failed to pay wages on time and failed to provide required wage statements.
The parties were conducting preliminary discovery before Castillo’s anticipated motion for conditional class certification. The court had previously denied the Montefiore defendants’ motion to dismiss, ruling that Castillo had adequately alleged that the defendants jointly controlled the conditions of his employment and therefore could qualify as joint employers under the FLSA and New York law. That earlier ruling was not the subject of this order.
Discovery Requests
Castillo moved to compel four categories of discovery:
- Responses to his proposed protocol for collecting and reviewing electronically stored information, or ESI;
- A complete list of potential custodians—people likely to possess relevant information—and organizational charts identifying them and relevant supervisors;
- Results and hit counts, organized by custodian, from searches using Castillo’s proposed search terms; and
- Identification of systems, applications, devices, or methods that could contain or generate information showing when proposed class or collective members began or ended work, along with people knowledgeable about those systems.
Under Federal Rule of Civil Procedure 26(b)(1), discovery may cover nonprivileged information relevant to a claim or defense and proportionate to the needs of the case. The party seeking discovery must show relevance. After that showing, the party resisting discovery must justify limits such as undue burden or expense.
Court’s Rulings
The court granted Castillo’s requests.
For the ESI protocol, the court found that Castillo’s proposed protocol appeared reasonable and proportionate. Rather than immediately adopt the proposal without changes, the court permitted the defendants to return redlines—proposed edits—by July 3, 2025. The parties were directed to meet and confer in good faith within three non-holiday business days after the redlines were returned and to submit jointly proposed final protocols by July 10, 2025.
For the custodian and organizational-chart request, the court found the information plainly relevant and discoverable. It rejected the defendants’ reliance on a current website as an adequate response, noting that the website might contain irrelevant information or fail to reflect the relevant period. The defendants were ordered to produce by July 10, 2025, a complete list of people responsible for establishing the pay rates and pay bases for Castillo and the proposed class members, along with an organizational chart including those people and any others who might qualify as immediate supervisors.
For the search-term request, the court found Castillo’s proposed terms reasonable and proportionate for initial searches. After the parties agreed on custodians, the defendants were ordered to run the searches and fully disclose the results by custodian for each term. If a term produced disproportionately many irrelevant results or otherwise proved burdensome or unhelpful, the parties were directed to meet and confer promptly about revising it.
For the systems-identification request, the court rejected the defendants’ arguments that the request was moot or overbroad. Identifying the people defendants considered the “best sources” would not identify every source of relevant information. The court also found that information about systems that could show when workers worked was relevant even if a system was not specifically designed to track working time. The defendants were therefore ordered to produce the requested information.
The Clerk of Court was directed to terminate the motion at Docket 51. The order resolved the discovery dispute; it did not decide whether Castillo or the proposed class and collective would ultimately prevail on the wage claims.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.