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S.D.N.Y.Procedural orderFiled Oct. 21, 2025

Dr. Stella Safo, et al. v. Dr. Prabhjot Singh, et al.

Judge
Vernon Broderick
Docket
1:19-cv-03779
Court
U.S. District Court · Southern District of New York
Pages
10
DiscoveryCivil Procedure
In one sentence

Safo v. Singh: Judge Willis denied plaintiffs’ discovery and reargument requests, while deferring the Kishore deposition request.

Who this affects

The plaintiffs’ ability to obtain additional discovery was limited: the court denied the identified document and deposition requests, denied the reargument request, and deferred the request for Sandeep Kishore’s deposition to a separate administrative matter. The defendants were not required by this order to provide the requested discovery, although they had agreed to re-review Dr. Singh’s personal email.

What happened

In Dr. Stella Safo, et al. v. Dr. Prabhjot Singh, et al., the plaintiffs asked the court to resolve several discovery disputes involving documents, communications, employment records, and witness depositions. They also asked the court to reconsider an earlier decision concerning an investigation conducted in 2018.

The court denied the requests for documents and depositions concerning the 2018 investigation, communications involving certain witnesses, and Dr. Singh’s employment file. It denied one request as moot because defendants agreed to search Dr. Singh’s personal email again, and denied another as moot based on defendants’ representation that responsive records had already been searched for and produced. The court also denied the request to reconsider its earlier ruling, but deferred the request to compel Sandeep Kishore’s deposition to a separate administrative matter.

Judge Jennifer E. Willis issued the order on October 21, 2025. She relied on lack of relevance, excessive breadth, burden, untimeliness, or defendants’ representations about their searches, and found no basis to reconsider the earlier ruling.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Dr. Stella Safo, et al. v. Dr. Prabhjot Singh, et al. · No. 1:19-cv-03779
Judge
Vernon Broderick
Date
Oct. 21, 2025

Background

Between April and May 2025, the plaintiffs filed several letter motions and responses about discovery disputes. The parties had jointly extended fact discovery to February 28, 2025, and the plaintiffs filed the motions addressed here after that deadline. After ordering the parties to meet and confer, the court heard oral argument on October 6, 2025.

Plaintiffs’ first motion to compel, Dkt. No. 176

The court declined to decide whether most of the requests were untimely because it found that the requests also failed on their merits.

The plaintiffs sought documents concerning former Arnhold Institute for Global Health Chief Operating Officer Kirsten Knaup, including documents related to a 2018 investigation and her departure. The plaintiffs argued that the documents could show discriminatory treatment and affect defendants’ credibility. The court found the 2018 investigation occurred years after the alleged discrimination and harassment and was not relevant to the claims. It therefore denied the requests identified as 1.b and 1.c.

The plaintiffs also sought Knaup’s communications with Dr. Irwin Redlener about an earlier sexual-harassment complaint involving another person. The court found the information minimally relevant but concluded that the relevance was outweighed by the burden of searching communications about an unsubstantiated rumor that Knaup had heard years earlier. The court denied request 1.e as disproportionate to the needs of the case.

The plaintiffs sought communications between Knaup and defendants Bruno Silva and Prabhjot Singh. Because defendants represented that Knaup was not aware of responsive documents after a reasonable and diligent search, the court denied requests 1.f and 1.g.

The plaintiffs also sought a draft report by an Oversight Committee concerning the 2018 investigation. Defendants asserted attorney-client and work-product privilege, but the court did not reach that issue. Instead, it found the request untimely because the plaintiffs had waited ten months after a deposition identifying the report’s main author. The court therefore denied request 2.a based on untimeliness.

Plaintiffs’ second motion to compel, Dkt. No. 179

The plaintiffs sought communications between defendants and Dr. Kevin Starr. Because defendants agreed to re-review Dr. Singh’s personal email for relevant communications with Starr, the court denied that request as moot.

The plaintiffs sought all communications involving Starr, John Arnhold, or Jody Arnhold concerning Singh, the Arnhold Institute, donations, or the 2018 investigation. The court found that the investigation was not relevant and that the request for “all” communications was too broad in scope and time period. The court denied the request.

The plaintiffs sought Dr. Singh’s employment file, including what they called a “letter of reproach.” Defendants represented that they had produced all personnel-related documents found through a good-faith, diligent search and had not located such a letter. The court denied the request as moot.

The plaintiffs sought to compel depositions of John and Jody Arnhold concerning their alleged influence over the 2018 investigation. The court declined to decide the timeliness issue but found the proposed discovery irrelevant because it concerned the 2018 investigation. It denied the motion to compel those depositions.

The court declined to rule at that time on the request to compel Sandeep Kishore’s deposition and stated that it would address that request in a separate administrative matter, Case No. 25-mc-154.

Motion for reargument, Dkt. No. 182

The plaintiffs asked the court to reconsider its earlier denial of a motion concerning the 2018 investigation. The court explained that the applicable local rule requires a reconsideration or reargument request within 14 days after the challenged order. The plaintiffs filed their request about 15 months after the earlier ruling, so the court found it untimely.

The court also held that the request failed on the merits. It found that the plaintiffs’ claimed new evidence either predated the earlier ruling or had been available before the close of fact discovery. The court characterized the motion as an attempt to relitigate old issues and denied the motion for reargument. The opinion refers to this motion as the plaintiffs’ motion but, in its final ruling, states that it is denying “Defendants’ motion for reargument.”

Disposition and classification

The order is a discovery and reconsideration ruling. It does not decide the parties’ underlying discrimination or harassment claims. The discovery requests were denied, several as moot, the Kishore deposition request was deferred to another matter, and the reargument motion was denied. The order is therefore classified as a procedural order.

The authoritative version

Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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