Williams v. TD Bank

Background

David K. Williams, identified in the filing as a self-represented estate representative, made several filings seeking discovery before a conference scheduled for October 27, 2025. The requests included Docket No. 33, titled a motion for expedited discovery, and requests in Docket Nos. 32, 35, and 36.

The motion alleged that TD Bank and the other defendants were involved in a systematic enterprise concerning the alleged theft of property from a safe-deposit box and related conduct. The opinion addresses only whether discovery should be expedited; it does not decide whether those allegations are true.

Requested Discovery

Williams sought immediate depositions and broad document production. The requests included all account activity for accounts associated with Gus Williams or his estate, personnel and communications records concerning alleged management changes, communications between TD Bank and the New York State Comptroller concerning the estate, and TD Bank’s outgoing mail records for July through September 2025.

Williams argued that the materials were needed before the October 27 conference and asserted that evidence might be destroyed or witnesses eliminated. The opinion states that these concerns were presented as bare assertions and that Williams did not explain sufficiently why the discovery had to occur before the conference rather than later.

Legal Standard

The court stated that courts in the district use a flexible standard based on reasonableness and good cause when deciding requests for expedited discovery. Under that approach, the requesting party must show that the requests are reasonable under the circumstances. The court also noted that some courts apply a stricter test similar to the showing required for a preliminary injunction, but it concluded that Williams’s requests failed even under the more lenient reasonableness standard.

Ruling

The court concluded that the requested expedited discovery was not justified. It found that many requests were overly broad because they were not limited in subject matter. It also found that other requests were overly burdensome because the defendants could not reasonably produce the requested materials before the October 27 conference.

Judge Kenneth M. Karas therefore denied Williams’s Motion for Expedited Discovery at Docket No. 33 without prejudice to further such requests. The Clerk of Court was directed to terminate that pending motion. To the extent Docket Nos. 32, 35, and 36 sought discovery before the conference, those requests were likewise denied. The ruling did not decide the parties’ underlying disputes or the truth of Williams’s allegations.