Roebuck v. City of New York
- 1:25-cv-07259
- U.S. District Court · Southern District of New York
- 2
Roebuck v. City of New York: the court, with no judge identified, denied early discovery because defendants had received a preservation notice.
Cameron Roebuck's request for early production of surveillance video and Internal Affairs records was denied. The defendants were not ordered to produce those materials through this motion, although the court stated that they could face sanctions if they destroyed evidence after receiving the preservation notice.
What happened
In Cameron Roebuck v. City of New York, et al., Roebuck, who represented himself, asked to obtain evidence before the parties' required discovery-planning meeting. He sought surveillance video from his June 12, 2025 arrest and processing, along with related Internal Affairs Bureau records.
Roebuck argued that the evidence was important and could be lost because video systems are routinely overwritten. He said he had sent the City and the New York City Police Department a letter on July 7, 2025, asking them to preserve the video.
The court denied the motion. The court found that defendants had acknowledged receiving the preservation letter, that there was no evidence they would destroy the evidence, and that they could face penalties if they did. The court also directed Roebuck to meet and discuss discovery with defendants before filing a future motion.
The detailed version
- Roebuck v. City of New York · No. 1:25-cv-07259
- Oct. 23, 2025
Background
Cameron Roebuck, proceeding without a lawyer, moved under Federal Rule of Civil Procedure 26(d)(1) for permission to conduct limited discovery before the parties' required Rule 26(f) conference. He requested the booking-area and holding-cell surveillance video from June 12, 2025, covering his arrest and processing, and related Internal Affairs Bureau records or reports identified as Internal Affairs Complaint No. 2025-18540.
Roebuck stated that he was arrested and processed by members of the New York City Police Department in Lower Manhattan and sustained physical injury while compliant and handcuffed. He argued that early discovery was justified because the video was time-sensitive, was held exclusively by the City, and could be overwritten. He also stated that he had sent defendants a preservation letter on July 7, 2025.
Court's Analysis
The court noted that defendants had acknowledged receiving Roebuck's preservation notice. The court explained that if defendants destroyed the requested evidence despite that notice, they could face sanctions, or penalties imposed by the court. Because there was no evidence that defendants would violate their obligation to preserve the evidence, the court found that Roebuck had not shown the required good cause for early discovery.
Disposition
The court denied the motion and directed the Clerk of Court to terminate the motion at docket entry 12. The court also stated that Roebuck should meet and confer with defendants before filing any future motion.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.