Waheed v. Rentoulis

Background

Sehra Waheed moved under Federal Rule of Civil Procedure 37 to strike the defendants’ answer as a sanction for alleged discovery violations. She relied on Rule 37(b), which concerns failing to obey a court order, and Rule 37(d), which concerns certain failures involving depositions, interrogatories, or inspection requests. Waheed argued that the defendants had not produced documents responsive to her discovery demands, including surveillance footage, valuation documents, and certified notice records.

Court’s analysis

The court found that Waheed’s request for relief was substantively identical to an earlier request that the court had denied. The court also found that Waheed had not identified an intervening change in controlling law, new evidence, an error, or a manifest injustice that would justify reconsidering the earlier order.

The court further noted that fact discovery had closed on August 29, 2025. Waheed had not filed a motion to compel discovery before the discovery period ended and had not requested more time to complete discovery. She also did not identify a discovery order that the defendants had failed to obey or assert that she had properly noticed a deposition at which a party failed to appear.

Ruling

The court found no basis to impose sanctions under Rule 37 or to strike the defendants’ answer. It denied Waheed’s motion at ECF No. 257. The order was issued by Henry J. Ricardo, United States Magistrate Judge.