Livingston v. Standard Int’!. Mgt.
- Jesse Furman
- 1:25-cv-04374
- U.S. District Court · Southern District of New York
- 4
In Livingston v. Standard International Management, LLC, Judge Furman denied Livingston’s motions to compel discovery and for sanctions after Defendant’s response.
Livingston’s requests for additional discovery and sanctions were denied; the underlying employment claims were not decided by this order.
What happened
Livingston, who is representing himself, asked the court to require Standard International Management, LLC to provide additional discovery, including comparator information, surveillance footage, and human-resources records. The case involves Livingston’s allegations of race, sex, and age discrimination and retaliation in employment.
Standard International Management opposed the request, stating that it had produced documents and 12 videos, responded to discovery requests, and would respond to a newer request concerning another workplace incident when its response was due. The defendant also argued that some requests were too broad, unclear, or sought confidential information.
Judge Jesse M. Furman concluded that there was no basis for court intervention at that time and no basis for sanctions. The court denied both Livingston’s motion to compel and motion for sanctions and directed the Clerk of Court to terminate ECF Nos. 32 and 33.
The detailed version
- Livingston v. Standard Int’!. Mgt. · No. 1:25-cv-04374
- Jesse Furman
- Nov. 7, 2025
Background
Livingston alleges that Standard International Management, LLC violated federal, New York State, and New York City employment-discrimination laws through race-, sex-, and age-based discrimination and retaliation. The opinion text states that Livingston remains employed as a server at The Standard, High Line Hotel and is representing himself.
Livingston filed a letter motion to compel discovery, identified as ECF No. 32, concerning comparator data, closed-circuit television footage, and related human-resources records. He also filed a motion for sanctions, identified as ECF No. 33.
The Discovery Dispute
In its opposition, Standard International Management stated that it had responded to Livingston’s document requests and produced 336 documents and four video files. It later supplemented the production, ultimately providing 12 videos showing areas of the hotel on September 27, 2024. The defendant stated that it had also produced documents concerning Livingston’s communication with Human Resources about an alleged incident and that it was not in possession of additional responsive documents.
The defendant further stated that Livingston’s request for documents concerning another workplace incident was included in supplemental requests served on October 11, 2025, and that the response to those requests was not yet due. The defendant argued that it had complied with its discovery obligations and asked the court to deny the motion to compel.
Ruling
Judge Jesse M. Furman concluded that, in light of the defendant’s response, there was no basis for court intervention at that time and no basis for sanctions. The court denied Livingston’s motion to compel and motion for sanctions. The Clerk of Court was directed to terminate ECF Nos. 32 and 33.
Classification
This is a procedural order concerning discovery and sanctions. The court did not decide the underlying employment-discrimination and retaliation allegations.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.