Roundtree v. NYC
- William Pauley
- 1:15-cv-08198-JPC
- U.S. District Court · Southern District of New York
- 3
In Roundtree v. City of New York, Judge Pauley denied Roundtree’s motion to compel discovery in its entirety.
Juel Roundtree and the defendants, because the court denied Roundtree’s requests for additional discovery and set out next steps concerning possible summary-judgment motions.
What happened
In Roundtree v. City of New York, Juel Roundtree asked the court to require the defendants to provide additional discovery, including medical records, incident reports, insurance agreements, and staff information.
The defendants said they had produced all responsive records they could find, that some requested medical information was confidential and irrelevant, and that other requests were vague, overly broad, or concerned documents that did not exist. They also objected to Roundtree’s 75 interrogatories because the federal rule generally limits parties to 25.
Senior United States District Judge William H. Pauley III denied the motion to compel in its entirety. The court found the defendants’ responses sufficient and rejected the remaining requests as irrelevant, vague, disproportionate, potentially creating security concerns, or exceeding the interrogatory limit.
The detailed version
- Roundtree v. NYC · No. 1:15-cv-08198-JPC
- William Pauley
- Aug. 14, 2020
Background
Juel Roundtree moved to compel discovery through filings at ECF Nos. 197, 203, and 207. A motion to compel asks the court to order an opposing party to provide requested information or documents. The defendants opposed the motion through filings at ECF Nos. 202, 206, and 208.
Discovery Requests and Court’s Analysis
- Medical log-book redactions: Roundtree challenged redactions in medical log books. The court found that the defendants had not redacted information about Roundtree’s visits or the dates of other inmates’ visits. They had redacted only non-party medical information, which the court found irrelevant and confidential. - Use-of-force and unusual-incident reports: Roundtree sought reports corresponding to dates in his Fourth Amended Complaint. The defendants said they searched for records involving chemical agents used in areas where Roundtree was housed and found records concerning a June 5, 2015 incident, which they produced. The court accepted the defendants’ good-faith statement that they had produced all responsive records and could not locate additional documents involving Roundtree for the relevant dates. - Staff medical-treatment logs: The court agreed with the defendants that these logs sought confidential medical information about non-parties and were not relevant to Roundtree’s action. - Insurance agreements: Roundtree sought agreements that he alleged described Aflac payments to Department of Correction staff. The defendants denied knowing of such agreements and said they could not locate relevant documents. The court stated that the defendants could not produce documents that did not exist. - “2015 reform settlement”: Roundtree made a vague request for documents concerning a publicly known “2015 reform settlement.” The court found that the request did not identify what documents he wanted and noted that he had at least three opportunities to clarify it. The court denied the request. The court also stated that, even if Roundtree meant the decree in a prior related proceeding, it did not see the decree’s relevance. - Staff rosters, sign-in sheets, and photographs: Roundtree made a new request for records concerning all staff who worked in the relevant housing area. The court found the request disproportionate and not targeted toward discovering admissible evidence. It also noted a possible security concern from providing photographs of prison staff to an inmate. - Interrogatories: Roundtree complained that the defendants had not answered his “75 interrogatories.” The court found that he did not identify which questions were unanswered and noted that the requests exceeded the 25-interrogatory limit in Federal Rule of Civil Procedure 33(a)(1).
Disposition
Judge William H. Pauley III denied Roundtree’s motion to compel discovery in its entirety. The court noted that the action was ready for summary judgment and that the defendants were scheduling a conference with Roundtree about a summary-judgment briefing schedule. The court allowed the parties to request a pre-motion conference concerning proposed summary-judgment motions by September 21, 2020, consistent with the court’s rules. It also reminded Roundtree to stop repeatedly sending letters, affidavits, applications, and notices, warning that further failures could result in dismissal of the action. The order did not dismiss the action.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.