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S.D.N.Y.Procedural orderFiled Dec. 18, 2020

Lentz v. ThoughtWorks, Inc.

Judge
Paul Gardephe
Docket
1:20-cv-07043
Court
U.S. District Court · Southern District of New York
Pages
5
DiscoveryCivil ProcedureEmployment
In one sentence

In Lentz v. ThoughtWorks, Judge Gardephe denied defendants’ motion to stay discovery while their motion to dismiss was pending.

Who this affects

The ruling affects Tiffany Lentz and defendants ThoughtWorks, Inc. and Kishore Rachapudi by denying defendants’ request to pause discovery.

What happened

In Lentz v. ThoughtWorks, the defendants asked the court to pause discovery until it decided their planned motion to dismiss Tiffany Lentz’s complaint. The complaint alleges race and gender discrimination, retaliation, unequal pay, and interference with a business relationship.

The defendants argued that the claims were inadequately supported, and that the expected discovery would be broad, expensive, and burdensome. They also argued that pausing discovery would not unfairly harm Lentz because discovery had not yet begun.

Judge Paul G. Gardephe denied the defendants’ motion to stay discovery. The order states that the denial was based on reasons given at the December 17, 2020 status conference, but the provided text does not describe those reasons.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Lentz v. ThoughtWorks, Inc. · No. 1:20-cv-07043
Judge
Paul Gardephe
Date
Dec. 18, 2020

Background

The provided filing is a letter from counsel for defendants ThoughtWorks, Inc. and Kishore Rachapudi. The defendants asked the court to stay, or pause, discovery under Federal Rule of Civil Procedure 26(c) while their anticipated motion to dismiss under Rule 12(b)(6) was unresolved. A Rule 12(b)(6) motion argues that a complaint does not adequately state a legally valid claim.

The complaint, as described in the defendants’ filing, asserts claims for race and gender discrimination under Title VII, the New York State Human Rights Law, and the New York City Human Rights Law. It also asserts retaliation, tortious interference with a business relationship, and a New York equal-pay claim. The filing says the complaint includes allegations concerning personnel decisions involving other employees, alleged conduct by Rachapudi, alleged retaliation, and differences in pay.

Defendants’ Arguments

The defendants argued that the complaint lacked facts showing overt discrimination, discriminatory treatment, constructive discharge, or retaliatory intent. They also argued that Rachapudi was not Lentz’s supervisor and that the complaint did not connect him to the alleged actions affecting Lentz. Regarding tortious interference, the defendants argued that Lentz could not bring that claim against Rachapudi as a company employee and had not alleged specific acts causing the claimed harm. Regarding equal pay, they argued that the complaint did not show that Lentz’s positions involved substantially equal skills and responsibilities compared with Rachapudi’s position.

The defendants further argued that discovery would be unusually broad and burdensome because it could involve employment practices, companywide policies and complaints, electronically stored information, several years of alleged incidents, and many nonparties. They stated that Lentz’s counsel had indicated an intent to seek orders compelling discovery even before discovery began. The defendants argued that resolving the motion to dismiss first would conserve the parties’ and court’s time and resources and could narrow the scope of discovery.

Ruling

The court denied the defendants’ motion to stay discovery. The endorsement states: “For the reasons stated at the December 17, 2020 status conference, Defendants’ motion to stay is denied.” The provided text does not state those reasons or decide the anticipated motion to dismiss. Judge Paul G. Gardephe signed the endorsement on December 18, 2020.

Effect

The ruling denied the requested pause in discovery. It did not, in the provided text, dismiss any claim, rule on the merits of the discrimination or other claims, or decide the defendants’ anticipated motion to dismiss.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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