Griffith v. Metropolitan Transit Authority - New York City Transit

Background

Claudette Griffith moved for reconsideration of the court’s January 6, 2021 discovery order. That earlier order denied her motion to compel production of documents related to a non-party employee of the defendants. Griffith also sought to reopen discovery by modifying the scheduling order.

Arguments and analysis

A motion for reconsideration may be granted if there has been a change in controlling law, the court overlooked controlling decisions or facts, new evidence warrants revisiting the decision, or reconsideration is needed to correct a clear error or prevent serious unfairness.

Griffith argued that events occurring between November 20 and December 17, 2020 showed good reason to modify the scheduling order and reopen discovery. She also argued that refusing to order production would result in serious unfairness. The court rejected those arguments. It stated that Griffith’s additional facts did not address a central basis for the earlier ruling: she had known since June 5, 2020 that the defendants objected to producing the requested materials. The court concluded that its six-factor good-cause analysis would remain unchanged even if it considered the additional facts. Griffith therefore had not shown good reason to reopen discovery.

The court also noted that Griffith did not argue that controlling law had changed or that new evidence had been discovered. It rejected her serious-unfairness argument because the requested materials had questionable evidentiary value and she had five months between learning they would not be produced and the discovery deadline to bring the issue to the court.

Disposition

Judge Katharine H. Parker denied Griffith’s letter motion for reconsideration. The opinion does not state any additional disposition of the underlying case.