Lyman v. New York City Health and Hospitals Corporation
- Paul Engelmayer
- 1:20-cv-04390
- U.S. District Court · Southern District of New York
- 3
Lyman v. New York City Health and Hospitals Corporation: Judge Cave deferred ruling on NYCHHC’s protective-order motion and paused its deadline to answer 116 requests.
Denise Lyman and New York City Health and Hospitals Corporation; Lyman was directed to submit a letter, and NYCHHC’s deadline to respond to the requests was paused.
What happened
In Lyman v. New York City Health and Hospitals Corporation, pro se plaintiff Denise Lyman served the defendant with 116 requests for admission—statements asking the defendant to admit or deny specific facts. NYCHHC asked the court for a protective order concerning those requests.
The court said many requests were simple and narrow, but several were unnecessarily lengthy and complex. It asked Lyman to consider withdrawing or rewriting some requests and to tell the court by August 12, 2021 whether she would do so. If she kept all 116 requests as written, she had to explain why the court should require NYCHHC to answer them.
Judge Sarah L. Cave did not yet rule on NYCHHC’s motion. She held NYCHHC’s deadline to respond to the requests in abeyance—meaning the deadline was paused—until the court resolves the motion, and directed the Clerk to mail Lyman a copy of the order.
The detailed version
- Lyman v. New York City Health and Hospitals Corporation · No. 1:20-cv-04390
- Paul Engelmayer
- Aug. 5, 2021
Background
Pro se plaintiff Denise Lyman served New York City Health and Hospitals Corporation (NYCHHC) with 116 requests for admission under Federal Rule of Civil Procedure 36. NYCHHC filed a motion for a protective order concerning those requests.
Legal framework
The court explained that requests for admission are not generally a discovery tool for obtaining new information. They are a procedure for placing on the record admissions about facts already known to the requesting party and about which there is no real dispute. Each request should be direct, simple, limited to one relevant fact, and specific enough to answer by examining the request itself. A responding party may admit or deny a request, explain in detail why it cannot truthfully do either, assert lack of knowledge in appropriate circumstances, or object when the request is vague.
Court’s review and directions
The court preliminarily reviewed Lyman’s requests. It found that many were simple, narrow factual statements, citing requests 6, 7, 16, 29–33, 36, and 38 as examples. It also found several requests unnecessarily verbose and complex, including requests 4, 5, 14, 40, 52, 55, 61, 97, 102, and 114.
The court asked Lyman to submit a letter by August 12, 2021 stating whether she would withdraw or redraft any requests. If she stood on all 116 requests as drafted, the court directed her to explain why there was good cause to deny NYCHHC’s request for a protective order and require NYCHHC to respond. After receiving Lyman’s letter, the court said it would rule on NYCHHC’s motion.
Disposition
The order did not grant or deny NYCHHC’s motion for a protective order. Instead, Judge Sarah L. Cave deferred a ruling, held NYCHHC’s deadline to respond to the requests in abeyance pending resolution of the motion, and directed the Clerk of Court to mail Lyman a copy of the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.