Cintron v. Albert Einstein College of Medicine

Nature of the matter

The provided text contains a defendants’ letter requesting a conference about an anticipated motion for a protective order under Federal Rule of Civil Procedure 26(c), together with Amanda Cintron’s deposition notice. It also contains the court’s direction that the parties proceed with the deposition and preserve disputed questions and answers for later consideration.

Background

Cintron noticed a deposition of Albert Einstein College of Medicine’s corporate representative under Federal Rule of Civil Procedure 30(b)(6). The notice listed 26 topics, although Cintron later proposed limits to some topics and withdrew others. The deposition was scheduled for May 24, 2022, by videoconference.

The defendants stated that they had objected to the original notice and to later amended versions. They sought protection concerning Topics 3, 6–7, 9–13, 15–21, and 24. According to the defendants, Topics 9–11 and 24 sought overly broad information about possible comparison employees across the organization, including discipline, performance, and disability-discrimination or retaliation concerns. They argued that preparing a corporate witness to address this information would be unreasonable and burdensome and could disclose sensitive information about other employees.

The defendants also argued that Topics 3, 6, 7, and 13 sought information about Cintron’s concerns, performance, accommodation-related discussions, and termination that had already been or would be covered by witnesses with direct knowledge. They contended that Topic 12 sought information Cintron herself possessed or that was already reflected in produced documents. Finally, they argued that Topics 15–21 improperly sought “discovery on discovery”—information about document searches, preservation, email retention, and document authenticity—without any allegation that evidence had been lost or improperly withheld.

Court’s action

The court directed the parties to conduct the deposition and to mark questions and answers for a future ruling. The court reminded the parties that discovery must be relevant to the claims and defenses and proportional to the needs of the case. It stated that it would address remaining discovery issues and issues arising during the deposition at a telephone conference scheduled for May 31, 2022, at 3:45 p.m.

The provided text does not state that the court granted or denied the anticipated protective order, and it does not resolve the underlying employment or disability-discrimination claims.