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S.D.N.Y.Procedural orderFiled May 4, 2023

Harris v. NYC Human Resources Administration

Judge
John Cronan
Docket
1:20-cv-02011
Court
U.S. District Court · Southern District of New York
Pages
2
DiscoveryCivil ProcedurePro Se
In one sentence

In Harris v. NYC Human Resources Administration, Judge Netburn denied Harris permission to depose Mayor Eric Adams after fact discovery closed.

Who this affects

Mary L. Harris was not permitted to depose Mayor Eric Adams; the parties remained subject to the court’s summary-judgment briefing schedule.

What happened

In Harris v. NYC Human Resources Administration, pro se Plaintiff Mary L. Harris asked to depose New York City Mayor Eric Adams after fact discovery had ended. Defendants opposed the request.

The court explained that deposing a high-ranking government official requires exceptional circumstances, such as unique firsthand knowledge of the claims or information unavailable through less burdensome methods. The court found no reason to believe Mayor Adams had relevant information, because the allegations mostly concerned events from 2016 through 2019, before he became mayor, and did not concern him or his role as Brooklyn Borough President.

Judge Sarah Netburn denied Harris’s request to depose Mayor Adams and ordered the parties to follow the existing summary-judgment briefing schedule. The court also identified a free legal clinic and a possible settlement conference as available resources.

The detailed version

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

Case
Harris v. NYC Human Resources Administration · No. 1:20-cv-02011
Judge
John Cronan
Date
May 4, 2023

Background

After fact discovery closed, pro se Plaintiff Mary L. Harris asked for permission to take depositions of several people, including New York City Mayor Eric Adams. Harris later told the court that she wanted to depose only Mayor Adams. She said he might have some ability to resolve the issue. Defendants opposed the request.

The court had previously explained that reopening discovery would require Harris to pay the costs of the deposition, including court-reporter and transcription fees, and to conduct the deposition under the Federal Rules of Civil Procedure.

Court’s analysis

The court applied the rule that a party seeking to depose a high-ranking government official must show exceptional circumstances. Those circumstances can include the official’s unique firsthand knowledge of the claims or the unavailability of the necessary information through less burdensome or intrusive means.

The court found no basis to believe that Mayor Adams had information about the issues in the case, much less unique firsthand knowledge. The complaint’s allegations mostly concerned events from 2016 through 2019, when Harris worked at the New York City Human Resources Administration. The allegations did not concern Adams or his role as Brooklyn Borough President. The court also noted that Adams became mayor on January 1, 2022.

Ruling and case schedule

The court DENIED Harris’s request for leave to depose Mayor Adams. It ordered the parties to comply with the summary-judgment briefing schedule: defendants’ motion was due June 5, 2023; Harris’s opposition was due July 20, 2023; and any reply was due August 3, 2023. The court encouraged Harris to contact the New York Legal Assistance Group free legal clinic for help opposing the motion and stated that the parties could contact the court to arrange a settlement conference.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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