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S.D.N.Y.Procedural orderFiled July 7, 2023

Naula Ndugga v. Bloomberg L.P.

Judge
Gregory Woods
Docket
1:20-cv-07464
Court
U.S. District Court · Southern District of New York
Pages
1
DiscoveryCivil ProcedureEmployment
In one sentence

In Naula Ndugga v. Bloomberg L.P., Judge Gorenstein ordered defendants to produce certain human-resources data in a discovery dispute.

Who this affects

Naula Ndugga and the defendants, regarding production of human-resources data about editors and reporters.

What happened

Naula Ndugga, a producer, asked for human-resources data about editors and reporters. The opinion does not describe the underlying claims.

The court found the data relevant because the Editorial Management Committee had at least some involvement in compensation decisions for all three job categories. It ordered defendants to produce the editors’ and reporters’ data, while allowing them to raise unusually burdensome requests involving a limited subset of the data.

Judge Gabriel W. Gorenstein issued the July 7, 2023 order. The order addressed discovery only and did not decide the underlying claims.

The detailed version

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

Case
Naula Ndugga v. Bloomberg L.P. · No. 1:20-cv-07464
Judge
Gregory Woods
Date
July 7, 2023

Background

The court considered the parties’ letters concerning Naula Ndugga’s request for human-resources data about editors and reporters. The opinion states that Ndugga was a producer. It does not provide further details about the underlying claims.

Ruling

The court explained that, to establish that data about editors and reporters was relevant to a producer’s claims, Ndugga had to show some common decision-making group or process that operated across those job categories. The court accepted that the Editorial Management Committee had only sporadic involvement in compensation decisions for producers, editors, and reporters. It nevertheless found that the committee had at least some involvement and that defendants had offered only conclusory statements about the burden of producing the information.

The court therefore ordered production of the human-resources data concerning editors and reporters. It also directed defendants to discuss with Ndugga any particularly burdensome limited subset of the data and try to reach an agreement. If a dispute remained about the burden of producing a limited subset, defendants could bring that issue to the court.

Effect of the Order

This was a discovery order. It resolved the request for the specified data but did not decide the merits of the underlying employment dispute. The order was issued by United States Magistrate Judge Gabriel W. Gorenstein.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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