Summary
This United States District Court order denies the plaintiff’s motion to compel discovery responses from the defendant Veterans Affairs Medical Center. The magistrate judge analyzed several interrogatories and requests for production under Federal Rule of Civil Procedure 26(b) and Rule 34, concluding that the requested information was either irrelevant to the plaintiff’s Privacy Act claim regarding the accuracy of specific medical records, overly broad, or vague. The court emphasized that the plaintiff failed to demonstrate how the sought-after documents would prove inaccuracies in the disputed March and April 2020 medical records.
Topics
Practice areas
Questions Presented
- Whether the plaintiff’s interrogatories and requests for production are relevant and proportional under Fed. R. Civ. P. 26(b) and therefore subject to a motion to compel
- Whether the motion to compel should be denied as the requests are overbroad, vague, and unrelated to the privacy‑act claim
Holdings
- The court denied the motion to compel because the requests were irrelevant, overbroad, vague, and not proportional to the issues presented in the privacy‑act claim.
Key quotations
““The proponent of a motion to compel discovery bears the initial burden of proving that the information sought is relevant.””
““And the purpose of a motion to compel discovery is not to challenge the truthfulness of the response but rather to compel a party to answer the interrogatory.””
Factual background
Plaintiff Steven Roger Mannon seeks correction of two VA medical records created in March and April 2020 that he alleges inaccurately describe his behavior and compliance. He moved to compel the VA to answer interrogatories identifying staff and to produce documents such as DBC reports and internal communications.
Procedural history
Plaintiff filed a motion to compel the government to produce responses to interrogatories and requests for production related to alleged inaccuracies in VA medical records. The magistrate judge denied the motion.