Jose Guadalupe Rocha v. Matt Winden

Summary

The United States District Court for the District of Colorado grants in part and denies in part Jose Guadalupe Rocha’s motion to reopen discovery, compel production, and seek sanctions. The court finds that Rocha did not demonstrate good cause or diligence warranting the broader discovery and depositions requested, but permits limited discovery concerning Centennial Correctional Facility classification records that the defendant agreed were relevant. The order addresses discovery under Rule 16(b)(4), the relevance and proportionality of requested materials, and the relationship between the discovery dispute and the defendant’s pending qualified-immunity summary-judgment motion.

Holdings

1. Rocha failed to show good cause to reopen discovery for the broad categories of documents and depositions he sought because the record demonstrated a lack of diligence, the requested discovery would prejudice Winden and expand the case, and the discovery was unlikely to lead to relevant admissible evidence on qualified immunity.
2. Limited good cause existed to reopen discovery so that Winden could produce the relevant Centennial Correctional Facility Internal Classification Committee minutes and related documents, followed by five interrogatories limited to those documents.
3. Sanctions were unwarranted because the record did not establish obstruction, misrepresentation, or other sanctionable conduct by Winden or his counsel.

Questions Presented

1. Whether Rocha established good cause under Federal Rule of Civil Procedure 16(b)(4) to reopen discovery broadly for additional documents and depositions.
2. Whether the defendant's concession that limited Centennial Correctional Facility classification documents were relevant justified narrowly limited additional discovery.
3. Whether Winden or his counsel engaged in sanctionable discovery conduct under Federal Rule of Civil Procedure 37.

Disposition

other