Boudreau v. Petit, et al.

Summary

The United States District Court for the District of Rhode Island grants defendants’ motion for a protective order concerning plaintiff’s new interrogatories and document requests, and addresses the related extension of time to respond. The court finds good cause under Federal Rule of Civil Procedure 26(c), concluding that the interrogatories exceed the permissible limit and that the discovery is duplicative, overbroad, insufficiently targeted, or disproportionate. The court permits responses to certain document requests that defendants had begun addressing but protects Warwick from responding to the interrogatories and specified remaining requests.

Holdings

1. Defendants demonstrated good cause for protection because the thirty-three interrogatories exceeded the twenty-five-interrogatory limit, Plaintiff had already been denied leave to expand that limit, and the interrogatories were independently overbroad, irrelevant, duplicative, and disproportionate.
2. The court granted a limited protective order as to document requests that were duplicative, irrelevant, overbroad, disproportionate, untethered to the facts of the case, or directed to privileged material, but excluded requests to which Warwick was already in the process of responding.
3. The court exercised its discretion to waive strict compliance with Rule 26(c)(1)'s meet-and-confer certification requirement and declined to deny the motion on that ground.
4. The court denied Plaintiff's request to extend the fact-discovery deadline and denied Defendants' request to require advance judicial approval of any future discovery.

Questions Presented

1. Whether Defendants showed good cause for a protective order under Federal Rule of Civil Procedure 26(c)(1) concerning Plaintiff's new interrogatories and document requests.
2. Whether Plaintiff could serve more than twenty-five interrogatories by naming the City of Warwick and the Warwick Police Department separately.
3. Whether the motion should be denied because Defendants failed to certify that they had met and conferred as required by Federal Rule of Civil Procedure 26(c)(1).
4. Whether Plaintiff was entitled to extend the fact-discovery deadline or obtain advance judicial approval for future discovery.

Disposition

other