Ako Burrell v. Tia Van Winkler, N. Pezdek, D. Traglia, LaPorte, D. Bektic and Pelligrino

Summary

The United States District Court for the Northern District of New York denied Ako Burrell’s motions to compel discovery and for admissions based on insufficient answers or objections. The court held that Burrell failed to comply with Local Rule 37.1’s meet-and-confer requirements and that defendants had timely fulfilled their discovery obligations. The court also found that Burrell’s document requests were overly broad and insufficiently specific and that his requests for admission did not comply with Federal Rule of Civil Procedure 36(a)(2).

Holdings

1. A party seeking an order compelling discovery in the Northern District of New York must make good-faith efforts to resolve or narrow discovery disputes and confer in detail with the opposing party before filing the motion; plaintiff failed to satisfy that requirement.
2. Defendants complied with the Court's scheduling order and served their initial disclosures and discovery responses timely; plaintiff was not entitled to an order compelling further responses absent a specific, properly raised dispute.
3. Document requests that lack a reasonable degree of specificity and are overly broad are not proper subjects of a motion to compel, particularly when the requests are not limited to relevant claims or acts.
4. A request for admission must separately state each matter and separately present each document whose genuineness is at issue; plaintiff's compilation of more than 300 pages did not comply with Rule 36(a)(2), so defendants' objection was proper.

Questions Presented

1. Whether plaintiff's motions to compel discovery should be denied for failure to comply with N.D.N.Y. Local Rule 37.1's meet-and-confer requirements.
2. Whether defendants complied with their discovery obligations under the Court's scheduling order and the Federal Rules of Civil Procedure.
3. Whether plaintiff's document requests were sufficiently specific and proportional to support an order compelling production.
4. Whether plaintiff's request for admissions complied with Federal Rule of Civil Procedure 36(a)(2).

Disposition

other