Denise Guerrero v. Albany Med Health System

Summary

The United States District Court for the Northern District of New York denied pro se Plaintiff Denise Guerrero’s motion to compel discovery in her remaining ADA retaliation claim against Albany Med Health System. The court found that most challenged discovery requests concerned dismissed claims, declined to order production of documents that Defendant represented did not exist, and directed Defendant to provide information about its search for documents responsive to one request. The court also extended the discovery deadline to October 30, 2026, and the dispositive-motion deadline to December 30, 2026.

Holdings

1. Discovery seeking comparator information, complaints concerning Warner, and ADA training materials was not relevant to the surviving ADA retaliation claim based on Plaintiff's request for an accommodation because it related, if at all, to claims that had already been dismissed.
2. The court would not order Defendant to produce documents that do not exist absent evidence that Defendant was withholding relevant documents in its possession.
3. Although the motion to compel was denied, Defendant was directed to provide Plaintiff with further information concerning the steps taken to search for documents responsive to Request for Production No. 3, including the custodians and locations searched.
4. The parties remain obligated under Federal Rule of Civil Procedure 26(e)(1)(A) to supplement their productions if responsive documents are later located.

Questions Presented

1. Whether Plaintiff was entitled to compel responses to interrogatory and document requests seeking comparator information, complaints about a former supervisor, and ADA training materials when those requests related primarily to claims previously dismissed from the action.
2. Whether Defendant should be ordered to produce additional documents concerning the handling of Plaintiff's accommodation request when Defendant represented that it had searched for and produced responsive documents.
3. Whether Defendant should provide further information about the custodians and locations searched for documents responsive to Request for Production No. 3.
4. Whether the discovery and dispositive-motion deadlines should be extended.

Disposition

other