June Carey Moore v. CHSI EMP LLC

Summary

The United States District Court for the Northern District of Ohio granted in part and denied in part Plaintiff June Carey Moore’s motion to compel discovery in her Fair Labor Standards Act overtime action against CHSI EMP LLC. The court ordered production of unredacted patient-related records under a protective order, concluding that disclosure was authorized for good cause under 42 U.S.C. § 290dd-2, but denied the request concerning additional defense documents and declined to impose discovery sanctions.

Holdings

1. Good cause existed under 42 U.S.C. § 290dd-2(b)(2)(C) to order CHSI to disclose the unredacted patient names and dates of service in the specified records, subject to a protective order and appropriate safeguards.
2. Moore was not entitled to an order compelling further production on her request for all documents on which CHSI based any defense because CHSI represented that it was not currently aware of other responsive documents, and Moore effectively conceded that there was nothing further to compel.
3. Discovery sanctions were not warranted because CHSI's objection to producing unredacted patient names was substantially justified and its handling of the sixth production request was not sufficiently egregious.

Questions Presented

1. Whether CHSI must produce unredacted patient names and dates of service contained in relevant records under the confidentiality protections of 42 U.S.C. § 290dd-2.
2. Whether Moore was entitled to an order compelling CHSI to respond further to her request for all documents supporting CHSI's defenses.
3. Whether discovery sanctions, including expenses or attorney fees, were warranted based on CHSI's objections and discovery responses.

Disposition

other