Dunsmore v. San Diego County Sheriff's Department, et al.

Summary

The court denied without prejudice the plaintiffs’ motion to reopen fact discovery to obtain records and testimony concerning the July 2025 deaths of two incarcerated persons. The court concluded that the requested discovery was overly broad and that the post-cutoff evidence would primarily bear on remedies if plaintiffs prevailed on liability. The court granted plaintiffs’ motion to seal information derived from attorney-eyes-only ADA housing rosters and denied without prejudice defendants’ request for sanctions.

Holdings

1. Plaintiffs did not establish good cause to reopen discovery for the broad discovery sought, so the motion to reopen discovery was denied without prejudice.
2. The denial was without prejudice, and plaintiffs could meet and confer with defendants and then seek a discovery conference regarding a more narrowly tailored set of records.
3. Good cause supported sealing the information because it was derived from ADA rosters that the court had ordered produced as attorney-eyes-only material pursuant to the parties' ADA settlement.
4. The request for sanctions was denied without prejudice because sanctions must be sought through a properly noticed motion giving the opposing party an opportunity to respond.

Questions Presented

1. Whether plaintiffs established good cause under Federal Rule of Civil Procedure 16(b)(4) to reopen fact discovery for broad discovery concerning two July 2025 deaths.
2. Whether information in plaintiffs' counsel's declaration drawn from attorney-eyes-only ADA rosters should be filed under seal.
3. Whether defendants' request for sanctions should be granted when it was not presented through a properly noticed motion.

Disposition

other