Brown v. McDonough

CourtDistrict Court, District of Columbia
DecidedFebruary 3, 2025
DocketCivil Action No. 2014-1457
StatusPublished

This text of Brown v. McDonough (Brown v. McDonough) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. McDonough, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

GAYLE D. BROWN

Plaintiff, Case No. 14-cv-1457 (JMC)

v.

TODD HUNTER, Acting Secretary of Veterans Affairs,

Defendant.

MEMORANDUM OPINION

Defendant Todd Hunter, in his official capacity as Acting Secretary of the United States

Department of Veterans Affairs, 1 moves to dismiss pro se Plaintiff Gayle Brown’s lawsuit as a

sanction for her failure to comply with the Court’s orders. 2 ECF 91. Moments after this Court

directed Plaintiff to answer the questions defense counsel posed to her at her deposition, Plaintiff

continued to refuse to answer the questions, told defense counsel “I don’t care what Judge Cobb

says; I really don’t,” ECF 91-3 at 45:17–18, and abruptly left her deposition, id. at 48:18.

Unfortunately, this is the third time that the Court has been called upon to resolve an issue

concerning Plaintiff’s failure to cooperate with her deposition. The Court has provided clear

directives to Plaintiff, resisted imposing monetary sanctions, and warned her that failure to follow

orders may result in the dismissal of her case. Because Plaintiff has made it clear that she “do[es]n’t

care” what this Court orders, id. at 45:17–18, the Court finds that any further orders requiring her

1 At the time the instant motion to dismiss was filed, Denis McDonough served as Secretary of the Department of Veterans Affairs. Pursuant to Fed. R. Civ. P. 25(d), however, when a public officer sued in his official capacity ceases to hold office while an action is pending, “[t]he officer’s successor is automatically substituted as a party.” 2 Unless otherwise indicated, the formatting of citations has been modified throughout this opinion, for example, by omitting internal quotation marks, emphases, citations, and alterations and by altering capitalization. All pincites to documents filed on the docket in this case are to the automatically generated ECF Page ID number that appears at the top of each page. 1 to cooperate with her deposition will be futile. Accordingly, the Court GRANTS Defendant’s

motion to dismiss Plaintiff’s case with prejudice.

I. BACKGROUND

This is a discrimination case that Plaintiff filed against her employer, the Department of

Veterans Affairs. See ECF 15. Plaintiff represents herself pro se. This case has a long history that

predates the Court’s involvement in the matter. In May 2023, after a stay of litigation and an

unsuccessful mediation attempt, this Court granted in part and denied in part Defendant’s motion

for judgment on the pleadings. ECF 69. Discovery opened on September 14, 2023, and was

initially set to close on February 14, 2024. ECF 77. During the litigation, the Court has resolved

various discovery disputes regarding Plaintiff’s deficient responses to Defendant’s discovery

requests and extended case deadlines to allow the Parties to complete discovery. See, e.g., Oct. 23,

2023 Minute Order; Feb. 14, 2024 Minute Order; May 8, 2024 Minute Entry; July 3, 2024 Minute

Entry; July 8, 2024 Minute Entry; Sept. 4, 2024 Minute Order.

Most relevant here are the Parties’ disputes, and the Court’s rulings, concerning Plaintiff’s

deposition. The first deposition dispute the Court addressed occurred in August 2024. On

August 30, 2024, Defendant filed a joint motion requesting a telephone conference. ECF 89. At

that point, discovery was set to close on September 2, 2024. See July 8, 2024 Minute Order.

Defendant sent Plaintiff a notice to appear on August 28, 2024 for a video deposition. ECF 89-2

at 2. According to Defendant, Plaintiff refused to appear for her deposition by video as indicated

in the deposition notice, and instead called into the deposition by telephone. ECF 89 at 2. After a

back and forth, Defendant claimed that Plaintiff hung up the phone on defense counsel as she was

speaking (thus terminating the deposition) and did not respond to subsequent emails attempting to

2 reschedule the deposition. Id. 3 In addition to asking the Court to compel Plaintiff to appear for her

deposition, Defendant asked to extend the deadline to complete discovery and requested that the

Court order Plaintiff to reimburse the defense for the costs associated with the deposition that had

not gone forward. ECF 89 at 3–4, 8. In the joint motion, Plaintiff acknowledged that she called

into the deposition by telephone and claimed that she did not have access to video conferencing.

Id. at 7. She further represented that she told defense counsel about health issues that she was

experiencing because of her employer’s treatment of her and argued that the deposition should

have been canceled. Id. She denied hanging up on defense counsel, but acknowledged that she

disconnected from the call after defense counsel told her that the deposition could not go forward

unless Plaintiff appeared by video. Id.

The Court addressed the joint motion by order. The Court extended discovery until

October 11, 2024. Sept. 4, 2024 Minute Order. The Court also ordered that Defendant contact

Plaintiff by a date certain to propose dates for her deposition, that Plaintiff respond with her

availability by a set deadline, that Plaintiff attend her deposition in-person, and that Plaintiff

produce the outstanding discovery the Court previously ordered her to turn over. Id. The Court

declined to order monetary sanctions, but warned that Plaintiff’s failure to comply with the Court’s

order, which included that she attend her deposition in-person, could result in the dismissal of her

case. Id.

3 Defendant’s motion references other examples of Plaintiff’s failure to comply with her discovery obligations. ECF 89 at 2–3. It is true that the Court has been required to compel Plaintiff to respond to Defendant’s interrogatories, provide interrogatory verifications, and produce documents as requested. See, e.g., May 8, 2024 Minute Entry; July 8, 2024 Minute Order; Sept. 4, 2024 Minute Order. It is not clear to the Court whether Plaintiff has complied with the Court’s prior orders to compel. After reviewing the email correspondence between the Parties concerning Plaintiff’s deficient responses, the Court believes that some of Plaintiff’s prior conduct in discovery may be attributable to the fact that she is pro se. But it is also clear to the Court that Plaintiff has been purposefully difficult to obstruct Defendant’s ability to obtain information from her—including after the Court required her to provide responses. See, e.g., ECF 84- 6 at 6; ECF 86-1 at 3–4; ECF 89-4 at 3–4. This opinion focuses largely on Plaintiff’s conduct related to her deposition, but the Court acknowledges that Plaintiff has not been a cooperative litigant in discovery generally. 3 The second time the Court had to resolve an issue concerning Plaintiff’s cooperation with

her deposition occurred on the day of the scheduled deposition, October 4, 2024. ECF 91 at 3.

Plaintiff showed up to the deposition in-person, but was almost immediately uncooperative.

According to the deposition transcript, she refused to answer basic (and innocuous) background

questions. For example, when defense counsel asked her to confirm whether she lived at a certain

address, Plaintiff responded “I would like to defer to that question and answer it later.” ECF 91-3

at 11:23–25. She gave the same response when asked to confirm her telephone number and provide

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