BURGESS v. CENTRAL BUCKS SCHOOL DISTRICT

CourtDistrict Court, E.D. Pennsylvania
DecidedNovember 6, 2023
Docket2:23-cv-01369
StatusUnknown

This text of BURGESS v. CENTRAL BUCKS SCHOOL DISTRICT (BURGESS v. CENTRAL BUCKS SCHOOL DISTRICT) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BURGESS v. CENTRAL BUCKS SCHOOL DISTRICT, (E.D. Pa. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

ANDREW BURGESS : CIVIL ACTION : v. : : CENTRAL BUCKS : SCHOOL DISTRICT, et al. : NO. 23-1369

O P I N I O N

SCOTT W. REID DATE: November 6, 2023 UNITED STATES MAGISTRATE JUDGE

As explained below, plaintiff Andrew Burgess’s Motion to Compel will be granted in part and denied in part. Defendants’ Motion for a Protective Order will be denied. First, however, some review is provided as to the appropriate conduct of counsel and clients in the discovery process. It is dismaying that a review of such basic standards is necessary. Surely, all counsel involved in this case are familiar with the principles set forth below. Let the forthcoming, however, serve as a reminder of the standards imposed by the Federal Rules of Civil Procedure, and expected and enforced by this Court. I. Principles Applicable to the Discovery Process A. Signature on Documents Federal Rule of Civil Procedure 26(g) requires an attorney’s signature on all discovery documents, such as the responses to requests for production of documents at issue in Burgess’s motion. It imposes an “affirmative duty to engage in pretrial discovery in a responsible manner that is consistent with the spirit and purpose of the [Rules].” Fed. R. Civ. Pr. 26(g), Comments to 1989 Amendment. The signature certifies that the lawyer has made a reasonable effort to assure that the client has provided all the information and documents that are available to the client and that are responsive to the discovery demand. Id. As an obviously frustrated judge in the District of New Jersey has explained: Rule 26(g) should not be treated like the proverbial stepchild. Lawyers should not be able to serve boilerplate, meritless and frivolous objections with impunity. Lawyers should not have to wait until after … motions to obtain plainly relevant information. Lawyers should not act like “potted plants” and accept implausible representations that no responsive documents or discovery exists. These actions have to stop.

Younes v. 7-Eleven, Inc., 312 F.R.D. 692, 706 (D.N.J. 2015). The Younes judge further observed: “Parties cannot be permitted to jeopardize the integrity of the discovery process by engaging in halfhearted and ineffective efforts to identify and produce relevant [discovery].” Id. at 706-7 (quoting Bratka v. Anheuser-Busch Co., Inc., 164 F.R.D. 448, 463 (S.D. Ohio 1995)). Nor is counsel’s blind reliance on a client’s production efforts adequate. Bracy v. Valencia, Civ. A. No. 19-1385, 2022 WL 1570812 at *13 (W.D. Pa. May 18, 2022). While an attorney need not supervise every aspect of a client’s document production, the attorney is responsible for coordinating the client’s efforts so that responsive documents are produced. Id. (quoting Younis, supra, at 312 F.R.D. 707). If the 26(g) certification duty is violated without substantial justification, the Court “must” impose a sanction on the signer, the client, or both, either upon motion or on its own initiative. Fed. R. Civ. Pr. 26(g)(3). However, it is not only Rule 26 which imposes a discovery duty enforceable by sanction. Federal Rule 37(2) permits sanctions upon a motion from the opposing party for failure to comply with a discovery order. Further, Rule 11 imposes a duty of certification on documents presented to a court, such as a response to a discovery motion, that “to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances,” all factual contentions and denials of factual contentions are supported, warranted, and not presented for any improper purpose. Here again, sanctions may be imposed upon motion, or on the court’s initiative. Fed. R. Civ. Pr. 11(c). Finally, an attorney found to have “multiplied proceedings” in bad faith or by intentional misconduct, is subject to personal sanction under 28 U.S.C. §1927. See In re

Prudential Ins. Co. America Sales Practice Litigation, 278 F.3d 175, 188 (3d Cir. 2002). B. Supplements to Discovery Responses Several times in their discovery responses, Defendants state that they “preserve their right to supplement” their production. Defendants do not have such a “right.” Rather, they have a duty. Fed. R. Civ. Pr. 26(c); and see Walsh v. East Penn Manufacturing Co. Civ. A. No. 18- 1194, 2021 WL 1318003 at *2 (E.D. Pa. April 8, 2021) (“Rule 26(e) does not give East Penn permission to supplement its prior discovery production – it expressly imposes a duty to do so on the producing party”). Thus, a defendant is not entitled to provide production at its leisure or convenience. As explained above, the signatures on Defendants’ responses to Burgess’s Requests for Production

of Documents entitle Burgess to rely on a representation – upon pain of sanction – that all the information and documents available have already been produced. However, if other material becomes available, Defendants have a continuing duty to supplement their responses. C. A Privilege Log is Required There can be no doubt that Federal Rule of Civil Procedure 26(b)(5) imposes a duty upon a party seeking to protect discovery material as privileged to prepare a privilege log: Once a party withholds responsive documents on the basis of an assertion of privilege, “[a] log describing those documents not made available is in order.” See Tex. Capital Corp. v. Fleet Capital Corp., Civ. A. No. 03-1605, 2004 WL 1472778 at *1 (E.D. Pa. June 14, 2004); Apollo v. Pa. Convention Center Auth., Civ. A. No. 11-6684, 2018 WL 6795978 at *4 (E.D. Pa. Dec. 23, 2013) (directing producing parties to produce a rolling privilege log contemporaneously with their production of documents); New Park Entm’t L.L.C. v. Elec. Factory Concerts, Inc., Civ. A. No. 98-775, 2000 WL 62315 at *8 (E.D. Pa. Jan. 13, 2000) (“Courts in this district have held that parties must comply with the requirements of Fed. R. Civ. P. 26(b)(5) by providing a privilege log.” (citing Northwood Nursing and Convalescent Home, Inc. v Cont’l Ins. Co., 161 F.R.D. 293, 299 (E.D. Pa. 1995)).

Parks, LLC. v. Tyson Foods, Inc., Civ. A. No. 15-946, 2015 WL 5042918 at *4 (E.D. Pa., Aug. 26, 2015). Further, “if a party fails to timely produce a privilege log or other adequate description of the basis for withholding specific documents on the grounds of privilege, such failure may result in a waiver of the asserted privilege.” Id. (citing Rhoads Indus., Inc. v. Bldg. Materials Corp. of America, 254 F.R.D. 216, 221 (E.D. Pa. 2008)). It could also be noted that, in a case of this limited scope, a court would be extremely unlikely to find that the preparation of a privilege log is unduly burdensome. See Northwood Nursing & Convalescent Home, Inc. v. Continental Ins. Co., 161 F.R.D. 293, 299 (E.D. Pa. 1995), (citing Transamerica Computer Co. v. IBM, 573 F.2d 646, 649 (9th Cir. 1978) (1.7 million potentially privileged documents)). D. Duane Morris The law firm of Duane Morris is not a party in this employment discrimination litigation and does not represent any party in this litigation.

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BURGESS v. CENTRAL BUCKS SCHOOL DISTRICT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burgess-v-central-bucks-school-district-paed-2023.