Francisco J. Reyes Caparrós v. Jefferson Beauregard Sessions, III Attorney General of the United States

2018 DNH 093P
CourtDistrict Court, D. New Hampshire
DecidedMay 4, 2018
Docket15-cv-2229-JNL
StatusPublished

This text of 2018 DNH 093P (Francisco J. Reyes Caparrós v. Jefferson Beauregard Sessions, III Attorney General of the United States) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Francisco J. Reyes Caparrós v. Jefferson Beauregard Sessions, III Attorney General of the United States, 2018 DNH 093P (D.N.H. 2018).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF PUERTO RICO

Francisco J. Reyes Caparrós

v. Civil No. 3:15-cv-2229-JL Opinion No. 2018 DNH 093P

Jefferson Beauregard Sessions, III Attorney General of the United States

MEMORANDUM ORDER

Plaintiff Francisco J. Reyes Caparrós brings a single claim

under Title VII of the Civil Rights Act of 1964, see 42 U.S.C.

§ 2000e-16, alleging that the United States Attorney’s Office

for the District of Puerto Rico retaliated against him for

engaging in protected activity between 2012 and his resignation

in 2015. Before the court are the parties’ several motions in

limine seeking to exclude a variety of evidence and areas of

inquiry from the upcoming trial. The court addresses each

motion in turn.

The court reminds the parties that these rulings are made

without prejudice to revisiting particular issues in response to

circumstances that might arise during trial. Furthermore, these

rulings are limited to grounds argued in the parties’ filings

and raised at the final pretrial conference. The court reserves

the right to assess other factors at trial, such as hearsay,

authenticity, and best evidence, see Fed. R. Evid. 800 et seq., 900 et seq., and 1000 et seq., and where appropriate, arguments

and grounds not raised by counsel.

Plaintiff’s motions

A. Plaintiff’s motion in limine1

Reyes moves to exclude two categories of evidence on the

basis that it was not timely disclosed. A party must disclose

“the name . . . of each individual likely to have discoverable

information -- along with the subjects of that information --

that the disclosing party may use to support its claims or

defenses” and “all documents . . . that the disclosing party has

in its possession, custody, or control and may use to support

its claims or defenses,” unless the witness or information

“would be solely for impeachment.” Fed. R. Civ.

P. 26(a)(1)(A)(i)-(ii). A party who fails to make such a

disclosure “is not allowed to use that information or witness to

supply evidence . . . at a trial, unless the failure was

substantially justified or is harmless.” Id. Rule 37(c)(1). As

the plaintiff acknowledges, this “preclusion is not a strictly

mechanical exercise; district courts have some discretion in

deciding whether or not to impose that onerous sanction.”2

1 Document no. 122. 2 Plaintiff’s Mot. in Limine (doc. no. 122) at 3-4.

2 Santiago-Díaz v. Laboratorio Clínico, 456 F.3d 272, 276 (1st

Cir. 2006).

Documents. First, Reyes seeks to exclude the documents

identified at entries 203-245 and 249-251 of the defendant’s

exhibit list, which the defendant produced to the plaintiff on

August 25, 2017, after the close of discovery in this case.

Both the character of the evidence and intervening circumstances

weigh against exclusion on this basis, however.

The defendant characterizes the majority of these exhibits

as documents that “pertain solely to damages,” which it offers

“to meet its burden of proving Plaintiff’s failure to mitigate

and to establish Plaintiff’s post-resignation earnings for

purposes of obtaining an offset against any damages award in

this case.”3 Specifically, they include newspaper classifieds,

YouTube videos posted by the plaintiff after his resignation,

his LinkedIn profiles and the Facebook page of a law firm where

he worked after his resignation, and information concerning

lawyers’ salaries in Puerto Rico.4 The only non-public-facing

documents appear to be human resource documents concerning his

resignation and his salary at that time.5 Many of these

3 Defendant’s Obj. (doc. no. 141) at 2. 4 Id. at 2-3. 5 Id. at 2.

3 documents were available to the plaintiff during the discovery

period because they were (1) publicly available and relevant to

his case, or, more particularly, (2) created by him.

Of course, a party’s duty to produce documents under

Rule 26 is not abrogated by the documents’ public availability.

In this case, however, it appears that the plaintiff could not

only have obtained many of these documents independently (in

part, at least, because he created them), but also that he never

issued requests for production that would encompass them.6 Nor

has he identified any witness he would have deposed had the

documents been produced sooner, or any other specific prejudice

he may face at trial as a result of their late production,

beyond any general prejudice introduced by that late production.

That general prejudice plays less of a role here in light

of the circumstances intervening between the defendant’s

production and the impending trial. Trial in this action was

originally scheduled for September 18, 2017. Had it taken place

as scheduled, the plaintiff and his counsel would have been

afforded a relatively (albeit not impossibly) short time to

review and address the documents produced on August 25. As it

stands, however, the impact on Puerto Rico of a series of

hurricanes that season necessitated continuing the trial for

6 Id. at 6.

4 nearly nine months. The court acknowledges, in light of a lack

of electricity and internet connectivity, that plaintiff’s

counsel has not had consistent access to trial-related materials

during that time. The plaintiff has nevertheless had ample

opportunity to adapt his trial preparation strategy and tactics

to account for these documents, or to ask for an opportunity to

conduct additional discovery. He has made no such request. The

plaintiff’s motion to exclude these documents due to their late

production is therefore denied.

While the court is thus disinclined to exclude these

documents on timeliness grounds, to the extent the documents are

(as the defendant represents) relevant only to the plaintiff’s

claims for front and back pay, and his mitigation of those

damages, they may be excluded from trial on relevance grounds.

See Fed. R. Evid. 401. As discussed more fully infra Part II.D,

to the extent such damages may be available to the plaintiff in

equity, and should he prevail at trial, the court will reserve

those issues for a post-trial damages hearing.

Witnesses. Second, Reyes seeks to preclude ten of the

defendant’s 29 proposed witnesses from testifying because they

were not identified as potential witnesses in the defendant’s

disclosures under Rule 26. As discussed supra, a party has a

duty to disclose “each individual likely to have discoverable

information” during the discovery period, Fed. R. Civ.

5 P. 26(a)(1)(A)(i), and to supplement those disclosures “in a

timely manner if the party learns that in some material respect

the disclosure or response is incomplete or incorrect, and if

the additional or corrective information has not otherwise been

made known to the other parties . . . .” Id. Rule 26(e)(1)(A).

At the same time, “Federal Rule of Civil Procedure

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