Georges F. de Laire v. Gary Michael Voris, et al.

2021 DNH 186
CourtDistrict Court, D. New Hampshire
DecidedDecember 9, 2021
Docket21-cv-131-JD
StatusPublished
Cited by1 cases

This text of 2021 DNH 186 (Georges F. de Laire v. Gary Michael Voris, et al.) 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
Georges F. de Laire v. Gary Michael Voris, et al., 2021 DNH 186 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Georges F. de Laire

v. Civil No. 21-cv-131-JD Opinion No. 2021 DNH 186 Gary Michael Voris, et al.

O R D E R

The Very Reverend Georges F. de Laire, J.C.L., who serves

as the Judicial Vicar and the Vicar for Canonical Affairs for

the Diocese of Manchester, brings a defamation claim against

Gary Michael Voris, Anita Carey, and St. Michael’s Media, Inc.

a/k/a Church Militant. In support, de Laire alleges that the

defendants published defamatory articles and a video about him

because of a doctrinal dispute between a religious group in New

Hampshire and officials of the Catholic Church. The defendants

served the Diocese of Manchester, which is not a party in the

case, with a subpoena under Federal Rule of Civil Procedure 45,

seeking documents for discovery, and now move to compel the

Diocese to comply with the subpoena. The Diocese objects.

Standard of Review

A subpoena to a nonparty must comport with the scope of

discovery under Federal Rule of Civil Procedure 26(b)(1). Katz

v. Shell Energy N. Am. (US), LP, --- F. Supp. 3d ---, 2021 WL 4477626, at *1 (D. Mass. Sept. 30, 2021). In that regard, the

documents or information subject to the subpoena must not be

privileged, must be relevant to a party’s claim or defense, and

must be proportional to the needs of the case. Fed. R. Civ. P.

26(b)(1). Further, the party who issues the subpoena “must take

reasonable steps to avoid imposing undue burden or expense on a

person subject to the subpoena.” Fed. R. Civ. P. 45(d)(1). In

determining whether the subpoena imposes an undue burden, courts

examine the relevance of and need for the documents sought, the

benefits of the request, and the expense and inconvenience of

compliance. Katz, 2021 WL 4477626, at *1.

Background

As the Judicial Vicar and the Vicar for Canonical Affairs

for the Diocese of Manchester, de Laire serves with the Bishop

of the Diocese of Manchester in a judicial body, the Tribunal,

for the Diocese of Manchester.1 As part of his official duties,

de Laire has had interactions since 2016 with a religious group

in New Hampshire known as the Slaves of the Immaculate Heart of

Mary, incorporated as the Saint Benedict Center, Inc. He

1 The Diocese states that it is composed of the Most Reverend Peter Anthony Libasci and the Roman Catholic Bishop of Manchester, a Corporation Sole.

2 eventually placed sanctions on the group because of a doctrinal

dispute with the Catholic Church.

The defendant, Church Militant, is identified as a Michigan

not-for-profit corporation that posts articles, videos, and

podcasts on a website, churchmilitant.com. Gary Michael Voris

is president of Church Militant. Anita Carey was a reporter for

Church Militant from March of 2017 to November of 2019.

Church Militant published an article about de Laire dated

January 17, 2019, that criticized de Laire’s role in the

church’s interactions with the Saint Benedict Center and the

sanctions imposed. After that article was published, Voris

travelled to New Hampshire in April of 2019 to interview members

and supporters of the Saint Benedict Center about de Laire’s

actions and made a video about de Laire, which was published on

April 15, 2019. On June 25, 2019, Church Militant published

another article, which was written by Anita Carey, that

challenged de Laire’s interpretation of canon law, his

interactions with the Saint Benedict Center, and reported that

complaints had been lodged against him, among other things.

De Laire brought suit against Church Militant, Voris, and

Carey, alleging that the articles and video defamed him. The

defendants served a subpoena on the Diocese of Manchester with

six requests for documents. The Diocese provided some documents

but also objected to the requests.

3 Discussion

The defendants move to compel the Diocese to comply with

their requests in the subpoena that are numbered 1, 2, 3, and 5.

The Diocese objects.

A. Request 1

In Request 1, the defendants sought:

All documents related to or concerning any complaint made against or about de Laire, by any person or entity, concerning any manner, at any time. “Complaint” is to be given its broadest possible meaning and encompasses any document where de Laire’s performance or behavior is questioned or criticized.

Doc. no. 46-2, at *2. The Diocese provided the following

response:

The Subpoena Recipients incorporate and restate all of the objections above. They state further that the request is vague, ambiguous, overly broad, and unduly burdensome to the extent that "complaint" is undefined, disproportional and not tailored to the subject matter in the underlying suit, not reasonably calculated to discover admissible evidence, and does not describe with reasonable particularity the topics for examination.2

2 The defendants did not provide the Diocese’s general objections that were in an introductory section of their responses. When challenged for failing to do so, the defendants argued that the Diocese should not have included boilerplate objections. The matters addressed under the heading “General Objections” are not “boilerplate” and instead include issues about the scope of a subpoena under Rule 45, privilege, privacy of health information, and confidentiality. The defendants were required to submit that section.

4 Id. In its objection, the Diocese contends that the defendants

amended the scope of Request 1, which is demonstrated by an

email from defendants’ counsel dated July 2, 2021. The

defendants do not acknowledge that amendment in their motion.

The defendants assert that the request is relevant to de

Laire’s allegation that they defamed him by reporting that “at

least three complaints against de Laire have been filed with the

Holy See . . . [t]ogether they allege corruption, abuse of

office, grave violations of the law, and incompetence as a

canonist.” Doc. no. 1, ¶ 58. They further assert that they

specified that they were looking for annulment complaints and

that the Diocese did not deny such complaints existed, but the

Diocese has not produced them. They state that the Diocese said

it searched for other complaints but found none, when the Saint

Benedict Center produced complaints that its members filed

against de Laire.

As written, Request 1 is overbroad and not proportional to

the needs of the case. If the request has been narrowed or

redefined by agreement, which appears to be the case, that would

be material to the court’s consideration of whether to enforce

the subpoena with respect to Request 1. Further, to the extent

the defendants are aware of and are seeking specific complaints

or documents, they should address those matters directly rather

5 than in a footnote. As presented, however, the Diocese cannot

be compelled to provide additional responses to Request 1.

B. Request 2

Request 2 states: “De Laire’s employment or personnel

file.” Doc. no. 46-2, at *2. The Diocese responded as follows:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

de Laire v. Voris
D. New Hampshire, 2021

Cite This Page — Counsel Stack

Bluebook (online)
2021 DNH 186, Counsel Stack Legal Research, https://law.counselstack.com/opinion/georges-f-de-laire-v-gary-michael-voris-et-al-nhd-2021.