Giannerini v. Embry-Riddle Aeronautical University, Inc.

District Court, M.D. Florida·Decided November 20, 2023·No. 6:22-cv-02075·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

MARISSA GIANNERINI,

Plaintiff,

v. Case No: 6:22-cv-2075-RBD-LHP

EMBRY-RIDDLE AERONAUTICAL UNIVERSITY, INC.,

Defendant

ORDER This cause came on for consideration without oral argument on the following motion filed herein: MOTION: DEFENDANT’S MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW (Doc. No. 48) FILED: October 31, 2023

THEREON it is ORDERED that the motion is GRANTED in part, DENIED in part, and DEFERRED in part. Defendant moves for a protective order regarding discovery in this case. Doc. No. 48. The motion addresses three discrete categories of information: (1) information allegedly protected by the attorney-client privilege; (2) documents containing student personally identifiable information (“PII”), from which Defendant wishes to redact student identities; and (3) documents containing PII of Defendant’s current and former employees, from which Defendant also wishes to

redact the employee identities. Id. Defendant submits a privilege log in support listing each of these categories of documents/information (Doc. No. 48-1), the Affidavit of Charles W. Sevastos as it relates to the attorney-client privileged communications (Doc. No. 48-2), and the Affidavit of Allison O. Kahn in support of

the redaction of student PII (Doc. No. 48-3). Defendant asks the Court to enter a protective order that it proposed to Plaintiff as a joint discovery agreement (Doc. No. 48-4), but which Plaintiff rejected (Doc. No. 51-8). Plaintiff, of course, opposes

Defendant’s motion (Doc. No. 51), and has submit a proposed confidentiality agreement of her own (Doc. No. 53-2). The Court ordered supplemental briefing from the parties (Doc. No. 52), which the parties have now submitted (Doc. Nos. 53–54). Thus, the matter is ripe

for review. Upon consideration, the motion will be granted in part, to the extent that the Court will enter a protective order governing discovery in this case, given the parties’ inability to negotiate a confidentiality agreement. However, the Court

declines to adopt in toto either of the proposed agreements/orders submitted by the parties, as they are both too broad and too narrow in several respects.1 The Court will defer ruling on the attorney-client privilege issues, to allow for in camera inspection of those documents, for the reasons outlined herein. Each of the categories of information will be addressed in turn.2

A. Student PII. Defendant wishes to redact student PII from its document production, citing privacy concerns and the Family Educational Rights and Privacy Act (FERPA).3

1 The Court notes that Defendant appears to have objected to Plaintiff’s request to enter into a broad confidentiality agreement governing discovery in this case, and Defendant wishes to limit any confidentiality agreement to only the student and employee information at issue, and Plaintiff’s medical records. Doc. No. 48-4. However, Defendant fails to explain why a broader confidentiality agreement would not be appropriate. See Doc. Nos. 48, 53. Given the discovery disputes that have already occurred in this case, to include issues which likely could have been resolved without Court involvement had the parties entered into a confidentiality agreement, the Court finds Defendant’s position unpersuasive in this respect, and will enter a protective order governing all discovery production in this case. 2 In its motion and supplemental briefing, Defendant seeks to incorporate by reference prior filings. See Doc. No. 48, at 2 and Doc. No. 54, at 2 (incorporating Doc. Nos. 41 and 46). Incorporating by reference prior filings is impermissible and violates the page limits set forth in the Court’s Orders (see Doc. Nos. 25, 52), therefore the Court has not considered Doc. Nos. 41 or 46 in resolving the disputes presently at issue. See Aatrix Software, Inc. v. Green Shades Software, Inc., No. 3:15-cv-164-MMH-MCR, 2022 WL 4592013, at *1 & n.7 (M.D. Fla. Sept. 30, 2022), clarified on denial of reconsideration, 2022 WL 18716690 (M.D. Fla. Dec. 16, 2022); Soul Quest Church of Mother Earth, Inc. v. Att’y Gen., No. 6:20-cv- 701-WWB-DCI, 2022 WL 1131202, at *2 & n.1 (M.D. Fla. Mar. 4, 2022). Counsel is reminded that future filings must stand on their own and must not incorporate by reference arguments raised in prior filings, or risk summary denial/striking. 3 The purpose of FERPA is to “‘assure parents and students . . . that access to their education records and to protect such individuals’ right to privacy by limiting the transferability (and disclosure) of their records without their consent.” Alig–Mielcarek v. Doc. No. 48, at 2–3; Doc. No. 54, at 5–6.4 Specifically, Defendant would redact the student identity, replace the identity of the student with a student number, with such student numbers to be placed on a separate confidential legend to be available

to the parties but not to be filed absent a Court Order. See Doc. No. 48-4, at 3–4.

Jackson, 286 F.R.D. 521, 525–26 (N.D. Ga. 2012) (quoting Rios v. Read, 73 F.R.D. 589, 597 (E.D.N.Y. 1977)). “FERPA does not create a privilege which protects against the disclosure of student information, rather, it provides for the imposition of sanctions against an offending institution.” Bigge v. Dist. Sch. Bd. of Citrus Cty., Fla., No. 5:11-cv-210-Oc- 10TBS, 2011 WL 6002927, at *1 (M.D. Fla. Nov. 28, 2011) (citations omitted). However, disclosure of FERPA-protected information may be made pursuant to a court order. 20 U.S.C. § 1232g(b)(2). FERPA defines PII to include:

(a) The student’s name; (b) The name of the student’s parent or other family members; (c) The address of the student or student’s family; (d) A personal identifier, such as the student's social security number, student number, or biometric record; (e) Other indirect identifiers, such as the student’s date of birth, place of birth, and Mother’s maiden name; (f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or (g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.

34 C.F.R. § 99.3.

4 Pinpoint citations to all docket entries refer to the pagination assigned by CM/ECF, rather than the internal pagination on the documents. Notably, Defendant does not request to redact any other information encompassed by FERPA. Although Plaintiff opposes, and argues that FERPA does not apply, both

confidentiality agreements proposed by Plaintiff allow for redaction of student identities from document production, and, generally speaking, the legend procedure Defendant seeks to employ. See Doc. No. 51-8, at 5; Doc. No. 53-2, at 20 ¶ 20. And the Court finds that treating this information as confidential and

permitting redaction of student identities is appropriate. See, e.g., Doe v. Rollins Coll., No. 6:18-cv-1069-Orl-37LRH, 2019 WL 11703979, at *5 (M.D. Fla. Apr. 10, 2019) (“FERPA does not prohibit the release of records so long as the student’s identifying

information is redacted.”). See also Ragusa v. Malverne Union Free Sch. Dist., 549 F. Supp. 2d 288, 294 (E.D.N.Y.

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Giannerini v. Embry-Riddle Aeronautical University, Inc., (M.D. Fla. 2023).

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Related

Ragusa v. Malverne Union Free School District
549 F. Supp. 2d 288 (E.D. New York, 2008)
Alig-Mielcarek v. Jackson
286 F.R.D. 521 (N.D. Georgia, 2012)
Rios v. Read
73 F.R.D. 589 (E.D. New York, 1977)