Hartnett v. Hardenbergh

CourtDistrict Court, E.D. Virginia
DecidedJanuary 26, 2024
Docket3:23-cv-00017
StatusUnknown

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

Bluebook
Hartnett v. Hardenbergh, (E.D. Va. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division PAMELA K. HARTNETT, ) Plaintiff, V. Civil Action No. 3:23-cv-17-HEH CHARLES VANEVERA HARDENBERGH, et al., ) Defendants. MEMORANDUM OPINION (Denying Plaintiff’s Contempt Motion, Denying the City of Petersburg’s Motions, and Denying in Part Defendants’ Motions to Quash) THIS MATTER is before the Court on numerous motions filed by the parties and the City of Petersburg (“Petersburg”). Defendants Charles Vanevera Hardenbergh and Mari Liza Hardenbergh (collectively, the “Hardenberghs”) filed a Motion to Quash Subpoena Duces Tecum Issued to City of Petersburg Bureau of Police (the “Petersburg Police Motion,” ECF No. 58) and a Motion to Quash Subpoena Duces Tecum Issued to Petersburg Information Technology Department (the “Petersburg IT Motion,” ECF No. 73) (collectively, the “Motions to Quash”) on October 4, 2023, and October 25, 2023, respectively. The Hardenberghs argue that both subpoenas should be quashed because they request expunged documents. (Mem. in Supp. of Petersburg Police Mot. at 1, ECF No. 67; Mem. in Supp. of Petersburg IT Mot. at 1, ECF No. 74.) Plaintiff Pamela K. Hartnett (“Plaintiff”) filed memoranda in response to the Motions to Quash on October 11, 2023, and November 1, 2023.

Thereafter, Plaintiff filed a Motion to Hold in Contempt (the “Contempt Motion,” ECF No. 84) the Petersburg Bureau of Police (“Petersburg Police”) and the Petersburg Information Technology Department (“Petersburg IT Department”) (collectively, the “Petersburg Agencies”) on November 28, 2023. Plaintiff asks the Court to hold the Petersburg Agencies in contempt because they failed to turn over responsive documents in their possession that were not expunged. (Br. in Supp. of Contempt Mot. at 2-4, ECF No. 85.) In response, Petersburg filed a Motion for Protective Order (ECF No. 86), a Motion for Sanctions (ECF No. 87), and a Response to the Contempt Motion (ECF No. 91) on December 5, 2023.! Plaintiff filed responsive memoranda on December 13, 2023. The Court heard oral argument on the Motions to Quash on December 21, 2023. As to the Contempt Motion, the Motion for Protective Order, and the Motion for Sanctions, the Court will dispense with oral argument because the facts and legal contentions have been adequately presented to the Court, and oral argument would not aid in the decisional process. See E.D. VA. Loc. Civ. R. 47(J). I. Background On September 26, 2023, Plaintiff issued and served a subpoena duces tecum on the Petersburg Police. (Br. in Supp. of Contempt Mot. { 1.) The Hardenberghs filed their Motion to Quash this subpoena on October 4, 2023. The Petersburg Police responded to

' Petersburg originally filed its Response to the Contempt Motion, Memorandum in Support of thé Motion for Protective Order, and Memorandum in Support of the Motion for Sanctions in a single document on December 5, 2023. (ECF No. 88.) Petersburg then filed the documents separately on December 7, 2023.

the subpoena on October 23, 2023, and provided certain police records to Plaintiff. (ld. 4 2.) However, it did not provide all of the records requested by the subpoena. (/d.) The Petersburg Police then told Plaintiff to “refer to Petersburg Information and Technology Department” for most of the records it did not provide. (Exhibit A-1 at 1, ECF No. 85-2.) In response, Plaintiff issued a second subpoena duces tecum to the Petersburg IT Department on October 24, 2023. (Br. in Supp. of Contempt Mot. 4.) The Hardenberghs filed a Motion to Quash the subpoena the next day. The Petersburg IT Department did not respond to the subpoena and instead instructed Plaintiff to contact the Petersburg City Attorney (the “City Attorney”). (/d. ]6.) On November 22, 2023, Plaintiff conferred with the City Attorney who stated that his office was advised by the Hardenberghs’ counsel not to respond to Plaintiff's subpoenas until the Motions to Quash were resolved. (/d. § 9; Resp. to Contempt Mot. □ 17, ECF No. 91.) Though Plaintiff informed the City Attorney that a number of the document requests were not covered by the expungement at issue in the Motions to Quash, the City Attorney refused to produce any of the requested documents. (Br. in Supp. of Contempt Mot. {{ 10-11.) II. Contempt Motion & Motions to Quash Because of Petersburg’s failure to respond, Plaintiff asks the Court to hold the Petersburg Agencies in contempt. Federal Rule of Civil Procedure 45(f) allows a court to hold in contempt a party who “fails without adequate excuse to obey [a] subpoena or an order related to it.” FED. R. Civ. P. 45(f). To hold a party in civil contempt, the movant

must establish four elements “by clear and convincing evidence: (1) the existence of a valid court order; (2) the order was in the moving party’s ‘favor’; (3) a knowing violation

of the terms of the order; and (4) the moving party suffered harm from the violation.” Consumer Fin. Prot. Bureau v. Klopp, 957 F.3d 454, 461 (4th Cir. 2020). Ifthe movant

proves all four elements, the burden shifts to the non-movant and “a good faith attempt to comply, as well as substantial compliance or the inability to comply, can be defenses to a civil contempt order.” United States v. Darwin Const. Co., 873 F.2d 750, 754 (4th Cir. 1989) (citing Consolidation Coal Co. v. Loc. 1702, United Mineworkers of Am., 683 F.2d 827, 832 (4th Cir. 1982)). Plaintiff argues that the Petersburg Agencies should be held in contempt because they failed to respond to Plaintiff's subpoenas, despite Plaintiff explaining to Petersburg that most of her requests were not covered by the expungement at issue in the Motions to Quash. (Br. in Supp. of Contempt Mot. {J 10-11.) Petersburg responds that the Petersburg Agencies should not be held in contempt because their lack of response was

an attempt to avoid usurping the Court’s authority. (Resp. to Contempt Mot. at 5.) Further, they did not produce any documents because they were unsure which documents, if any, the Court would allow to be produced when it rules on the Motions to Quash. (Id.) Since there were pending Motions to Quash that could potentially nullify the subpoenas issued, Plaintiff cannot show that Petersburg knowingly violated the subpoena. Accordingly, the Court will deny Plaintiff's Contempt Motion. However, the Court finds Plaintiffs argument that the Petersburg Agencies should produce any non-expunged documents to be compelling. Thus, the Court will deny in

part the Motions to Quash and will require the Petersburg Agencies to produce any responsive documents that are not expunged. At this time, the Court does not rule on

whether it is appropriate for the expunged documents to be produced. This issue remains

open and the Court will make a determination at a later date. III. Motion for Protective Order Petersburg seeks a protective order in response to Plaintiff's subpoenas. A non-

party may seek a protective order in response to receiving a subpoena that it objects to. United States v. Star Sci., Inc., 205 F. Supp. 2d 482, 484 (D. Md. 2002). Pursuant to Rule 26(c), “[a] court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense.” FED. R. CIv. P. 26(c). “The party seeking a protective order has the burden of establishing ‘good cause’ by demonstrating that ‘specific prejudice or harm will result if no protective order is granted.’” U.S.

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