Howard v. City of Rochester

District Court, W.D. New York·Decided June 9, 2025·No. 6:23-cv-06561·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

Darius Howard,

Plaintiff, DECISION and ORDER v. 23-cv-6561-FPG-MJP City of Rochester, et al.,

Defendants.

INTRODUCTION Pedersen, M.J. Plaintiff Darius Howard requests that this Court permit him to move forward with sanctions against the City De- fendants. (ECF No. 74, May 16, 2025.) Rather than permit full-blown motion practice on the question, the Court nips this issue in the bud. The Court denies Plaintiff’s request for leave to set a briefing schedule

for a motion seeking reasonable costs and attorneys’ fees because the Court sees no reason to award sanctions against the City under Fed. R. Civ. P. 30(d)(2). But the Court grants Plaintiff’s request for 1.5 more

hours of deposition time and directs that the parties complete the depo- sition at issue by the end of June 2025. BACKGROUND This order arises from a discovery dispute dating back to January 2025. The dispute began because the cast of characters in this case over- laps with that of another case pending before the Chief Judge (and a different Magistrate Judge), Johnson v. City of Rochester, 21-cv-6683- EAW-CDH. Chief Judge Wolford issued a decision and order in Johnson barring further discovery. Johnson v. City of Rochester, No. 6:21-CV-

06683 EAW, 2024 WL 4799913, at *3 (W.D.N.Y. Nov. 15, 2024). Before turning to Johnson’s impact (or not) on this case, several overlapping cast members bear mentioning. First, Plaintiff’s counsel in

this case also represents the plaintiff in Johnson. Second, the cases in- volve allegations about the same former City of Rochester Police Officer, Jonathan Laureano. And third, the City’s Law Department is defending Laureano in both cases. Given the Chief Judge’s ruling, the defense argues that Plaintiff’s

counsel would like backdoor discovery that he can use in Johnson. In letters exchanged off-the-docket, the parties alerted the Court to the City’s request “that Plaintiff agree to postpone Officer Laureano’s depo- sition until after the trial in Johnson v. City of Rochester, 21-cv-6683.” (Pl. Letter at 1, on file, Jan. 8, 2025.) The City’s request was based on the Chief Judge’s decision in Johnson. The City reasoned that Plaintiff should not obtain indirectly what he could not obtain directly. Respond- ing, Plaintiff opposed the City’s request from the outset: Plaintiff cannot agree to postpone the [Laureano] deposi- tion … Fact discovery closes May 9, 2025, and Officer Lau- reano’s deposition has been properly noticed well within the discovery period. After Officer Laureano’s deposition, Plaintiff anticipates serving follow-up discovery demands and conducting numerous additional depositions that will need to be completed before the discovery deadline. Delay- ing Officer Laureano’s deposition would severely compress the time available for this necessary follow-up discovery. (Id.) The Court heard from the parties about the dispute during a con- ference on January 10, 2025. During that conference, Plaintiff’s counsel alluded to his ethical

obligation to pursue relevant discovery under Fed. R. Civ. P. 26(b)(1). To the undersigned, Plaintiff’s position appeared to be one of good faith.

Likewise, the undersigned determined that the City was proceeding in good faith and wanted to bring this issue to the Court’s attention before resorting to motion practice. Ultimately, the Court determined that a letter to the parties was appropriate in part because the Court wanted to afford the City the op- portunity for formal briefing. So on January 27, 2025, the undersigned wrote the parties. In that letter, the Court indicated it would likely per- mit Plaintiff’s counsel to use this arguable “backdoor,” stating: “I am not

inclined to grant the City Defendants any relief regarding Mr. Lau- reano’s deposition.” (Letter at 1–2, ECF No. 63-1 (attached as Exhibit 1 to ECF No. 63).) After all, Plaintiff properly noticed Laureano’s deposi- tion in this case. So the only limitation the undersigned noted regarding the Laureano’s deposition was that Plaintiff’s questions to Laureno

should be relevant to this case. (Id. at 2 (“In short, if Mr. Shields asks Mr. Laureano a question that is relevant to the Howard case (and oth- erwise permissible), I see no problem.”).) Plaintiff’s counsel believes that allegations about Laureano are

relevant to this case “because” the two cases “involve[] similar allega- tions that Laureano provided false sworn testimony and/or included un- truthful statements in his official reports.” (Letter at 1, ECF No. 61, Apr. 2, 2025.) It appears that City counsel permitted questioning about Lau- reano’s credibility in other cases: Although [City counsel] had allowed me to question Lau- reano about People v. Allen, Ind. No. 2021-0027A (Monroe Cty. Ct.) (Exhibit 1); People v. Parsons, Ind. No. 2019/0597 (Sup. Ct. Monroe Cty. Dec. 2, 2019) (Exhibit 2); and United States v. Brookins, No. 17-cr-6019-CJSJWF (W.D.N.Y. Sept. 28, 2018) (Exhibit 3), he abruptly terminated the dep- osition without letting me pose even one question about Johnson. The suppression ruling in People v. Johnson, Ind. No 2020/0070 (Monroe Cty. Ct.) is attached as Exhibit 4. (Id. at 2.) Plaintiff posits that despite the Court’s letter advising the par- ties of its position, the City improperly terminated the Laureano depo- sition. True, City counsel inaccurately described the January 17 letter as an “order … that says that you can’t ask questions about the Devin Johnson case.” (Rough Tr. 9:25–10:3, on file.) The Court finds that the City misread the Court’s January 17 let- ter. First, the letter is expressly not an order. Instead, the Court gave the parties its initial reaction but further gave the City the chance to move for relief to attempt to convince the Court otherwise through a discussion of applicable law.1 (Letter at 1, ECF No. 63-1 (attached as Exhibit 1 to ECF No. 63).) The Court accordingly indicated that it was unlikely to grant the City relief concerning Laureano’s deposition.

Second, the letter stated that Plaintiff’s counsel could not ask a

question “relevant only to the Johnson case.” (Id. at 2.) The word “only” is key. If Plaintiff’s counsel asks a question relevant to this case that so

happens to bear on Johnson, that is permissible.2 But the City reads the Court’s letter too broadly: The City’s “interpretation … is that question- ing Officer Laureano specifically about [the] subject of the Johnson case is impermissible.” (Letter at 2, ECF No. 63, Apr. 4, 2025.) Not so. To clear up any lingering doubt, the Court sua sponte issued a text order. The City prompted that text order by writing to the Court to purport to reserve the right to terminate the Laureano deposition again if Plaintiff’s counsel questioned Laureano about the Johnson case. (Let-

ter at 1, ECF No. 71 (“I would, however, reserve my right to move in the event that the questioning at [Laureano’s] resumed deposition runs afoul of Your Honor’s directive in your letter of January 17, 2025.”).) The

1 Thus, the City has had since mid-January to move to limit the Lau- reano deposition yet has not done so. This reinforces the Court’s finding below that the City has forfeited the ability to move to limit the Laureano deposition. 2 This likely includes credibility questions about the Johnson case, which are relevant in Howard because they tend to show Laureano’s propen- sity for truthfulness—a topic that parties may always explore during discovery and at trial. Moreover, deposition testimony, like all discovery, need not be admissible.

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