John Stokes v. County of Wayne

CourtDistrict Court, E.D. Michigan
DecidedNovember 5, 2025
Docket2:24-cv-11012
StatusUnknown

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

Bluebook
John Stokes v. County of Wayne, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JOHN STOKES, Case No. 24-11012 Plaintiff, v. Matthew F. Leitman United States District Judge COUNTY OF WAYNE, Defendant. Curtis Ivy, Jr. ____________________________/ United States Magistrate Judge

ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF’S MOTION TO COMPEL AND FOR EXTENSION OF DISCOVERY (ECF No. 13)

Before the Court is Plaintiff John Stokes’s motion to compel discovery responses and motion to extend discovery and for related costs and fees as sanctions for Defendant Wayne County’s conduct during discovery. (ECF No. 13). The District Judge referred this motion to the undersigned. (ECF No. 14). The motion is fully briefed, and the parties appeared before the undersigned on this matter during status conferences on October 2, 2025 and October 9, 2025. (ECF Nos. 15, 16, 17, 19). Plaintiff’s motion to compel is GRANTED IN PART AND DENIED IN PART; his motion for sanctions is DENIED. I. BACKGROUND After a lengthy, delay-filled discovery process, Plaintiff filed a motion to compel discovery responses on April 24, 2025. (ECF No. 13). Specifically, Plaintiff seeks full responses to Interrogatory Nos. 13, 21, and 22 and Requests for Production (“RFP”) Nos. 13 and 17. (Id. at PageID.163). Plaintiff served these discovery requests on Defendant on August 14, 2024. (ECF No. 13, PageID.150;

ECF No. 13-1). Defendant served its responses on September 13, 2024. (ECF No. 13-2). Because Plaintiff’s counsel’s child was born shortly thereafter, he did not inform Defendant of the deficiencies in its initial discovery responses until

November 7, 2024; this included deficiencies with the discovery requests at issue here. (ECF No. 13, PageID.150). After missing agreed-upon deadlines between the parties, Defendant informed Plaintiff’s counsel it was finalizing its supplemental responses on

December 19, 2024; at that time, Defendant also requested a protective order (and provided a draft to review) but did not condition its first supplemental responses on the entry of such an order. (Id. at PageID.153-54; ECF No. 13-4). Defendant

shared its First Supplemental Responses the next day. (ECF No. 13, PageID.154- 55; ECF No. 13-5). The supplemental responses did not address the issues with Interrogatory Nos. 13, 21, and 22 or RFPs 13 and 17. There is no explanation in the record for Defendant’s omission.

Plaintiff’s counsel did not request to meet-and-confer with Defendant regarding the outstanding deficiencies until February 26, 2025; counsel also provided suggested revisions on the proposed protective order the same day. (ECF No. 13, PageID.155). There is no explanation in the record as to why Plaintiff’s counsel waited more than two months to do so.

During the meet-and-confer process on March 17, 2025, the parties agreed to narrow RFP No. 17 to specific parameters including a timeframe;1 Plaintiff’s counsel also reminded Defendant of its proposed revisions for the protective order.

(Id. at PageID.156). Defendant indicated that further supplemental responses would be produced soon, even “less than a week.” (Id.). Even so, the parties agreed to adjourn scheduling order deadlines. (ECF No. 12). Plaintiff’s counsel provided the narrowed version of RFP No. 17 on March

24, 2025.2 (Id. at PageID.157; ECF No. 13-9). When he did not receive supplemental responses from Defendant by April 7, Plaintiff’s counsel requested an update; Defendant indicated it had finalized their second supplemental

responses but were waiting on the revised parameters for RFP No. 17. (ECF No. 13, PageID.157; ECF No. 10). Plaintiff’s counsel forwarded his previous email,

1 RFP No. 17 originally read: “Please provide all documents reflecting all meetings, conversations, discussions, written correspondence, emails, statements, and telephone calls reflecting any complaint by employees about racial discrimination by Defendant.” (ECF No. 13- 1, PageID.213).

2 Plaintiff’s revised RFP No. 17 reads:

Complaints within the County Police Department, from January 1, 2015 to today, and which included and/or resulted in one of the following: (1) An EEO and/or EEOC filing; (2) A union grievance; (3) A formal written complaint to H.R.; (4) Any discipline for any party; and/or (5) A formal meeting with supervisors.

(ECF No. 13-12, PageID.343-44). and Defendant provided its second set of supplemental responses on April 18, little more than a week before the close of fact discovery on April 28. (ECF No. 12

(regarding discovery deadlines); ECF No. 13, PageID.157-58; ECF No. 13-12). From Plaintiff’s perspective, Defendant’s second set of supplemental responses were as deficient as the first. (ECF No. 13, PageID.158-59). For

instance, Defendant indicated it had responsive information to Interrogatory Nos. 13, 21, and 22 and RFP No. 13; but—for the first time apparently—Defendant stated that production was contingent on a protective order. (Id.; ECF No. 13-12, PageID.339, PageID.342-43). Yet there was no acknowledgment from Defendant

regarding Plaintiff’s suggested revisions to the protective order. (ECF No. 13, PageID.159). Indeed, Plaintiff’s counsel was not aware Defendant received his suggested edits until Defendant asserted they were unacceptable in their response

brief to this motion. (ECF No. 15, PageID.354 (regarding Defendant’s response); ECF No. 16, PageID.405-06 (regarding Plaintiff’s counsel’s reaction)). Nor did Defendant respond to RFP No. 17, contending instead that Plaintiff broadened this discovery request rather than narrowing it. (ECF No. 13,

PageID.159; ECF No. 13-12, PageID.343-44). In fact, Defendant’s only issue with the original RFP No. 17 was apparently the lack of a timeline. (ECF No. 13-12, PageID.344 (“Defendant sought date ranges for clarification on the original request

not a new and different request.”); ECF No. 15, PageID.356-57 (“Plaintiff could [have] simply provide[d] timeframe parameters relative to the initial discovery request.”). Accordingly, Defendant interpreted the revised RFP as an entirely

different discovery request. (ECF No. 13-12, PageID.343-44). See also supra notes 1-2. As mentioned, Plaintiff seeks full responses to Interrogatory Nos. 13, 21,

and 22 and RFP Nos. 13 and 17. Plaintiff also asks for sanctions in the form of an extension of discovery and an award of costs and fees for—what Plaintiff’s counsel deems—wasted efforts pursuing supplemental responses from Defendant.3 (ECF No. 13, PageID.169-172).

II. ANALYSIS Since Plaintiff moves to compel production and for sanctions, the Court will address the related arguments in that order.

A. Plaintiff’s Motion to Compel 1. Governing Standards Parties may obtain discovery related to any nonprivileged matter relevant to any party’s claim or defense and proportional to the needs of the case, considering

the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the

3 Defendant’s version of the facts underlying Plaintiff’s motion does not differ by much. The only difference is Defendant’s emphasis of Plaintiff’s own delays and errors while minimizing its own. (ECF No. 15). importance of discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Fed. R. Civ. P. 26.

Information within this scope of discovery need not be admissible in evidence to be discoverable. Id. “Although a [party] should not be denied access to information necessary to establish her claim, neither may a [party] be permitted to

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