J.T.F. v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedAugust 28, 2023
DocketCivil Action No. 2021-1453
StatusPublished

This text of J.T.F. v. District of Columbia (J.T.F. v. District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.T.F. v. District of Columbia, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

J.T.F., et al., : : Plaintiffs, : Civil Action No.: 21-1453 (RC) : v. : Re Document Nos.: 43, 44 : DISTRICT OF COLUMBIA, : : Defendant. :

MEMORANDUM OPINION & ORDER

GRANTING DEFENDANT’S MOTION TO COMPEL; DENYING PLAINTIFFS’ MOTION TO COMPEL

I. INTRODUCTION

Plaintiffs J.T.F. and her mother, Ana Flores (collectively, “Plaintiffs”), bring this action

against Defendant the District of Columbia, alleging violations of their rights under the

Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq.; Title VI of the

Civil Rights Act of 1964, 42 U.S.C. § 2000d; the Equal Educational Opportunities Act of 1974

(“EEOA”), 20 U.S.C. § 1701 et seq.; Section 504 of the Rehabilitation Act of 1973, 29 U.S.C.

§ 794; the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq.; and the

Elementary and Secondary Education Act of 1965 (“ESEA”), 20 U.S.C. § 6301 et seq. Am.

Compl. ¶¶ 1–2, ECF No. 2. Plaintiffs’ Counts 1–17 allege they were “discriminated against

. . . on the basis of [their] national origin,” and Plaintiffs’ Count 18 alleges that Defendant “failed

to train [IDEA] Hearing Officers on . . . the requirements of those statutes.” Id. ¶¶ 111–33. As a

result, Plaintiffs ask to enjoin the District from engaging in further violations of the IDEA, Title

VI, the EEOA, Section 504 of the Rehabilitation Act, and the ADA. They further seek orders

requiring: that Defendant provide multiple educational services to J.T.F.; that the District provide

1 copies of J.T.F.’s complete and cumulative records in Spanish; that Defendant fund various

independent evaluations of J.T.F.; and that the District develop a new Individualized Education

Program (“IEP”) based on these evaluations. Plaintiffs also seek compensatory damages and

attorneys’ fees. Id. at 31–33.

Defendant moved to dismiss these claims for failure to state a claim under Federal Rule

of Civil Procedure 12(b)(6). See Def.’s Mot. Dismiss, ECF No. 9. The Court granted in part and

denied in part Defendant’s motion to dismiss, and ordered that all claims in the Amended

Complaint, except for the claims within Counts 1–18 under the EEOA, and the Count 18 claim

under the IDEA, be dismissed. See Order, ECF No. 26.

Defendant now moves to compel responses to its discovery requests that were first served

on April 4, 2022. Def.’s Mot. Compel Disc. (“Def.’s Mot.”) at 2, ECF No. 43. Plaintiffs object

to Defendant’s discovery responses, and move to compel responses to their discovery requests.

Pls.’ Objs. to Def.’s Disc. Resps. & Mot. Compel Disc. (“Pls.’ Mot.”), ECF No. 44. For the

reasons detailed below, the Court grants Defendant’s, and denies Plaintiffs’, motion to compel

discovery.

II. FACTUAL BACKGROUND

On February 16, 2022, the Court ordered the parties to serve any discovery requests by

April 4, 2022, and to conclude discovery of facts by July 5, 2022. Sched. Order at 1, ECF No.

38. On April 4, 2022, the last day to serve any discovery requests, see id., each party served the

other with interrogatories and requests for production of documents (“RPD”), Def.’s Mot. Ex. 1

(“Def.’s Interrog. Pls.”), ECF No. 43-1; Def.’s Mot. Ex. 2 (“Def.’s Req. Produc. Doc. Pls.”),

ECF No. 43-2; Pls.’ Mot. Ex. A (“Pls.’ Interrog. & Req. Produc. Doc. Def.”), ECF No. 44-1.

Defendant agreed to a June 30, 2022 deadline for Plaintiffs’ responses. See Def.’s Mot. at 2. On

2 June 30, 2022, Defendant provided responses, but Plaintiffs did not. Pls.’ Mot. Ex. B, ECF No.

44-2. As a result, the parties requested to extend the close of discovery, Joint Mot. Extend

Sched. Order at 3–4, ECF No. 39, which the Court extended from July 5, 2022 to September 30,

2022, Min. Order, July 5, 2022.

On August 12, 2022, Plaintiffs agreed to provide discovery responses by August 15,

2022. Def.’s Mot. Ex. 4, ECF No. 43-4. On August 15, 2022, however, Plaintiffs did not

provide any discovery responses because of Plaintiffs’ counsel’s significant health concerns. Id.

Ex. 5, ECF No. 43-5. Therefore, Plaintiffs requested to extend the close of discovery, Pls.’ Mot.

Extend Sched. Order, ECF No. 41, which the Court extended from September 30, 2022 to

January 31, 2023, Min. Order, Aug. 26, 2022. The Court also ordered Plaintiffs to submit

discovery responses by October 24, 2022. Id.

On October 18, 2022, Plaintiffs served the District with another set of RPD. Pls.’ Mot.

Ex. D, ECF No. 44-4. Defendant declined to respond arguing that the request was untimely

because the latest “Minute Order did not extend the deadline for the parties to serve discovery

requests,” but rather it extended the close of factual discovery. Id. Ex. E, ECF No. 44-5

(emphasis in original). Plaintiffs claim that they believed a RPD would fall within discovery of

facts. Id. at 5.

On October 21, 2022, Plaintiffs responded to the RPD that had been served on April 4,

2022. Def.’s Mot. Ex. 7, ECF No. 43-7. The District claims that Plaintiffs “failed to respond to

21 of the District’s 29 [RPDs] and provided insufficient responses to the remainder.” Id. at 1.

More specifically, Defendant argues that “the numbered paragraphs in Plaintiffs’ response do not

correspond to the numbered paragraphs on the District’s RPDs,” that Plaintiffs “failed to provide

3 any objection or response to [multiple] RPD,” and that Plaintiffs failed to identify, or even

provide, specific documents. Id. at 4.

On October 26, 2022, two days after the deadline to submit discovery responses, see Min.

Order, Aug. 26, 2022, Defendant asked Plaintiffs when it should expect their interrogatory

responses, see Def.’s Mot. Ex. 8, ECF No. 43-8. On November 1, 2022, more than a week later,

see Min. Order, Aug. 26, 2022, Plaintiffs objected to Defendant’s interrogatories because they

were not available in Spanish, see Def.’s Mot. Ex. 9, ECF No. 43-9. Consequently, on

November 30, 2022, the District sent Plaintiffs a deficiency letter regarding their discovery

responses. Id. Ex. 10, ECF No. 43-10. On December 5, 2022, Plaintiffs said they would

“respond in greater detail within the next 3-4 business days,” id. Ex. 11, ECF No. 43-11, but they

never did, see Def.’s Mot. at 5. Instead, on January 10, 2023, Plaintiffs objected to Defendant’s

interrogatory responses claiming violations of multiple rules, and failure to respond. Pls.’ Mot.

Ex. C, ECF No. 44-3.

Defendant claims that, on January 17, 2023, it contacted Plaintiffs to meet and confer.

Def.’s Mot. at 5. It also claims that they had an unsuccessful meeting on January 20, 2023,

which prompted them to contact the Court. Id. As a result, on January 23, 2023, the Court

ordered the parties to file their respective motions relating to any discovery disputes by February

6, 2023. Min. Order, Jan. 23, 2023. On February 6, 2023, the District filed a motion to compel

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