Kelly v. Cuomo

District Court, D. Nevada·Decided May 23, 2025·No. 2:18-cv-00923·Unknown

Opinion

Gregory Kelly, 2:18-cv-00923-JAD-MDC Plaintiff(s), ORDER GRANTING AND DENYING IN PART STIPULATION REGARDING vs. DISCOVERY (ECF NO. 141) AND DENYING WITHOUT PREJUDICE, WITH LEAVE TO Jody Marie Cuomo, REFILE, THE MOTION TO WITHDRAW (ECF NO. 137) Defendant(s). The parties filed a Stipulation Regarding Discovery Dispute (ECF No. 141)(“Stipulation”) pursuant to the Court’s Standing Order (ECF No. 129). The Court GRANTS AND DENIES the Stipulation IN PART as discussed in this Order. Counsel for the defendant also filed a Motion to Withdraw (ECF No. 137)(“Motion”). The Court DENIES the Motion WITHOUT PREJUDICE WITH LEAVE TO REFILE after counsel files a Notice of Compliance with this discovery Order, which is due within thirty days. This case has been pending for over seven years: this is a post-judgment proceeding brought by pro se litigant Gregory Kelly. Plaintiff Kelly served numerous written discovery requests on defendant Jody Marie Cuomo, which the parties now dispute in Stipulation. ECF No. 141. Counsel for the defendant asks the Court to withdraw because defendant can no longer afford to pay counsel. ECF No. 137. A. Legal Standard Post-judgment discovery is governed by Federal Rule of Civil Procedure 69(a)(2), which allows 1 a judgment creditor to obtain discovery from any person, including the judgment debtor, in aid of the judgment or execution. This rule is designed to help the judgment creditor identify and trace the debtor's assets to enforce the judgment. Republic of Argentina v. NML Capital, Ltd., 573 U.S. 134 (2014). Federal Rule of Civil Procedure 26(b)(1) provides that parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case. This rule applies to post-judgment discovery, allowing judgment creditors to propound interrogatories or requests for the production of documents and electronically stored information. Gersh v. Anglin, No. CV 17-50-M-DLC-KLD, 2021 WL 461570, at *1 (D. Mont. Feb. 9, 2021). Federal Rule of Civil Procedure 34 requires parties to make a reasonable inquiry when responding to requests for production of documents. A party is only obligated to produce during discovery those documents which are in the "possession, custody, or control" of the party, Fed. R. Civ. P. 34(a), and a party cannot be compelled to produce documents and other items which do not exist. If a judgment debtor fails to comply with post-judgment discovery requests, the judgment creditor may move for an order compelling disclosure or discovery under Federal Rule of Civil Procedure 37(a). B. Analysis of the Stipulation The 32-page stipulation is difficult to follow as it is generally unorganized, but given Kelly’s pro se status, the Court views his arguments liberally.1 Plaintiff appears to have served multiple requests for production of documents, and the defendant responded with some objections: the defendant also made multiple supplemental responses. See ECF No. 141 at 4. The Court analyzes the requests in dispute the stipulation. a. Probate Documents Request No. 2 pertains to probate documents. ECF No. 141 at 4.

1 “[A] pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). 2 • REQUEST NO. 2 – COPIES OF ALL PROBATE DOCUMENTS FOR THE ESTATE • RESPONSE NO. 12 – "See attached of all documents I have.” RESPONSE NO. 2 – "Objection, the term “probate documents” is undefined and is vague and ambiguous. Further, requesting “all” documents is overly burdensome and not proportional to the needs of the case, as “all” documents for the estate of Joseph M. Cuomo are not relevant to whether Ms. Cuomo has any assets that can be used to satisfy the judgment, and production of “all” documents is not proportional to the needs of the case." Without waiver of said objection, On August 7, 2024, all documents within Ms. Cuomo’s custody relating to Joseph M. Cuomo’s last will and testament and estate were produced." RESPONSE NO. 3 – Same as Response No. 2. with the following supplemental paragraph, in bold (emphasis omitted): "It is inaccurate to state that you received no documents responsive to the request. Further, you state in a conclusory manner that “probate documents” is not ambiguous or vague, but it is so ambiguous and vague that Ms. Cuomo’s production of documents relating to Mr. Cuomo’s estate were not recognized by you. There is no “probate” case known to exist, and as a corollary, Ms. Cuomo could have just produced nothing upon the interpretation that the request was limited to documents relating to a “probate” case. However, acting in good faith and with nothing to hide, Ms. Cuomo read the request more expansively, and on August 7, 2024, Ms. Cuomo produced the Last Will and Testament and a copy of the distribution check payable to Ms. Cuomo pursuant to that Last Will and Testament, as well as ALL other documents in her possession or control substantiating the amount she received following

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)