Kelly v. Cuomo

CourtDistrict Court, D. Nevada
DecidedMay 23, 2025
Docket2:18-cv-00923
StatusUnknown

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

Bluebook
Kelly v. Cuomo, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Gregory Kelly, 2:18-cv-00923-JAD-MDC 4 Plaintiff(s), ORDER GRANTING AND DENYING IN 5 PART STIPULATION REGARDING vs. DISCOVERY (ECF NO. 141) AND DENYING 6 WITHOUT PREJUDICE, WITH LEAVE TO 7 Jody Marie Cuomo, REFILE, THE MOTION TO WITHDRAW (ECF NO. 137) 8 Defendant(s). 9 10 The parties filed a Stipulation Regarding Discovery Dispute (ECF No. 141)(“Stipulation”) 11 pursuant to the Court’s Standing Order (ECF No. 129). The Court GRANTS AND DENIES the 12 Stipulation IN PART as discussed in this Order. Counsel for the defendant also filed a Motion to 13 Withdraw (ECF No. 137)(“Motion”). The Court DENIES the Motion WITHOUT PREJUDICE WITH 14 LEAVE TO REFILE after counsel files a Notice of Compliance with this discovery Order, which is due 15 within thirty days. 16 I. BRIEF BACKGROUND 17 This case has been pending for over seven years: this is a post-judgment proceeding brought by 18 pro se litigant Gregory Kelly. Plaintiff Kelly served numerous written discovery requests on defendant 19 Jody Marie Cuomo, which the parties now dispute in Stipulation. ECF No. 141. Counsel for the 20 defendant asks the Court to withdraw because defendant can no longer afford to pay counsel. ECF No. 21 137. 22 II. DISCUSSION 23 A. Legal Standard 24 Post-judgment discovery is governed by Federal Rule of Civil Procedure 69(a)(2), which allows 25 1 1 a judgment creditor to obtain discovery from any person, including the judgment debtor, in aid of the 2 judgment or execution. This rule is designed to help the judgment creditor identify and trace the debtor's 3 assets to enforce the judgment. Republic of Argentina v. NML Capital, Ltd., 573 U.S. 134 (2014). 4 Federal Rule of Civil Procedure 26(b)(1) provides that parties may obtain discovery regarding 5 any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of 6 the case. This rule applies to post-judgment discovery, allowing judgment creditors to propound 7 interrogatories or requests for the production of documents and electronically stored information. Gersh 8 v. Anglin, No. CV 17-50-M-DLC-KLD, 2021 WL 461570, at *1 (D. Mont. Feb. 9, 2021). Federal Rule 9 of Civil Procedure 34 requires parties to make a reasonable inquiry when responding to requests for 10 production of documents. A party is only obligated to produce during discovery those documents which 11 are in the "possession, custody, or control" of the party, Fed. R. Civ. P. 34(a), and a party cannot be 12 compelled to produce documents and other items which do not exist. If a judgment debtor fails to 13 comply with post-judgment discovery requests, the judgment creditor may move for an order compelling 14 disclosure or discovery under Federal Rule of Civil Procedure 37(a). 15 B. Analysis of the Stipulation 16 The 32-page stipulation is difficult to follow as it is generally unorganized, but given Kelly’s pro 17 se status, the Court views his arguments liberally.1 Plaintiff appears to have served multiple requests for 18 production of documents, and the defendant responded with some objections: the defendant also made 19 multiple supplemental responses. See ECF No. 141 at 4. The Court analyzes the requests in dispute the 20 stipulation. 21 a. Probate Documents 22 Request No. 2 pertains to probate documents. ECF No. 141 at 4. 23

24 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 25 (1976)). 2 1 • REQUEST NO. 2 – COPIES OF ALL PROBATE DOCUMENTS FOR THE ESTATE 2 OF JOSEPH M. CUOMO. 3 • RESPONSE NO. 12 – "See attached of all documents I have.” RESPONSE NO. 2 – 4 "Objection, the term “probate documents” is undefined and is vague and ambiguous. 5 Further, requesting “all” documents is overly burdensome and not proportional to the 6 needs of the case, as “all” documents for the estate of Joseph M. Cuomo are not relevant 7 to whether Ms. Cuomo has any assets that can be used to satisfy the judgment, and 8 production of “all” documents is not proportional to the needs of the case." Without 9 waiver of said objection, On August 7, 2024, all documents within Ms. Cuomo’s custody 10 relating to Joseph M. Cuomo’s last will and testament and estate were produced." 11 RESPONSE NO. 3 – Same as Response No. 2. with the following supplemental 12 paragraph, in bold (emphasis omitted): "It is inaccurate to state that you received no 13 documents responsive to the request. Further, you state in a conclusory manner that 14 “probate documents” is not ambiguous or vague, but it is so ambiguous and vague that 15 Ms. Cuomo’s production of documents relating to Mr. Cuomo’s estate were not 16 recognized by you. There is no “probate” case known to exist, and as a corollary, Ms. 17 Cuomo could have just produced nothing upon the interpretation that the request was 18 limited to documents relating to a “probate” case. However, acting in good faith and with 19 nothing to hide, Ms. Cuomo read the request more expansively, and on August 7, 2024, 20 Ms. Cuomo produced the Last Will and Testament and a copy of the distribution check 21 payable to Ms. Cuomo pursuant to that Last Will and Testament, as well as ALL other 22 documents in her possession or control substantiating the amount she received following 23

24 2 Defendant provided responses to each request along with supplemental responses, which are confusingly numbered in a one, two, three sequence in the stipulation. It is unclear if the plaintiff renumbered them or if this 25 numbering is in the original. 3 1 Mr. Cuomo’s passing. There are no other known responsive documents that are within 2 Ms. Cuomo’s possession or control." RESPONSE NO. 4 – Same as Response No. 3, with 3 the following supplemental paragraph: "Please see documents previously produced and 4 reproduced herewith, bates stamped, DEF_000001 –000022." 5 Similarly, Request No. 3 seeks probate documents. ECF No. 141 at 7 and 8. 6 • REQUEST NO. 3– A COPY OF THE FINAL DISTRIBUTION FROM THE 7 EXECUTOR OR ADMINISTRATOR FOR THE ESTATE OF JOSEPH M. CUOMO. 8 • RESPONSE NO. 1 – "See attached of all documents I have." RESPONSE NO. 2 – 9 "Objection, the term “probate documents” is undefined and is vague and ambiguous. 10 Further, requesting “all” documents is overly burdensome and not proportional to the 11 needs of the case, as “all” documents for the estate of Joseph M. Cuomo are not relevant 12 to whether Ms. Cuomo has any assets that can be used to satisfy the judgment, and 13 production of “all” documents is not proportional to the needs of the case. Without 14 waiver of said objection, Ms. Cuomo is not in possession of any further documents 15 related to the estate of Joseph M. Cuomo beyond those documents produced on August 7, 16 2024."RESPONSE NO. 3 – Same as Response No. 2, with the following supplemental 17 paragraph, in bold (emphasis omitted): It is inaccurate to state that you received no 18 documents responsive to this request. The distribution check ($1,125) was produced to 19 you on August 7, 2024. Further, you state in a conclusory manner that “probate 20 documents” is not ambiguous or vague, but it is so ambiguous and vague that Ms. 21 Cuomo’s production of documents relating to Mr. Cuomo’s estate were not recognized 22 by you.

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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)

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Kelly v. Cuomo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelly-v-cuomo-nvd-2025.