Kiss v. Kenny

CourtDistrict Court, S.D. New York
DecidedMay 9, 2025
Docket7:22-cv-10663
StatusUnknown

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

Bluebook
Kiss v. Kenny, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT See eee eee ORS x DANIEL KISS, ORDER Plaintiff, 22 Civ. 10663 (CS)(JCM) -against- JANET KENNY, DEBRA RUBIN, Defendants, ence cece □□□□□□□□□□□□□□□□□□□□□□□□□□□□ cence K Presently before the Court are a flurry of letters taking issue with pro se Plaintiff Daniel Kiss’ discovery demands, dated April 25, 2025 (“April 25, 2025 Demands”), and his revised discovery demands, dated April 30, 2025 (“April 30, 2025 Demands”). (Docket Nos, 78, 79, 81, 83). Plaintiff responds to these objections and seeks the Court’s approval of his expanded interrogatories and an order directing Defendants Janet Kenny and Debra Rubin (collectively, “Defendants”) to respond to them. (Docket Nos. 80, 84), For the following reasons, the parties’ motions are granted in part and denied in part. It is undisputed that the April 25, 2025 Demands and the April 30, 2025 Demands exceed the parameters of Local Rule 33.3. (Docket Nos. 78, 79, 80, 81, 83). The issue now before the Court is whether they should be allowed. During the March 31, 2025 Status Conference, Plaintiff informed the Court that he would not be taking depositions due to the cost associated with them. In his May 2, 2025 letter, Plaintiff further explained that his expanded interrogatories were a more practical means of obtaining relevant information because he lacks the financial resources to conduct depositions. (Docket No, 80). Defendant Kenny opposes this request.

(Docket No. 81).! Defendant Rubin also asserts several interrogatories are “totally inappropriate as to their content” and reflect cross-examination questions. (Docket No. 83 at 1). Local Rule 33.3(b) “permits the use of interrogatories if they are a more practical method of obtaining the information sought than a request for production or a deposition.” McConnell v. Pepp, No, 89 Civ. 2604 (MIL), 1991 WL 50965, at *1 (S.D.N.Y. Apr. 3, 1991) (directing defendants to answer specific interrogatories but not those calling for legal conclusions). While there is a mechanism to depose parties through the use of written questions, “[t]here are cases in which interrogatories may be preferable to deposition by written question.” Manigaulte v. Long Island Univ., CV 08-1853 (IS)(WDW), 2010 WL 11632628, at *3 (E.D.N.Y. Nov. 5, 2010), aff'd sub nom. Manigaulte v. CW. Post of Long Island Univ., 2010 WL 11632629 (E.D.NLY. Dec. 10, 2010) (citing McConnell, 1991 WL 50965, at *1). In addition, if interrogatories are more practical, the parties may go beyond the bounds of Local Rule 33.3(a). See CG3 Media, LLC v. Belleau Techs., LLC, 1:21-cv-04607-MKV, 2022 WL 1172499, at *1 (S.D.N.Y. Apr. 20, 2022). In such a case, the Court examines “each interrogatory seriatim’” to determine if it is a “more practical method of obtaining the information sought.” Roelcke v. Zip Aviation, LLC, 15- CV-6284 (JIGK)GLC), 2020 WL 5752228, at *1-2 (S.D.N.Y. Sept. 25, 2020), Given Plaintiff's pro se status and limited resources, the Court will permit Plaintiff to obtain information through the use of broader interrogatories rather than through depositions.’

' Defendant Kenny claims the Court “already ruled that Mr. Kiss cannot use interrogatories in lieu of depositions.” (Docket No. 81 at 1). However, the Court never specifically ruled on whether the Plaintiff could use interrogatories in lieu of depositions. 2 If Plaintiff does not have access to cases cited herein that are available only by electronic database, then he may request copies from Defendants’ counsel. See Local Civ. R. 7.2 (“Upon request, counse! must provide the pro se litigant with copies of such unpublished cases and other authorities as are cited in a decision of the court and were not previously cited by any party.”). 3 Defendant Kenny argues the local rules do not address a party’s financial ability to pay and that if they did, the courts might require financial proof. (Docket No. 81 at 1). However, Plaintiff has jn forma pauperis status, (Docket No. 5}, and courts in this District have permitted pro se plaintiffs to issue interrogatories in lieu of depositions for

2.

Cardew v. Fleetwood, No, 98 Civ. 4704 (SHS)(DFE), 1999 WL 1067867, at *1 (S.D.N.Y. Nov. 23, 1999), on reconsideration, 2000 WL 310362 (S.D.N.Y. Mar, 27, 2000); see also Boomer v. Grant, Nos, 00 CIV 4709 (DLC\ AJP), 00 CIV 5540 (DLC\AJP), 2001 WL 1580237, at *1 (S.D.N.Y, Dec. 12, 2001) (permitting plaintiff to depose defendants through interrogatories and/or through depositions on written questions). Such interrogatories will not be subject to the subject matter limitation in Local Civil Rule 33.3. See Riddle v. Liz Claiborne, Inc., No. 00 Civ. 1374 (MBM)(HBP), 2003 WL 21982967, at *1 (S.D.N.Y. Aug, 19, 2003). In addition, the Court will grant Plaintiff permission to serve interrogatories beyond the 25 permitted by Rule 33(a)(1). See id. (permitting the pro se plaintiff to serve additional interrogatories after her initial 25 interrogatories, in lieu of a deposition). The Court has reviewed the April 25, 2025 Demands and April 30, 2025 Demands in light of this ruling, and its specific findings relating to each request are set forth herein. I. DISCOVERY DEMANDS FOR DEFENDANT JANET KENNY With respect to the demands addressed to Defendant Janet Kenny, the Court makes the following rulings. 1. Interrogatory Numbers 3, 4, 5, 6, 8 and 9 of the April 30, 2025 Demands seek factual information. (Docket No. 79-1). Therefore, Defendant Kenny must answer them as written. 2. The Court has also reviewed the April 30, 2025 Demands and takes the liberty to modify some of the interrogatories so that they do not ask for legal conclusions, are clearer, and allow Plaintiff to obtain the relevant information he seeks. As a result, Defendant Kenny must respond to the following modified interrogatories:

financial reasons, See Riddle v. Liz Claiborne, Inc,, No. 00 Civ. 1374 (MBM)(HBP), 2003 WL 21982967, at *1 (S.D.N.Y. Aug. 19, 2003).

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e Interrogatory Number 1: On December 18, 2019, you and six others arrived at Sharon Kenny’s house to collect her valuables. Were Plaintiff and his wife present at the time? Did Plaintiff and his wife offer any assistance, and did Plaintiff specifically help load the items into your vehicles? e iInterrogatory Number 2: From December 18, 2019, to February 13, 2020, did you allow the Plaintiff and his spouse to freely remove their personal belongings from the house and the shed? e Interrogatory Number 10: Debra Rubin stated in her deposition: “Why don’t we just let him go? Janet told me there was nothing in the shed that resembled tools, even though he talked about them a lot.” Please explain why you refused to return the Plaintiff's property. e Interrogatory Number 12: “In your deposition, you stated: ‘And they had put a van, a green van pulled up to the house, and it was passed — the back of the van was inside the garage, so you could not see what was going on, That is what prompted my phone call.’ On the day you called 911, five police officers saw that the van was not inside the garage but parked approximately 20 feet away. The garage was full of items, making it physically impossible for a vehicle to enter.” Why did you say this? e Interrogatory Number 13: “Debra Rubin’s deposition states: ‘] know that Janet had asked him to stay there’ and ‘I understand that Janet is working with a lawyer to work out an atrrangement.’” Did you tell Debra that you had asked Plaintiff and his wife to stay in the house after your father left the residence?

4.

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