Patty Carambot, Ph.D. v. New York City Health and Hospitals Corporation, et al.

CourtDistrict Court, S.D. New York
DecidedJanuary 13, 2026
Docket1:24-cv-00841
StatusUnknown

This text of Patty Carambot, Ph.D. v. New York City Health and Hospitals Corporation, et al. (Patty Carambot, Ph.D. v. New York City Health and Hospitals Corporation, et al.) 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
Patty Carambot, Ph.D. v. New York City Health and Hospitals Corporation, et al., (S.D.N.Y. 2026).

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT aa. FILED SOUTHERN DISTRICT OF NEW YORK DATE FILED: 01/13/26 PATTY CARAMBOT, Ph.D., Plaintiff, 24-CV-841 (JPO) (BCM) -against- MEMORANDUM AND ORDER NEW YORK CITY HEALTH AND HOSPITALS CORPORATION, et al, Defendants.

BARBARA MOSES, United States Magistrate Judge. Plaintiff Patty Carambot worked as a forensic criminal psychologist for the New York City Health and Hospitals Corporation (HHC) in its Correctional Health Services (CHS) department, providing mental health care to detainees at the Rikers Island Correctional Facility (Rikers), which is operated by the New York City Department of Correction (DOC). See Compl. (Dkt. 9) [§ 6, 17- 19; Carambot v. New York City Health & Hosps. Corp., 2025 WL 753893, at *1 (S.D.N.Y. Mar. 10, 2025). Plaintiff brought this action under 42 U.S.C. § 1983 and New York Civil Service Law § 75-b, alleging that she was suspended in August 2023 and fired in October of that year because she "expressed concern over the conditions at Rikers," in violation of her First Amendment rights and in retaliation for her efforts to report constitutionally deficient treatment of detainees. Compl. 135-54; Carambot, 2025 WL 753893, at *3. On March 10, 2025, the Hon. J. Paul Oetken, United States District Judge, permitted plaintiff to proceed on her § 1983 claim, but only against three individual defendants: her supervisor Virginia Fineran, the Director of Mental Health Services at Rikers; Patricia Yang, a CHS Senior Vice President; and Jessica Laboy, CHS's Chief Administrative Officer. Carambot, 2025 WL 753893, at *8-10. Additionally, the District Judge permitted plaintiff to proceed against HHC under § 75-b. /d. at *10. The parties are now engaged in discovery. On November 14, 2025, plaintiff served a notice of deposition for the three individual defendants and ten additional witnesses, all of whom are

current or former employees of HHC or DOC. On December 16, 2025, defendants filed a letter- motion seeking a protective order, pursuant to Fed. R. Civ. P. 26(c)(1)(A), "preventing the depositions" of nine of those witnesses. Def. Mot. (Dkt. 76) at 1. On December 19, 2025, plaintiff filed a letter opposing defendants' motion and cross-moving, pursuant to Fed. R. Civ. P.

30(a)(2)(A)(i), for leave "to take more than ten depositions." Pl. Opp. (Dkt. 77) at 1. On December 22, 2025, defendants filed a letter in further support of their protective order motion, see Def. Reply (Dkt. 79) at 1, and in opposition to the cross-motion. For the reasons that follow, defendants' motion will be granted in part – as to four of the challenged witnesses – and plaintiff's motion will be denied without prejudice. I. STANDARDS A. Rules 26(b)(1), (b)(2)(C), and (c)(1)(A) Ordinarily, a party may obtain discovery of "any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case[.]" Fed. R. Civ. P. 26(b)(1). Since "information within this scope of discovery need not be admissible in evidence to be discoverable," id., "the Rule 26(b)(1) standard presents a 'relatively low threshold[.]'" John Wiley

& Sons, Inc. v. Book Dog Books, LLC, 298 F.R.D. 184, 186 (S.D.N.Y. 2014) (quoting In re Zyprexa Injunction, 474 F. Supp. 2d 385, 421 (E.D.N.Y. 2007)). "However, district courts have 'broad discretion to manage the manner in which discovery proceeds.'" DoubleLine Cap. LP v. Odebrecht Fin., Ltd., 2022 WL 2162992, at *2 (S.D.N.Y. May 31, 2022) (quoting Diamond v. 500 SLD LLC, 2022 WL 956262, at *2 (S.D.N.Y. Mar. 30, 2022)). Under Rule 26(b)(2)(C), a court must limit the "extent of discovery otherwise allowed" if it is "unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive" or if it is "outside the scope permitted by Rule 26(b)(1)." Fed. R. Civ. P. 26(b)(2)(C)(i), (iii). Additionally, a court may, on motion, issue a protective order to safeguard a party or witness "from annoyance, embarrassment, oppression, or undue burden or expense," including by "forbidding" the challenged discovery, Fed. R. Civ. P. 26(c)(1)(A), "but the moving party bears the burden of establishing good cause for such a protective order." Rekor Sys., Inc. v. Loughlin, 2022 WL 488941, at *1 (S.D.N.Y. Feb. 17, 2022)

(quoting Qube Films Ltd. v. Padell, 2015 WL 109628, at *2 (S.D.N.Y. Jan. 5, 2015)); see also Khan v. New York City, 757 F. Supp. 3d 327, 338 (E.D.N.Y. 2024) ("[T]he party seeking the protective order bears the burden of establishing good cause under Fed. R. Civ. P. 26(c).") (citation omitted). B. Apex Doctrine Courts frequently rely on Rule 26(c)(1)(A) to prohibit depositions of "high-ranking government official[s]." Lederman v. New York City Dep't of Parks & Recreation, 731 F.3d 199, 203 (2d Cir. 2013) (quoting United States v. Morgan, 313 U.S. 409, 422 (1941), and upholding district court's Rule 26(c) order prohibiting plaintiffs from taking the depositions of the Mayor and a former Deputy Mayor of New York in a First Amendment-based challenge to the City's efforts to prevent visual artists from selling their works on sidewalks and in parks). The standard for

conducting such a deposition – known as an "apex deposition" – is high: "[T]o depose a high- ranking government official, a party must demonstrate exceptional circumstances justifying the deposition – for example, that the official has unique first-hand knowledge related to the litigated claims or that the necessary information cannot be obtained through other, less burdensome or intrusive means." Id.; see also Loc. 2507, Uniformed EMTs, Paramedics & Fire Inspectors v. City of New York, 787 F. Supp. 3d 4, 6 (S.D.N.Y. 2025) (applying Lederman standard to prohibit plaintiffs from deposing Fire Commissioner in civil rights suit where plaintiffs did not show "that the Commissioner has any unique or first-hand knowledge"). The party seeking the apex deposition "bear[s] the burden of showing that the deposition of the [high-ranking official] is appropriate under these criteria." Winfield v. City of New York, 2018 WL 4350246, at *1 (S.D.N.Y. Sept. 12, 2018). For purposes of the apex doctrine, the question whether a proposed witness qualifies as a "high-ranking government officer" is determined "on a case-by-case basis." In re Terrorist Attacks

on Sept. 11, 2001, 2020 WL 8611024, at *12 (S.D.N.Y. Aug. 27, 2020) (internal quotation and citation omitted), adopted, 2021 WL 2227204 (S.D.N.Y. June 2, 2021). However – as the label itself implies – the doctrine has "generally only been applied to government officials who are at the apex of their organization." Sec. & Exch. Comm'n v. Comm. on Ways & Means of the U.S. House of Representatives, 161 F. Supp. 3d 199, 250 (S.D.N.Y. 2015) (collecting cases); accord In re Terrorist Attacks, 2020 WL 8611024, at *12.

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Patty Carambot, Ph.D. v. New York City Health and Hospitals Corporation, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/patty-carambot-phd-v-new-york-city-health-and-hospitals-corporation-et-nysd-2026.