Ramiro Ramirez v. Kay County Justice Facilities Authority, a public trust doing business as Kay County Detention Center; Turn Key Health Clinics LLC, a domestic limited liability company; Callie Gray, individually; Josephine Otoo, individually; Don Jones, in his official capacity as Director of the Kay County Detention Center

CourtDistrict Court, W.D. Oklahoma
DecidedDecember 1, 2025
Docket5:21-cv-00971
StatusUnknown

This text of Ramiro Ramirez v. Kay County Justice Facilities Authority, a public trust doing business as Kay County Detention Center; Turn Key Health Clinics LLC, a domestic limited liability company; Callie Gray, individually; Josephine Otoo, individually; Don Jones, in his official capacity as Director of the Kay County Detention Center (Ramiro Ramirez v. Kay County Justice Facilities Authority, a public trust doing business as Kay County Detention Center; Turn Key Health Clinics LLC, a domestic limited liability company; Callie Gray, individually; Josephine Otoo, individually; Don Jones, in his official capacity as Director of the Kay County Detention Center) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramiro Ramirez v. Kay County Justice Facilities Authority, a public trust doing business as Kay County Detention Center; Turn Key Health Clinics LLC, a domestic limited liability company; Callie Gray, individually; Josephine Otoo, individually; Don Jones, in his official capacity as Director of the Kay County Detention Center, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

RAMIRO RAMIREZ, an individual, ) ) Plaintiff, ) ) v. ) Case No. CIV-21-00971-JD ) KAY COUNTY JUSTICE FACILITIES ) AUTHORITY, a public trust doing ) business as Kay County Detention ) Center; TURN KEY HEALTH ) CLINICS LLC, a domestic limited ) liability company; CALLIE GRAY, ) individually; JOSEPHINE OTOO, ) individually; DON JONES, in his ) official capacity as Director of the ) Kay County Detention Center, ) ) Defendants. )

ORDER Before the Court are multiple motions regarding discovery disputes between Plaintiff Ramiro Ramirez and the defendants. First, the Medical Defendants—Turn Key Health Clinics, LLC, d/b/a TK Health, Callie Gray, and Josephine Otoo—filed a Motion for Leave to Amend Their Expert Disclosures and Final Witness List. [Doc. No. 115]. The Court set this motion for expedited briefing and ordered that no replies would be permitted. [Doc. No. 116]. Plaintiff filed a response. [Doc. No. 117]. The Medical Defendants filed a Motion for Leave to File a Reply [Doc. No. 118], and Plaintiff filed a response in opposition [Doc. No. 119]. Second, Defendants Kay County Justice Facilities Authority d/b/a Kay County Detention Center (“KCDC”) and Don Jones, in his official capacity, filed a Motion to Amend Witness List and Exhibit List. [Doc. No. 120]. Plaintiff filed a response [Doc. No. 122] to which Defendants KCDC and Jones replied [Doc. No. 127]. Third, all defendants jointly filed a Motion to Quash Plaintiff’s

Subpoenas Duces Tecum. [Doc. No. 121]. Plaintiff filed a Response in Opposition [Doc. No. 124], and the defendants replied [Doc. No. 136]. Plaintiff then filed a Motion Seeking Leave to File Supplemental Brief to Defendants’ Joint Reply. [Doc. No. 139]. Lastly, Plaintiff filed an Opposed Motion to Extend Remaining Deadlines. [Doc. No. 123]. The Court set this motion for expedited briefing and again ordered that no replies would be permitted. [Doc. No. 130]. The Medical Defendants and Defendants KCDC and

Jones filed separate responses. [Doc. Nos. 140, 141]. Plaintiff moved for leave to file a reply brief. [Doc. No. 142]. Upon consideration of the relevant briefing and applicable legal standards, the Court rules on these motions as follows. I. BACKGROUND This case arises from Plaintiff’s claims that KCDC and its medical staff were both

negligent and deliberately indifferent to Plaintiff’s serious medical needs by failing to provide him adequate medical care after he had a stroke while in custody. The Court entered a Scheduling Order in this case on July 19, 2024. [Doc. No. 54]. Based on the parties’ representation that they anticipated discovery to be completed within eight months [Doc. No. 53 at 4], the Scheduling Order set a deadline of March 10, 2025, for

discovery to be completed [Doc. No. 54 ¶ 6]. In December 2024, the parties jointly moved to extend all unexpired deadlines by 60 days. [Doc. No. 69]. Concluding that the parties only showed good cause to extend their discovery-related deadlines, the Court extended the parties’ deadlines to file expert disclosures, exchange expert reports, and file final witness and exhibit lists by 60 days, and the Court extended the discovery deadline by 45 days, or until April 24, 2025. [Doc. Nos. 70, 71]. The Court later granted an

extension for defendants to file dispositive and Daubert motions based on conflicts with scheduling the deposition of a key expert witness. [Doc. Nos. 89, 98]. On April 29, 2025, the Court granted an unopposed motion by Defendants KCDC and Jones to extend the discovery deadline by an additional 30 days. [Doc. No. 112]. The motion explained that while defense counsel was preparing a motion for summary judgment, he realized that one of defendants’ exhibits—a control center log—had

inadvertently been cut off. [Doc. No. 110 ¶¶ 6, 8]. The defendants obtained a complete copy, which revealed “that a previously unidentified Detention Officer, Janet Harrington, brought Plaintiff back to D pod, his cell, after his relevant meeting and examination by Defendant Nurses, Callie Gray and Josephine Otoo, early on October 21, 2020, at 1:38 a.m.” Id. ¶¶ 9–11. Officer Harrington had not previously been disclosed as a potential

witness. Id. ¶ 12. The Court extended the discovery deadline to June 3, 2025, “to allow the parties an opportunity to locate, contact, and take the deposition of Janet Harrington.” [Doc. No. 112 at 2]. The Court also allowed the parties to re-open the depositions of two jail administrative staff members, Wade Locke and Chuck Creppel, “for the sole purpose of inquiring about the newly produced jail logs or about Harrington.” Id. The Court

issued a Second Amended Scheduling Order and Modified Second Amended Scheduling Order reflecting this updated discovery deadline. [Doc. Nos. 113, 114]. Defendants now seek to modify the scheduling order by amending their final lists of witnesses, final exhibit lists, and expert disclosures after the deadline to file these lists has passed. See [Doc. Nos. 115, 120]. Plaintiff seeks to amend the scheduling order by extending all remaining deadlines—including the discovery deadline and the deadline to

file dispositive and Daubert motions—by 60 days. [Doc. No. 123]. II. LEGAL STANDARD Once the Court has issued a scheduling order, that schedule “may be modified only for good cause and with the judge’s consent.”1 Fed. R. Civ. P. 16(b)(4). “In practice, this standard requires the movant to show the ‘scheduling deadlines cannot be met despite [the movant’s] diligent efforts.’” Gorsuch, Ltd., B.C. v. Wells Fargo Nat’l Bank

Ass’n, 771 F.3d 1230, 1240 (10th Cir. 2014) (alteration in original) (citation omitted). Moreover, the Court and the parties must construe, administer, and employ the Federal Rules of Civil Procedure “to secure the just, speedy, and inexpensive determination of every action and proceeding.” Fed. R. Civ. P. 1. The good cause standard “obligates the moving party to ‘provide an adequate

explanation for any delay.’” Husky Ventures, Inc. v. B55 Invs., Ltd., 911 F.3d 1000, 1020

1 In his responses to Defendants’ motions to modify the scheduling order, Plaintiff cites Federal Rule of Civil Procedure 6(b)(1)(B) and a prior order of the Court in a different case to suggest that the defendants must also show that their failure to act before the deadline was the result of excusable neglect. [Doc. No. 117 at 7–8; Doc. No. 122 at 12–13]. As one leading treatise notes, “[s]ome courts have applied Rule 6(b)(1)(B)’s excusable neglect standard in cases where parties have missed deadlines set by the scheduling order,” but “[t]he better view is that requests to amend the scheduling order should be analyzed under Rule 16(b)’s good cause standard only.” 1 Steven S. Gensler, Federal Rules of Civil Procedure, Rules and Commentary § 16:33 (updated June 2025). In this action, the Court follows this “better view” and analyzes the motions under Rule 16(b)’s good cause standard only. Cf. Camreta v. Greene, 563 U.S.

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Ramiro Ramirez v. Kay County Justice Facilities Authority, a public trust doing business as Kay County Detention Center; Turn Key Health Clinics LLC, a domestic limited liability company; Callie Gray, individually; Josephine Otoo, individually; Don Jones, in his official capacity as Director of the Kay County Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramiro-ramirez-v-kay-county-justice-facilities-authority-a-public-trust-okwd-2025.