Ricci v. Discover Bank

2024 NY Slip Op 34346(U)
CourtNew York Supreme Court, New York County
DecidedDecember 12, 2024
DocketIndex No. 157601/2021
StatusUnpublished

This text of 2024 NY Slip Op 34346(U) (Ricci v. Discover Bank) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ricci v. Discover Bank, 2024 NY Slip Op 34346(U) (N.Y. Super. Ct. 2024).

Opinion

Ricci v Discover Bank 2024 NY Slip Op 34346(U) December 12, 2024 Supreme Court, New York County Docket Number: Index No. 157601/2021 Judge: Lyle E. Frank Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 157601/2021 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 12/12/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LYLE E. FRANK PART 11M Justice ---------------------------------------------------------------------------------X INDEX NO. 157601/2021 MICHAEL RICCI, MOTION DATE 09/13/2024 Plaintiff, MOTION SEQ. NO. 003 -v- DISCOVER BANK, DISCOVER FINANCIAL SERVICES, DECISION + ORDER ON ANA VAZQUEZ, MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 56, 57, 58, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90 were read on this motion to/for MISCELLANEOUS .

Upon the foregoing documents, defendant’s motion is denied, and plaintiff’s cross-

motion is granted in part and held in abeyance in part.

Background

Michael Ricci (“Plaintiff”) alleges that while he was dating his now ex-girlfriend Ana

Vazquez (“Vazquez” or “Individual Defendant”), she used his personal information to open a

fraudulent account in his name at Discover Bank (“Discover” or “Corporate Defendant”). When

this was reported, Discover undertook an investigation that concluded that Vazquez had

permission to open the account. Vazquez was later arrested and stated that Discover had not

attempted to verify her statement that she was authorized to open the account. Plaintiff filed suit

against Vazquez and Discover in 2021.

At the time that the suit was filed, Discover was represented by the firm Holland &

Knight LLP. Over the course of discovery (which is not yet complete), the parties exchanged

various documents. These included documents that were stamped “DISCOVER

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CONFIDENTIAL PRODUCTION” at the bottom and documents that contained Plaintiff’s

personally identifiable information. Neither party requested a confidentiality order. Then in

2024, the firm Morgan, Lewis & Bockius was substituted in as Discover’s counsel. When

counsel discovered that there had been no confidentiality order, and that Plaintiff’s counsel had

distributed some of the discovery documents and testimony to third parties, the two sides

conferred on the topic of a confidentiality stipulation and order. While Plaintiff has agreed to the

entry of an order for future discovery, he does not agree to extend that protection to any

documents or testimony already produced.

Discussion

Discover has brought the present motion for an entry of an order for the production and

exchange of confidential information, including the material already produced in the course of

discovery. Plaintiff has opposed and cross-moved for an order compelling discovery of to

produce certain documents and witnesses. For the reasons that follow, Discover’s motion is

denied as to the information produced to date but granted for all forthcoming discovery.

Plaintiff’s cross-motion is granted as to the documents and two of the witnesses requested, with

the rest held in abeyance until after the documents and two witness depositions have been

reviewed.

The Parties Have Waived Confidentiality to This Point

Courts in New York have the power, on their own initiative or by motion of any party, to

issue a protective order limiting the use of discovery material. CPLR § 3103(a). Such

confidentiality orders are “routinely approved and enforced.” Mann v. Cooper Tire Co., 56

A.D.3d 363, 365 (1st Dept. 2008). Courts have broad discretion in tailoring appropriate

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“remedies to prevent the abuse of disclosure devices.” Pursuit Credit Special Opportunity Fund,

L.P. V. Krunchcash, LLC, 227 A.D.3d 628, 628 (1st Dept. 2024). But because of the “broad

constitutional proposition” that the public is generally entitled to have access to court

proceedings, there is a broad “presumption of public access” to such documents. Danco Lab.,

Ltd. v. Chemical Works of Gedeon Richter, Ltd., 274 A.D.2d 1, 6-7 (1st Dept. 2000). Here,

Plaintiff argues that Discover has waived confidentiality on the documents and testimony

produced to date by failing over the course of roughly two years to move for a confidentiality

order. Discover argues that by stamping “CONFIDENTIAL” on the documents, they had not

waived confidentiality.

Under the general concept of waiver:

[d]isclosure of a privileged document generally operates as a waiver of the privilege unless it was shown that the client intended to maintain the confidentiality of the document, that reasonable steps were taken to prevent disclosure, that the party asserting the privilege acted promptly after discovering the disclosure to remedy the situation, and that the parties who received the documents will not suffer undue prejudice if a protective order against use of the document is issued. N.Y. Times Newspaper Div. v. Lehrer McGovern Bovis, Inc., 300 A.D.2d 169, 172 (1st Dept. 2002); see also AFA Protective Sys. v. City of New York, 13 A.D.3d 564, 565 (2nd Dept. 2004).

Discover here waited years after producing the documents and long after becoming aware that

the documents were being disseminated to third parties to move for a confidentiality order

protecting the documents and testimony in question. This is not a reasonable time nor is it acting

promptly to remedy the dissemination. While the parties agree on a confidentiality order moving

forward, the Court declines to extend that protection to documents and testimony that has been

produced to date.

Plaintiff’s Discovery Cross-Motion is Granted in Part and Stayed in Part

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Plaintiff has made a cross motion to compel discovery of selected documents and eight

additional witnesses, arguing that Discover’s prior counsel had agreed to the document

production. They also argue that the number of requested witnesses is required due to the

decentralized process and multiple investigations that Discover made into the account in

question. Discover objects on the grounds that the discovery sought is not relevant and that the

additional witnesses would be redundant, given the four that Discover has already produced.

Discover has already, through prior counsel, agreed to produce the documents in question and at

oral argument, counsel for Discover reiterated this position. As regards the requested witnesses,

the Court will permit two of the eight to be deposed, with the rest held in abeyance while

Plaintiff reviews the requested documents and two testimonies.

At oral argument, counsel for plaintiff agreed to limit their request for witnesses to two

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Related

AFA Protective Systems, Inc. v. City of New York
13 A.D.3d 564 (Appellate Division of the Supreme Court of New York, 2004)
Danco Laboratories, Ltd. v. Chemical Works of Gedeon Richter, Ltd.
274 A.D.2d 1 (Appellate Division of the Supreme Court of New York, 2000)
New York Times Newspaper Division v. Lehrer McGovern Bovis, Inc.
300 A.D.2d 169 (Appellate Division of the Supreme Court of New York, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
2024 NY Slip Op 34346(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/ricci-v-discover-bank-nysupctnewyork-2024.