Vincent Artis v. Phelps Memorial Hospital Association, et al.

District Court, S.D. New York·Decided January 7, 2026·No. 7:23-cv-09827·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

VINCENT ARTIS MOTION FOR STAY Plaintiff No: 7:23-cv-09827-KMK -against- PHELPS MEMORIAL HOSPITAL ASSOCIATION, et, al., Defendants

I (Vincent Artis) would like to have a Stay pending my appeals for the following reasons;

The appeal! court wil! only allow an appeal where the decision of the lower court was: 1. Wrong, or 2. Unjust because of serious procedural or other irregularity in the proceedings in the lower court. (lets look at that quote for a minute) that is a very powerful quote, so in order to prove my case for a Stay my argument have to match this quote. (1) | said that Defendants lawyer should not have been granted the rights to see my mental and physical records; | have said somethings on my appeal, but | left out the most important piece of evidence; | have a case 25-cv-09045 in Judge Seibel court and | sent in my physical and mental permanent injury report. {Please see attached exhibit A} and this complaint lawsuit was filed before this matter came up in your court. The reason this is EXTREMELY important is because of the rules of "res judicata and collateral estoppa!" Which means | cannot bring up the same things in different law suits | do not have to recite cases because this is the rules and facts. My other case 25-cv-09045 talks about | got hurt on the job and that was after | put my original complaint in (7:23-cv-09827-KMK) and if you Jook at it my original complaint there is nothing saying | ask for Physical damages so Judge Krause should have never granted that. (The court of appeals will only allow an appeal when the decision of the lower court was: 1. Wrong, 2. Unjust because of serious procedural or other irregularity in the proceedings in the lower court} Now lets look at Mental; | have admitted to not seeking mental help until after | got hurt on the job (11/2-3/22) my complaint was in way before that and | was still working when | put my original complaint in. Judge Krause should have never granted access to all my mental records because that will be - covered in another case that is still pending and the rules of "res judicata and collateral estoppal" states | cannot bring up the same issues in another law suit. (The appeal court will only allow an appeal when the decision of the lower court was: 1. Wrong, or 2. Unjust because of serious procedural or other irregularity in the proceedings in the lower court. My

mental and Physical permanent injury(s) report shows these matters will be addressed in another complaint (25-09045) Also please note that Judge Seibel have denied my complaint, but she said | should file in State court. Which shows my complaint have merit, But | am appealing her decision with the court of appeals, and as long as | am appealing her decision it means my claims and complaint is still alive in the court system. (The law) (2) Federal Rule Of Civil Procedure (FRCP) have this thing called the “IN CONTROVERSY REQIREMENT” The physical condition must be a genuine issue in the case What makes this rule so important is because | never said or listed a physical injury in my complaint, and the ONLY way Defendants lawyer have any merit to there claim if | would have Amend my complaint. (3) Judge Krause ruled that if anybody talk to me or text me about Phelps hospital, | have to report it to the defendants lawyers. And he made that decision after defendants lawyer only argument was "I complained" On 12/22/25 in court t asked to see defendants personal cell phone records and Judge Krause said "no that is personal" see the problem with that is supervisor Diego is all over my complaint so at least there is somewhat of a probable cause, by judge Krause saying | have to report anything about Phelps hospital to defendants lawyers on my personal phone and not do the same with defendants phone then Bias and prejudice will automatically be assumed. {1 am appealing that decision, see attached to this motion) ALSO, Phelps hospital have a portal that all employees are hooked up to so they can talk to each other, the only rights Phelps have on this matter is to look at all the messages in that portal. (Please see exhibit D attached) my arguments with case law: In McMahan v. New York Organ Donor Network Inc; No. 156669/12,2016WL 1251204(NY sup. CT Mar. 28, 2016) Personal records must be disclosed, at least to the extent of requiring an in camera inspection by the court, whenever there is a reasonable possibility that these files contain relevant and material documents..... (Lets look at another case) Ladson v. Ulitra East Parking Corp, 878 F. Supp 25(S.D.NLY. 1995) this was a real dirty case, and as ugly as it can get. But, it shows the importancy of seeing employees records especially when it comes to Retaliation and Discrimination cases, which my case falls under. The case states that "All must be shown is that the Discovery requested possibly might be relevant. Henderson v. National R.R Passenger Corp 113 F.R.D 502, 506, (No. 111 1986) OR! 's reasonably calculated to lead to the Discovery of admissible evidence. Fed. R. Civ Pro 26(b)(1) Rozier v. ford motors Co. 573 F2d 1332, 1342-43 this is extremely important because supervisor Diego is all aver my complaint and Tony is too. (4)In Federal Civil Courts in NY (and generally) judges can err by admitting irrelevant, overly broad, or prejudicial discovery (Discovery not relevant to the case), but it’s often challenged via motions to compel/limit discovery or appeals, with courts generally favoring relevance under Federal Rules of Civil Procedure (FRCP) 26(b)(1) requiring proportionality), through sometimes judges admit wide-ranging info if potentially relevant, leading to appeals for abuse of discretion, like in cases where scope is abused or sanctions are improper, requiring parties to show the judge clearly exceeded bounds, as seen in general discovery disputes where courts struggle to balance access vs. burden. Types of Discovery Errors (Not Specific Cases, but Patterns) 1. Overly Broad Requests: Allowing discovery into a party's entire life/business when only a narrow aspect is relevant to the case.

2. Irrelevant Information: Admitting data/documents with no logical connection to the claims or defenses. 3. Undue Burden/Proportionality Issues: Forcing production of massive data when a small sample would suffice (violating FRCP 26(b)(1) 4. Confidentiality Breaches: Allowing disclosure of trade secrets or private info without proper protection | am saying Judge Krause is guilty in all these offenses. And the only way | can obtain justice from these errors 1. Motions for Protective orders (FRCP 26@©: Parties ask the judge to limit or deny discovery if it is irrelevant, harassing, or unduly burdensome. 2. Appeals (Abuse of Discretion): If a judge makes a clear, harmful discovery ruling (e.g., forcing irrelevant data), it can be grounds for appeal, though appellate courts often defer to trial judges 3. (Vincent Artis) is not a lawyer nor do | practice law, if its my right to add 1 and 2 to this motion then please do. (5) The court have to take in account that | filed a complaint on judge Krause. (Please see attached)

IN CONCLUSION: I like to first apologize to the court on a couple of my other motions, | talked angry and hurt which is not cool at all. | will be better for now on. In conclusion: | would like the judge to grant all my request and grant me a Stay or have a hearing on all these matters. Defendants are to respond to this application by 1/9/26. Sincerely The Clerk is respectfully directed to Vineerit Ariis\Rro-sa mail this document to Plaintiff. 23-cv-09827-KMK SoOrdered Se >

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Vincent Artis v. Phelps Memorial Hospital Association, et al., (S.D.N.Y. 2026).

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