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Williams v. Clark

United States District Court, W.D. Pennsylvania

July 12, 2019





         Shawn L. Williams, a prisoner in the custody of the Pennsylvania Department of Corrections ("DOC"), filed the underlying pro se action on July 31, 2017. ECF No. 1. Presently pending before the Court is Williams' motion to compel discovery based upon alleged deficiencies in Defendants' responses to his interrogatories and request for production of documents.[1] ECF No. 89. For the reasons discussed below, the motion will be GRANTED IN PART and DENIED IN PART.

         I. Standard of Review

         In general, the scope and limits of discovery are governed by Rule 26 of the Federal Rules of Civil Procedure. Specifically, Fed.R.Civ.P. 26 (b) (1) defines the scope of discovery as follows:

Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

Fed. R. Civ. P. 26 (b)(1). Evidence is "relevant 'if it has any tendency to make a fact more or less probable that it would be without the evidence' and 'the fact is of consequence in determining the action.'" Allen v. Eckard, 2019 WL 1099001, at *2 (M.D. Pa. March 3, 2019) (citing In re Suboxone (Buprenorphine Hydrochloride & Naloxone) Antitrust Litig., 2016 WL 3519618, at *3 (E.D. Pa. June 28, 2016). Although relevance in discovery is broader than for evidentiary purposes, it is not without its limits. Stabilus v. Haynsworth, Baldwin, Johnson & Greaves, P.A., 144 F.R.D. 258, 265 (E.D. Pa. 1992). "In ascertaining which materials are discoverable and which are not, a district court must further distinguish between requests that 'appear reasonably calculated to lead to the discovery of admissible evidence, and demands that are 'overly broad and unduly burdensome.'"[2] Westfield Insurance Co. v. Icon Legacy Custom Modular Homes, 321 F.R.D. 107, 111 (E.D. Pa. 2017) (citing Miller v. Hygrade Food Products Corp., 89 F.Supp.2d 643, 657 (E.D. Pa. 2000); see also Bell v. Lockheed Martin Corp., 270 F.R.D. 186, 191 (D.N.J. 2010).

         Federal Rule of Civil Procedure 37 allows a party who receives evasive or incomplete discovery responses to seek a court order compelling additional disclosure or discovery. A party moving to compel discovery bears the initial burden of proving the relevance of the requested information. Olin Corp., 298 F.R.D. at 263 (citing Bracey v. Harlow, 2012 WL 4857790, *2 (W.D. Pa. Oct. 12, 2012). Once that burden is met, "the party resisting the discovery has the burden to establish the lack of relevance by demonstrating that the requested discovery either does not come within the broad scope of relevance as defined under Fed.R.Civ.P. 26(b)(1), or is of such marginal relevance that the potential harm occasioned by discovery would outweigh the ordinary presumption in favor of broad disclosure." Id.

         II. Williams' Claims

         The relevance of each of the discovery requests at issue must be assessed in the context of Williams' claims and the issues of the case. Williams asserts a claim under the Prison Rape Elimination Act, 28 C.F.R. § 115 ("PREA"). See Generally ECF No. 1. Williams alleges that, primarily in 2015, Defendant Beddick subjected him to a "campaign of harassment" in retaliation for his submission of the PREA claim and additional grievances. Williams also alleges that Defendants Girioux, Clark, Franz, Meure, Irwin, Jones, Anders, Bashor, Szelewski, and Susiak acquiesced to Defendant Beddick's conduct and failed to comply with PREA investigation procedures. Id.

         III. Discussion

         Generally, Williams seeks discovery regarding the following: medical and mental health records; information regarding other inmates; copies of Departmental policies and procedure, and Departmental staff assignments. See Generally ECF No. 89. At the outset, the Court notes that Defendants represent that they have already produced much of the information Williams seeks in these requests. Defendants have objected to numerous requests for production of documents and interrogatories concerning which Williams now seeks an order compelling discovery. The subject requests/interrogatories, the Defendants' objections, and the Court's rulings are detailed as follows.

         A. Requests for Production of Documents directed to Defendants Franz, Giroux, Szelewski, Beddick, Anderson, and Bashor

         1. Request Nos. 4 & 5

         In Request No. 4 and No. 5, Williams asks for "any and all records, notes, memos, writings, reports, and filings" contained in the Williams' DC-14 and DC-15 files. ECF No. 89. Defendants object to this request as overbroad and irrelevant. They maintain that the requests encompass "nearly every piece of paper generated by the Department of Corrections on Williams for four years." ECF No. 98. Defendants also object because the request asks for highly confidential information, including mental impressions and considerations of staff members. Id.

         The Court agrees that the requests are overly broad and lack relevancy. Williams' request for these files is not limited to any specific timeframe but instead seeks the files in their entirety-from the date of his incarceration at SCI Albion to the day he sought discovery. The Court also notes that DC-14 counselor documents contain mental impressions of staff members and Defendants have valid security concerns associated with a wholesale release of Williams' records. Confidentiality and security concerns relating to the release of such records outweigh any possible relevance of the information. Finally, the Court notes that Defendants have produced the full grievances from February 2015-October 2017, misconducts B836085 and B591898, and the OSII investigation materials relating to Plaintiff and Defendant Beddick. These documents appear to comprise the investigatory information relevant to the claims and defenses of this case Therefore, the motion to compel is DENIED as to Requests No. 4 and 5.

         2. Request No. 12

         The same is true for Request No. 12. Here, Williams requests the "housing unit log entries from the SCI Albion Diversionary Treatment Unit." ECF No. 89. He claims that the "log entries" are necessary to determine "signature entries of all staff and officials who entered the DTU on December 12, 2015." Id. Defendants objected to this request as irrelevant and unclear as to what "log book entries" Plaintiff is seeking. The Court agrees with Defendants' objection. Further, Williams has not made any proffer to explain why identification of all staff and officials who entered the DTU is relevant or proportional ...

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