Equal Employment Opportunity Commission v. Global Medical Response, Inc. et al

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:22-cv-02544-DDD-SBP
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff,
RAVINDER SINGH,
Plaintiff/Intervenor, and
INDER DHANOTA,
Plaintiff/Intervenor,
v.
GLOBAL MEDICAL RESPONSE, INC., et al.,
Defendants.
ORDER REGARDING DISCOVERY DISPUTES
AND MOTION FOR STATUS CONFERENCE
Susan Prose, United States Magistrate Judge
This matter is before the court on Plaintiffs’ Unopposed Motion for Status Conference,
ECF No. 131, which asks the court to set a status conference to discuss various discovery issues.
The court declines to set a status conference at this time. The court will decide whether a hearing
or status conference is necessary after it receives from the parties a single Joint Discovery Brief
(“JDB”), outlining the complete scope of the parties’ remaining discovery disputes. By means of
the JDB, the court intends to resolve all existing discovery disputes between the parties.
As an initial matter, based on the record at this point, the court is unable to discern
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precisely what discovery disputes remain and what new disputes have emerged. However, in
light of the apparent multiplicity and complexity of the parties’ disagreements, the court deems it
appropriate to assist the parties by setting forth specific requirements for the conferral process
preceding the submission of the JDB.
To begin the process, the parties shall confer by January 31, 2025, to discuss all extant
discovery disputes and to develop a complete list of all unresolved disputes. Following that, on
or before February 14, 2025, Plaintiffs shall prepare a written statement delineating their position
and supporting arguments with respect to each dispute. Plaintiffs shall also propose a
compromise regarding each dispute.
Defendants shall then have until February 28, 2025, to review Plaintiffs’ positions and
arguments and to prepare a written response for Plaintiffs’ review. As with Plaintiffs’ statement,
Defendants shall articulate their position and supporting argument with respect to each dispute
and shall propose their own compromise regarding each dispute. Any argument that a
discovery request is overly burdensome must attempt to quantify the burden on Defendants of
responding to that particular request.
Plaintiffs shall have until March 10, 2025, to reply to Defendants’ positions and
arguments and file the JDB on the court’s docket. Plaintiffs shall respond to each compromise
proposed by Defendants and explain why it is insufficient.
The court will not consider any previously-submitted discovery statements and will look
only to the JDB for the parties’ competing positions and arguments on each discovery issue. The
court does not impose a page- or word-limit on the JDB, trusting that the parties will exercise
their best judgment to provide only the information necessary to allow the court to resolve each
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dispute. The parties may utilize a format of their choosing in presenting the JDB. For example,
the parties might prepare a chart reflecting the parties’ positions on each issue. Regardless of the
format, the JDB should follow an issue-by-issue approach, describing the parties’ respective
positions on each dispute, moving to the next dispute, and so on. The parties may attach
documents and other information they deem necessary for the court to consider.
The court therefore respectfully DENIES without prejudice the Motion for Status
Conference (ECF No. 131) and further ORDERS the submission of a JDB in accordance with
the foregoing specifications.1
DATED: January 17, 2025 	BY THE COURT:
______________________________
Susan Prose
United States Magistrate Judge
1 Rule 72 of the Federal Rules of Civil Procedure provides that within fourteen (14) days after
service of a Magistrate Judge’s order or recommendation, any party may serve and file written
objections with the Clerk of the United States District Court for the District of Colorado. 28
U.S.C. §§ 636(b)(1)(A), (B); Fed. R. Civ. P. 72(a), (b). Failure to make any such objection will
result in a waiver of the right to appeal the Magistrate Judge’s order or recommendation. See
Sinclair Wyo. Ref. Co. v. A & B Builders, Ltd., 989 F.3d 747, 782 (10th Cir. 2021) (firm waiver
rule applies to non-dispositive orders); but see Morales-Fernandez v. INS, 418 F.3d 1116, 1119,
1122 (10th Cir. 2005) (firm waiver rule does not apply when the interests of justice require
review, including when a “pro se litigant has not been informed of the time period for objecting
and the consequences of failing to object”).
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