Loren Chanderl v. Bayhealth Medical Center, Inc.

Wilmington, Delaware employment law lawyer represented the Plaintiff who sued on a employment discrimination theory.



On May 29, 2018, Defendant hired Plaintiff.[4] Defendant first allegedly discriminated against Plaintiff on the basis of race in January 2020, and Plaintiff first allegedly suffered retaliation in March 2020, when she was transferred to another role in Defendant's employ.[5] Plaintiff details various grievances thereafter, culminating in a dispute over her organization of a going-away party for a colleague on November 30, 2020, ostensibly in violation of Defendant's Covid-19 protocols.[6]According to Plaintiff, Defendant's employees unjustifiably "interrogated" her about this event on December 7, 2020.[7] Defendant terminated Plaintiff's employment on December 22, 2020.[8] On July 23, 2021, Plaintiff filed a Charge of Discrimination with the Delaware Department of Labor and with the Equal Employment Opportunity Commission.[9] On December 14, 2022, Plaintiff filed her Complaint with this Court, claiming racial discrimination and retaliation.



EMPLOYMENT LAW. DISCOVERY IN EMPLOYMENT DISCRIMINATION CASES. The case involves a motion for a limited extension of discovery in an employment discrimination suit, assessing whether the defendant failed to present an adequately prepared Rule 30(b)(6) witness related to the plaintiff's alleged wrongful termination.



CIVIL PROCEDURE. RULE 30(B)(6) DEPOSITION OBLIGATIONS. The court examines whether the defendant satisfied its obligations to provide complete responses via its corporate designee under Rule 30(b)(6) given the notice provided, and whether inadequate preparation constituted grounds for extending discovery.



CIVIL PROCEDURE. GOOD CAUSE FOR DISCOVERY EXTENSION. The judgment addresses the standard of "good cause" required to modify a scheduling order prior to a pretrial conference, focusing on whether the plaintiff acted with due diligence and the unforeseeability of needing additional discovery.



CIVIL PROCEDURE. PREJUDICE IN DISCOVERY EXTENSIONS. The court considers the potential prejudice to both parties in granting a discovery extension, weighing the impact of plaintiff's limited extension motion against any claimed prejudice to the defendant.



Key Phrases Employment discrimination suit. Limited extension of discovery. Rule 30(b)(6) witness. Covid-19 policies. Sign-in policy.