MCFADYEN et al v. DUKE UNIVERSITY et al

Filing 254

RESPONSE in Opposition re #249 MOTION for Protective Order, #250 Brief filed by BRECK ARCHER, RYAN MCFADYEN, MATTHEW WILSON. Replies due by 1/17/2012. (EKSTRAND, ROBERT)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
RYAN McFADYEN, et al.,
Plaintiffs,
v.

1:07 CV 953

DUKE UNIVERSITY, et al.
Defendants.

PLAINTIFFS’ RESPONSE TO THE DUKE DEFENDANTS’
MOTION FOR A PROTECTIVE ORDER REGARDING
SUBPOENAS TO TWO MEDIA CONSULTING FIRMS

The matter before the Court is the Duke Defendants' Motion and Brief [Doc.
Nos. 249-252] for a protective order regarding Plaintiffs' subpoenas to two media
consulting firms that Duke retained to design and implement its media strategy in
connection with the events alleged in Plaintiffs’ Second Amended Complaint [Doc.
No. 136]. The Duke Defendants seek the most extraordinary relief available under
Rule 26(c) - an order preventing Plaintiffs from discovering the materials sought by
Plaintiffs’ subpoenas. The Motion should be denied because Defendants fail to meet
their “heavy burden” of making “a specific demonstration of facts” sufficient to show
that they are entitled to the extraordinary protection they seek. Instead, the Duke
Defendants rely solely on bald, conclusory assertions, unadorned by any specific facts,

which this Court does not consider on a motion under Rule 26(c).

Indeed,

Defendants’ Motion is so patently meritless, the Court should summarily deny the
motion and permit no further briefing on it.
RELEVANT FACTS
A.

Duke's Media Strategy

It is already apparent from the limited discovery that the University’s strategic
intent was to sever Plaintiffs from the University in as visible a manner as possible.
Senior members of the media consulting firms themselves wrote extensively about
that and media reports from the relevant period also contain admissions to the same
effect. Duke’s strategy was to alienate, stigmatize, ostracize, and separate the Plaintiffs
from the University.
Discovery already shows that Duke employed several means of doing so. Most
relevant to this motion with regards to Count 21 is that Duke did so by suspending
Plaintiffs through gross violations of the written procedural protections that Duke
promises to all of its students. Thus, Duke employed its media strategy to separate
Plaintiffs from the University—literally—by suspending them, and then amplified the
public perception of their separation by making public statements to a nationwide
audience announcing Plaintiffs’ suspensions from the University and subjecting
Plaintiffs to further public humiliation and obloquy.

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Furthermore, with regards to Count 24, discovery has also revealed the
University’s public relations strategy to make false representations to the public in an
attempt to cover up and conceal from Plaintiffs and the public the fact that Plaintiffs’
educational records and information sought in the subpoena had already been
disclosed illegally by Duke University months before. An example of the University’s
public relations strategy to emphatically (and falsely) conceal the University’s
unauthorized and unlawful disclosure of Plaintiffs’ educational records, specifically in
this case by John Burness, Senior Vice President for Public Affairs and Government
Relations, is attached hereto as EXHIBIT 1.
Despite the Duke Defendants’ refusal to produce more than 27 documents1 in
all of their initial disclosures and responses to Plaintiffs’ First Request for Production
of Documents, there is still ample evidence that Duke’s media strategy drove its
decision-making, including its decisions to deprive Plaintiffs of the procedural
protections it promises to all of its students in connection with its disciplinary
proceedings. For example:
•

Early emails that circled among University administrators regarding

Mangum’s allegations, attached hereto as EXHIBIT 2, primarily involved public

1

Among the 27 documents are several duplicates.  

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relations and communications strategists.

For example, one of the first written

communications (if not the first) from any Duke administrator regarding Mangum’s
allegations—Sue Wasiolek’s March 17, 2006 e-mail2—was circulated to virtually every
senior media relations employee of the University, including (1) Duke’s Senior Vice
President for Public Affairs and Government Relations; (2) Duke’s Director of
Communications for the Office of Student Affairs and Spokesman for the University;
(3) Duke’s Senior Communication Strategist; (4) Duke’s Associate Vice President for
News and Communications; (5) Duke’s Assistant Vice President for the Office of
Communication Services; (6) Duke’s Director of Media Relations; (7) Duke’s Senior
Public Relations Specialist; and (7) Duke’s Sports Information Director.
•

In his deposition on December 2, 2011, Dr. Christopher Kennedy, who

was Duke University’s Associate Athletic Director in 2006 and is its current Deputy
Director of Athletics, testified that he was never consulted about the matter; rather
the media strategy designed by the University’s media consulting firms drove the
University’s decision-making throughout the relevant period. See, e.g., EXHIBIT 3,
Tr. of Kennedy Dep. at 39, 98, 101-102, 151-152, EXHIBIT 4 at 2, Exhibit 5 at 3,
and Exhibit 6 at 14. For example, regarding President Brodhead’s statement “[i]f [the]

None of the Duke Defendants produced Wasiolek’s March 17, 2006 e-mail. It is
one of the many documents that the Duke Defendants continue to withhold without
justification.  
2

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students did what is alleged, it is appalling to the worst degree. If they didn't do it,
whatever they did was bad enough,” Dr. Kennedy explained that “someone without
any knowledge of any of the facts, someone on the outside would again draw the
conclusion that some kind of crime had been committed and that Brodhead believed
they were guilty. And furthermore, I think it was incredibly indiscreet to say whatever
they did was bad enough.” Kennedy Dep. 98:2-15 (Dec. 2, 2011). Regarding the
public statements made by the University’s response to Mangum’s false allegations,
Dr. Kennedy’s advice would have been “to shut up, … every time something
happened, it seemed as if (the University) needed to make a statement.” Kennedy
Dep. 152:2-5.
Richard Edelman himself published his own position, and presumably that of
his Firm, to a world-wide audience, including the following statements:
[T]here are times when the court of public opinion needs heavier
weighting than those applied in the legal courtroom. This could
be one of those cases. The best type of statement in the days just
following the event would have established … a determination to
understand the root causes of the problem and a restatement of
[Brodhead’s] commitment to the rights of the accuser, not just the
accused. There had to be a separation of the interests of the
accused and those of the university … .
Attached hereto as EXHIBIT 7.

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B.

Duke's Media Consultants

The targets of the two subpoenas at issue are the two media consulting firms,
Burson-Marsteller and Edelman, Duke employed to provide media strategy services in
connection with its public response to the false allegations that give rise to this case.3
C.

Plaintiffs’ Subpoenas to Duke’s Media Consultants

The Duke Defendants mislead the Court when they assert that Plaintiffs’
subpoenas seek “‘all materials’ relating to the media consultants’ work with Duke
University.’" Defs.’ Mot. ¶ 3 at 2. To the contrary, Plaintiffs’ subpoenas are narrowly
drawn. Plaintiffs’ subpoena to Burson-Marstellar to request documents in either the
corporation’s possession, custody, or control relating to the Plaintiffs, their
suspensions, their teammates, the Duke University Men’s Lacrosse Team, any
investigation of Plaintiffs, their teammates, or Crystal Mangum’s false accusations (e.g.,
that Plaintiffs were principals or accomplices in a brutal, thirty-minute, racially
motivated gang rape), the management of the University’s public response
(specifically advice and strategic assistance provided by Burson-Marsteller to the
University regarding the University’s response to press inquiries, alumni inquiries, the
University’s crisis management, and the University’s issued public statements), the

Duke Defendants failed to identify either consultant in its Initial Disclosures, but
their employment during the relevant time was leaked to the public, often by the consultants
themselves. otherwise plaintiffs would not have discovered either relationship.  
3

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University’s public response on April 5, 2006—the day Plaintiff Ryan McFadyen was
unilaterally suspended in violation of every procedural protection the University
promises to all students before taking such action. The Complaint itself contains
video of President Brodhead publicly declaring that McFadyen was suspended.
D. The Duke Defendants’ Own, Expansive Discovery Requests
Highly relevant to this Motion are the Duke Defendants’ own expansive
discovery requests. For example, one such request required Plaintiffs to produce all
documents in their possession custody or control concerning Mangum’s allegations.
EXHIBIT 8 at 8 (Duke Defendants’ First Request for Production of Documents).
The Duke Defendants’ also compelled Plaintiffs to produce all videotapes or photographs
regarding the subject matter of this litigation. Id. Plaintiffs have complied in good faith
with Duke’s unfettered requests. In all, Plaintiffs have produced thousands of pages
of documents in response to the Duke Defendants’ requests, and a virtual a library of
audio and video recordings of the Duke Defendants engaging in the conduct alleged
in the Second Amended Complaint. For their part, the Duke Defendants have
delayed, obstructed, and produced next to nothing: collectively the Duke Defendants
have produced 27 documents to date (including several duplicates). Through this
Motion, the Duke Defendants now seek to prevent Plaintiffs from obtaining
documents from non-parties that may some of the materials that the Duke Defendants
themselves should have produced to Plaintiffs long ago.
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THE STANDARD OF REVIEW
Rule 45
Subpoenas are governed by Fed. R. Civ. P. Rule 45. Rule 45(c)(3) provides the
mechanism “to protect a person subject to or affected by a subpoena” to quash or
modify the subpoena. Fed. R. Civ. P. R. 45. The Duke Defendants’ Motion is not
made pursuant to Rule 45, the time for doing so expired long ago, and the venue for a
Motion is in the court from which the subpoenas issued (i.e., the United States
District Court for the Southern District of New York and the Northern District of
Illinois). Therefore, the Duke Defendants have abandoned any claim for protection
under Rule 45, and proceed solely under under Rule 26(c).
Rule 26
Fed. R. Civ. P. Rule 26(c) provides that “[a] party or any person from whom
discovery is sought may move for a protective order … to protect the party or person
from annoyance, embarrassment, oppression or undue burden or expense, …” Fed.
R. Civl P. R. 26(c)(1). The burden is on the moving party to show good cause for the
protective order. Static Control Components, Inc. v. Darkprint Imaging, 201 F.R.D. 431,
434 (M.D.N.C. 2001). To carry its burden, the moving party must make:
a specific request and a specific demonstration of facts in
support of the request as opposed to conclusory or
speculative statements about the need for a protective
order and the harm which would be suffered without one.

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Id. (quoting Brittain v. Stroh Brewery Co., 136 F.R.D. 408, 412 (M.D.N.C. 1991) (internal
quotations omitted)). Thus, conclusory assertions and speculative claims will not do;
the movant must come forward with specific facts to show the movant is entitled to
the specific protection requested under Rule 26. Id.
Further, where, as here, the movant seeks a protective order “forbidding the
disclosure or discovery” under Rule 26(c)(1)(A), the movant must carry “a heavy
burden because protective orders which totally prohibit [discovery from a particular
source] should be rarely granted absent extraordinary circumstances.” Static Control,
201 F.R.D. at 434 (quoting N.F.A. Corp. v. Riverview Narrow Fabrics, Inc., 117 F.R.D. 83,
84 (M.D.N.C. 1987)).4 Therefore, to obtain the protection they seek, the Duke
Defendants must carry their “heavy burden” by making “a specific demonstration of
facts” sufficient to justify their request for the most extreme protection available
under Rule 26. And they must do so without relying on “conclusory or speculative
statements about the need for a protective order and the harm which would be
suffered without one.” Static Control, 431 F.R.D. at 434.

This is consistent with the philosophy of liberal discovery animating the Federal Rules,
which authorize parties to “obtain discovery regarding any nonprivileged matter that is relevant to
any party's claim or defense... .” Fed R. Civ. P. R. 26(b)(1). Further, the Rules authorize district
courts to order discovery of “any matter” that is “relevant to the subject matter involved in the
action,” which includes anything that “appears reasonably calculated to lead to the discovery of
admissible evidence.” Id. (emphasis supplied).  
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ARGUMENT
I.

DEFENDANTS SEEK THE MOST EXTREME PROTECTIVE
ORDER AUTHORIZED BY RULE 26(c)
The Duke Defendants seek a protective order totally forbidding the discovery

of the information and documents described in the two subpoenas Plaintiffs served
on the two consulting firms that Duke retained to the global media strategy that the
Duke Defendants employed in connection with the false allegations that Plaintiffs
participated in a brutal, racially motivated gang-rape in March of 2006. Defs.’ Mot. at
¶ 14. This Court, the most extraordinary relief available under Rule 26(c) and, as this
Court has explained, such relief is rarely granted and only where the movant carries
the “heavy burden” of proving that the discovery sought is legally protected nature
and that there are no means of protecting it less burdensome on a party’s liberal right
of discovery. Static Control, 201 F.R.D. at 431.5
II.

DUKE DEFENDANTS FAIL TO CARRY THE “HEAVY BURDEN”
THIS COURT IMPOSES BEFORE GRANTING THE
EXTRAORDINARY RELIEF SOUGHT HERE

Thus, in Static Control, this Court refused to totally prohibit discovery from a defendant’s
litigation counsel in the case. Instead, the Court ordered that the noticed deposition of defendants’
litigation counsel not be conducted, but ordered the defendant’s litigation counsel “at a minimum”
to personally answer the plaintiff’s interrogatories. Id. at 437; see also id. at 435-436 (explaining that
the deposition of defendant’s litigation counsel should not be conducted because plaintiff already
possessed a complete recording of the conversation at issue.) 
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A.

The Duke Defendants’ Conclusory Assertions Do Not Constitute
the “Specific Demonstration of Facts” Required to Support the
Extraordinary Protective Order They Seek.

The Duke Defendants’ motion fails at the threshold because they fail to
support the motion with a “specific demonstration of facts” that this Court requires.
Rather, the Duke Defendants rely solely on bald, conclusory assertions devoid of
factual detail, which this Court has long refused to consider on a motion under Rule
26(c). See, e.g., Static Control, 201 F.R.D. at 434 (holding that protection from discovery
under

Rule

26(c)

requires

the

movant,

at

step

one,

to

“make a specific demonstration of facts” supporting the relief requested, and
explaining that this Court does not consider “conclusory or speculative statements
about the need for a protective order and the harm which would be suffered without
one....”).
And even if this Court were to consider such bald, conclusory assertions on a
motion made under Rule 26(c), the Duke Defendants’ motion would still fail because
the conclusory assertions offered to support their motion are not even their own: they
are the conclusory assertions of their lawyers.

The Duke Defendants filed no

affidavits to support their motion, nor did they even even verify the motion. Thus,
the Duke Defendants motion fails at the threshold requirement that they make a
showing of specific facts that establish the need for the extraordinary protection they
seek. The Motion must be denied based upon that failure alone.
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B.

The Duke Defendants Make No “Specific Demonstration of Facts”
Showing That the Subpoenas Do Not “Appear Reasonably
Calculated to Lead to the Discovery of Admissible Evidence”

Next, the Duke Defendants assert (ad nauseum) that Plaintiffs’ subpoenas seek
information that is “not relevant” to the counts on which discovery is proceeding, and
that the topics enumerated in Plaintiffs subpoenas “have nothing to do with Counts
21 and 24.” Defs.’ Br. at 9. The Duke Defendants offer no specific facts to support
that naked assertion, and their contention fails on that basis alone. See discussion,
supra, at § II(A).
And, while the topics enumerated in Plaintiffs’ subpoenas are highly the claims
that are presently going forward, they need not be “highly relevant” or even
“relevant” to Plaintiffs’ claims. Rather, the subpoenas need only “appear reasonably
calculated to lead to the discovery of admissible evidence.” Fed. R. Civ. P. Rule
26(b)(1).

As to this—the correct—standard, the Duke Defendants offer their

lawyers’ bald assertions and hyperbole, but nothing at all in the nature of a “specific
factual demonstration” sufficient to meet the “heavy burden” this Court imposes to
justify the extraordinary protection they seek.6

The Duke Defendants also assert that the media consulting firms are “not aware” of the
court’s order staying discovery as to claims involving the City Defendants. Br. at 6. That claim is
impugned by an email from counsel for Burson-Marstellar, Jesse Schneider, who wrote, “I am also
told that the Court has limited the discovery significantly and that this subpoena goes well beyond.”
Exhibit 9 (E-mail from Jesse Schneider to Plaintiffs’ counsel, dated December 7, 2011). Of course,

6

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C. The Duke Defendants Make No “Specific Demonstration of Facts”
Showing the Subpoenas to be Overbroad or Unduly Burdensome
Next, Duke asserts that the subpoenas are overbroad and unduly burdensome.
Here, again, the Duke Defendants offer nothing more than their lawyers’ bald,
conclusory assertions that the subpoenas are “overbroad” and “unduly burdensome,”
Defs.’ Br. at 10-12, but they offer nothing in the nature of a “specific factual
demonstration” that this Court requires on a motion under Rule 26(c).

Their

contention fails on that basis alone. See discussion, supra, at Argument §II(A). But
that is not all that is wrong with Defendant’s argument. The Duke Defendants also
have no standing to assert a claim of burden or overbreadth because Plaintiffs’
subpoenas are not directed to them.

Further, both claims are belied by

correspondence from Burson-Marstellar’s attorney, from which it is clear that BursonMarstellar did not preserve materials in their possession relating to Plaintiffs or the
matters identified in Plaintiffs’ subpoena, and, as a result, Burson-Marstellar may not
have any of the materials it once possessed to produce in response to Plaintiffs’
subpoena. See Exhibit 9 (E-mail from Jesse Schneider, attorney for Burson-Marstellar,
to Robert Ekstrand, Plaintiffs’ counsel, dated December 7, 2011.) (“We still do not
know whether we have any documents [responsive to Plaintiffs’ subpoena]. … It

neither Plaintiffs nor their counsel expressed the opinion that Plaintiffs’ subpoenas exceed the scope
of discovery. 

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requires going back and searching the files of certain employees no longer with the
company and others who may not have any relevant documents.”). Therefore, given
that the Duke Defendants apparently took no steps to ensure their consultants’
retention of evidence that is relevant to this case, and given that the subpoenas are not
directed to the Duke Defendants, their claim of “overbreadth” and “burden” has no
merit.
D. The Duke Defendants Make No “Specific Demonstration of Facts”
Showing that the Subpoenas Seek “Confidential Commercial
Information”
Next, in a footnote, Duke drops the suggestion that the subpoenas seek
materials that are or contain “confidential commercial information.” Defs.’ Br. at 12,
n.3. Here, again, the Duke Defendants do not even attempt to make “a specific
factual demonstration” showing that materials possessed by Duke’s media consulting
firms constitutes “confidential commercial information.”

The Duke Defendants’

failures do not end there in connection with their purported “confidential commercial
information.” The Duke Defendants do not submit any form of log or listing of the
specific documents they claim to constitute or contain “confidential commercial
information.” Fed. R. Civ. P. Rule 26(b)(5), added in 1993, provides the procedure
for asserting claims of protection for communications or materials that would
otherwise be discoverable. See id. The Rule requires the party asserting the privilege or
protection to make the claim expressly, and to describe the nature of the information
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not produced in a manner that, without revealing information itself privileged or
protected, will enable other parties to assess the applicability of the privilege or
protection. Id. The Duke Defendants have provided nothing of the sort, either to
Plaintiffs or to the Court.
The Duke Defendants also fail to identify any authority supporting the
proposition that communications and materials prepared by a media consulting firm
are subject to legal protection. Even if such authority existed, any legal protections
afforded to such materials were waived long ago by the Duke Defendants’ own (and
their consultants’) public commentary about the media strategy Duke devised in
collaboration with these two consulting firms.
In addition, any valid legal protections that may have existed in connection
with the subpoenaed documents have been waived by the Duke Defendants failure to
provide any of the information required by Fed. R. Civ. P. Rule 26(b)(5). The Duke
Defendants' have not produced any log or listing of documents that contain any
“confidential commercial information” whatsoever. That, alone, is enough to waive
whatever protection they claim. But that is not all. In addition, they have not
produced in connection with each document they purport to contain confidential
commercial information (1) a brief description or summary of the content of the
document or communication; (2) the date the document was prepared, (3) the name

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of the person(s) who prepared the document; (4) the person(s) to whom the
document was directed, or for whom it was prepared; (5) the purpose for preparing
the document; (6) the specific privilege or protection they claim in connection with
each document; or (7) an explanation of how the document satisfies the asserted legal
requirements of the claimed protection. See Fed. R. Civ. P. R. 26(b)(5). Courts not
only decline to issue protective orders in the face of such failures, but also deem the
failures to be a waiver of the protection sought. See, e.g., Aurora Loan Services, Inc. v.
Posner & Assocs., P.C., 499 F. Supp. 2d 475, 479 (S.D.N.Y. 2007) (party waived
privilege for documents identified in privilege log because log failed to identify which
privilege was being asserted for particular documents and often failed to identify
parties to each communication). Here, the Duke Defendants do not simply fail to
identify parties to each communication or identify which privilege is being asserted as
to each document—they have failed to produce a log itemizing the purportedly
confidential documents at step one, much less the detail required to protect the
purported “confidential commercial information” they contain. In short, the Duke
Defendants have failed to do what the Rules require in order avoid waiver of any legal
protections that may be afforded to the subpoenaed documents at step one. See
generally Fed. R. Civ. P. Rule 26(b)(5).
The Duke Defendants’ failure to take any of the actions necessary to preserve
whatever legal protections might have applied to the subpoenaed materials and their
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conspicuous failure to make the required “specific demonstration of facts” to justify
the extraordinary protection they seek suggests the absence of a proper purpose in
interposing this Motion. The only plausible purpose of such a motion is its most
obvious effect: to obstruct and delay Plaintiffs’ discovery of evidence of the Duke
Defendants’ conduct that, as the Duke Defendants themselves contend, will humiliate
them. But the Rules are not so trivial as to authorize protective orders prohibiting
discovery on grounds that a party, in the absence of protection, will be humiliated by
the revelation of their own prior conduct. See Fed. R. Civ. P. R. 26(c) (enumerating
grounds for protective orders).
E. The Duke Defendants Make No “Specific Demonstration of Facts”
Showing the Need for a “General Protective Order”
Next, having failed to identify any specific content in the subpoenaed material
that justifies a protective order, the Duke Defendants assert that Plaintiffs’ discovery
of the materials sought by their subpoenas is “premature in the absence of a general
protective order.”7 Mot. at para 9. To support this claim, the Duke Defendants rely
on generalities that belie their own claims. For example, instead of producing an
itemization of protected or privileged material, the Duke Defendants merely assert

This is the same meritless claim the Duke Defendants have invoked to justify their
refusal to make the initial disclosures required by Rule 26 or produce more than 27 pages of
documents in response to Plaintiffs First Request for Production of Documents. Plaintiffs
address this problem separately in Plaintiffs’ Motion to Compel. 
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that “Some of the documents requested may also be privileged.” Br. at 13, n.3
(emphasis supplied). Here, the Duke Defendants reveal that they apparently have no
idea what they are asking this Court to protect. Certainly, Rule 26(c) does not
authorize a baseless prior restraint on every document possessed by a corporate
entity’s media consulting firm, and the Duke Defendants offer no authority to the
contrary. In any event, the Rules provide ample remedies for disclosures of truly
confidential material in response to subpoenas.

See, e.g., Fed. R. Civ. P. Rule

45(d)(2)(B) (providing protections where “information produced in response to a
subpoena is subject to a claim of privilege or of protection....”). Thus, the Duke
Defendants’ request for a “general protective order” should be denied.
F.

The Duke Defendants Do Not Cure Their Total Failure to Make the
“Specific Demonstration of Facts” this Court Requires by Casting
Aspersions at Plaintiffs

Finally, the last refuge of the Duke Defendants is to cast aspersions at
Plaintiffs. See generally Defs.’ Br. at 13-14. They wind up their briefing by asserting that
Plaintiffs’ subpoenas are animated by improper purposes, including “fishing,” “muckraking,” and “swamp dredging.” Defs.’ Br. at 14. Again, they offer nothing in the
way of facts to back up their histrionics. It goes without saying that the Duke
Defendants do not cure their total failure to carry their “heavy burden” through such
tactics.

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CONCLUSION
The Duke Defendants have not carried their “heavy burden” of making a
“specific demonstration of facts in support of the request.” Rather, they rely on the
“conclusory” and “speculative statements” of their lawyers to support their claim of
“need for a protective order and the harm which would be suffered without one.”
Because this Court rejects such speculative and conclusory assertions as a basis for
imposition of a protective order (even when made by the parties themselves), the
Motion fails at the threshold, and must be denied.

Dated: December 29, 2011

Respectfully submitted by:
EKSTRAND & EKSTRAND LLP
/s/ Robert Ekstrand
Robert C. Ekstrand (N.C. Bar No. 26673)
Stefanie A. Sparks (N.C. Bar. No. 42345)
811 Ninth Street, Second Floor
Durham, North Carolina 27705
[e-mail]
[e-mail]
Tel: [phone]
Fax: [phone]
Counsel for Plaintiffs

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