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Williams v. District of Columbia

United States District Court for the District of Columbia
806 F. Supp. 2d 44 (D.D.C. 2011)


Facts

Christina Conyers Williams (plaintiff) sued the District of Columbia (District) (defendant) on grounds that the District violated the District of Columbia Whistleblower Protection Act. Around June 2, 2008, during the discovery phase of the litigation, the District produced documents to Williams. The response included a “recommendation to terminate packet” that consisted in part of an email to which the then-Deputy General Counsel for the District’s Department of Health was a party. The email discussed Williams’ proposed termination. The District later realized it had inadvertently produced the email and, on November 22, 2008, wrote to Williams demanding the immediate return of the email and forbidding its use or disclosure. Williams never responded to the demand and the District did not follow up in the next two years and eight months of litigation. In July 2011, Williams listed the email on her exhibit list. On July 20, 2011, the District moved to exclude the email.

Rule of Law

Issue

Holding and Reasoning (Kollar-Kotelly, J.)

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