Lomascolo v. OTTO OLDSMOBILE-CADILLAC. INC.
This case involves a defendant's motion for a protective order to preclude the plaintiff from using two documents at trial, alleging they were not disclosed previously. The plaintiff, who alleges sexual harassment and a hostile work environment under Title VII and New York State Human Rights Law, argued that the documents were solely for impeachment purposes and thus excluded from mandatory disclosure. The court analyzed whether the documents had a dual purpose (impeachment and substantive evidence) and reviewed circuit precedents, ultimately declining to completely preclude their use. Instead, the court applied judicial estoppel, ruling that the documents, which the plaintiff claimed were for impeachment to avoid sanctions, could only be used for impeachment purposes at trial.