The deposition will help sort out whether DOJ really wanted citizenship info to help bring (non-existent) Section 2 Voting Rights lawsuits or this was a pretext to give Wilbur Ross what he wanted for other nefarious reasons. Court order:
Given the combination of AAG Gore’s apparent role in drafting the Department of Justice’s December 12, 2017 letter requesting that a citizenship question be added to the decennial census and the Court’s prior rulings — namely, its oral ruling of July 3rd concerning discovery, (18-CV-2921, Docket No. 207), and its Opinion of July 26th concerning Defendants’ motions to dismiss (18-CV-2921, Docket No. 215, at 60-68) — his testimony is plainly “relevant,” within the broad definition of that term for purposes of discovery. See, e.g., Alaska Elec. Pension Fund v. Bank of Am. Corp., No. 14-CV-7126 (JMF), 2016 WL 6779901, at *2 (S.D.N.Y. Nov. 16, 2016) (“Although not unlimited, relevance, for purposes of discovery, is an extremely broad concept.” (internal quotation marks omitted)). Moreover, given Plaintiffs’ claim that AAG Gore “ghostwrote DOJ’s December 12, 2017 letter requesting addition of the citizenship question,” (Docket No. 236, at 1), the Court concludes that AAG Gore possesses relevant information that cannot be obtained from another source. See Marisol A. v. Giuliani, No. 95-CV-10533 (RJW), 1998 WL 132810, at *2 (S.D.N.Y. Mar. 23, 1998).