1 in the united states district court northern district...

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IN THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

STUDENTS AND PARENTS FOR PRIVACY,voluntary unincorporatedassociation,

Plaintiff,

vs.

UNITED STATES DEPARTMENT OFEDUCATION, et al.,

Defendants.

))))))))))))

Docket No. 16 C 4945

Chicago, IllinoisJuly 13, 20169:30 o'clock a.m.

TRANSCRIPT OF PROCEEDINGS - MOTIONBEFORE THE HONORABLE JEFFREY T. GILBERT

APPEARANCES:

For the Plaintiffs: ALLIANCE DEFENSE FUNDBY: MR. JEREMY DAVID TEDESCO15100 North 90th StreetScottsdale, AZ 85260(480) 444-0020

THOMAS MORE SOCIETYBY: MS. JOCELYN FLOYD19 South LaSalle Street, Suite 603Chicago, IL 60603(312) 782-1680

Court Reporter: MS. CAROLYN R. COX, CSR, RPR, CRR, FCRROfficial Court Reporter219 S. Dearborn Street, Suite 2102Chicago, Illinois 60604(312) 435-5639

Case: 1:16-cv-04945 Document #: 90 Filed: 07/20/16 of 21 PageID #:833

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APPEARANCES CONTINUED:

For the Defendants: UNITED STATES DEPARTMENT OF JUSTICECIVIL DIVISION, FEDERAL PROGRAMS BRANCHBY: MS. SHEILA M. LIEBER20 Massachusetts Avenue, N.W.Room 7132Washington, DC 20530(202) 514-2000

FRANCZEK RADELET PCBY: MR. MICHAEL A. WARNER, JR.

MS. SALLY J. SCOTT300 South Wacker Drive, Suite 3400Chicago, IL 60606(312) 786-6118

For the Intervenors: MAYER BROWN LLPBY: MS. BRITT MARIE MILLER

MS. LINDA XUEMENG SHI71 South Wacker DriveChicago, IL 60606(312) 782-0600

ROGER BALDWIN FOUNDATION OF ACLU, INC.BY: MR. JOHN A. KNIGHT180 North Michigan Avenue, Suite 2300Chicago, IL 60601(312) 201-9740


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(The following proceedings were had in open court:)

THE CLERK: 16 C 4945, Students and Parents for

Privacy, et al., v. The United States Department of Education,

for a status and motion hearing.

THE COURT: Okay. Good morning. Anybody who is

going to be speaking, do you want to come on up and identify

yourselves for the record and for the court reporter?

Hi, Carolyn.

THE COURT REPORTER: Hi, Judge.

THE COURT: Plaintiffs first.

MS. FLOYD: Jocelyn Floyd on behalf of the

plaintiffs, J-o-c-e-l-y-n, F-l-o-y-d.

MR. TEDESCO: Jeremy Tedesco for the plaintiffs.

THE COURT: Welcome to our fair city.

MR. TEDESCO: Thank you.

MS. LIEBER: Sheila Lieber for the federal

defendants.

THE COURT: Welcome.

MS. LIEBER: S-h-e-i-l-a, L-i-e-b-e-r.

It's my fair city too. I grew up here.

THE COURT: Oh, okay. I will go along with that.

MR. KNIGHT: John Knight and Britt Miller for the

intervener defendants.

MS. SCOTT: Sally Scott for defendant District 211.

MR. WARNER: Michael Warner for defendant


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District 211.

THE COURT: Okay. Good morning to everybody here.

So I am just filling out my scorecard here.

So here's my agenda. I want to address the

plaintiff's motion for leave to file some requests to admit.

I read them. I read the intervener defendants' response to

that motion this morning. I didn't see it last night. I read

the cases cited. I've got some thoughts, but maybe I ought to

hear what the intervener defendant -- or what the plaintiffs

would say in response to your opposition, which you guys

probably read too, right?

MR. TEDESCO: Yes, your Honor.

THE COURT: That's really the only formal thing I

wanted to discuss -- wanted to deal with and rule on this

morning, if I could.

And then I had set this conference after you guys

filed the response briefs just to see if there was anything I

needed to deal with.

I don't really think I need to deal with anything,

but I am happy to talk with you about -- take off the robe,

sit down, and do it more like a Rule 16 conference, just talk

about what everybody sees the shape of the table as. I know

you guys have a reply left and you are working on that.

I will tell you what I am thinking about in terms

of -- I haven't digested all of the briefs, but I've skimmed


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all, read some, and so I had a sense of where the issues are

joined. Okay?

But let's first deal with the motion for leave to

file the discovery. Mr. Tedesco or Ms. Floyd, where do you

come out on this?

MR. TEDESCO: Sure. Thank you, your Honor.

Just a couple things I guess to add in response to

their response brief. One is I just think it's remarkable

that the intervener defendants would voluntarily enter the

case, raise an issue of fact, ask for expedited discovery, get

that discovery granted on a particular issue, and then object

to us being able to do commensurate discovery on the same

issue.

In their pleadings, on the preliminary injunction

motion, they obviously relied on their discovery requests, and

I think it's appropriate for us to have commensurate

discovery. You know, at the last hearing, I know we talked

about tit for tat. It's certainly not -- pejoratively, we are

not, you know, pursuing this in that kind of pejorative sense.

But litigation is tit for tat. If an issue is raised and one

party gets discovery, the other party has to have an equal

opportunity to do discovery on the same issue.

I think I'd also just point out that their discovery

and their argument goes to, you know, a core issue in the

case, which is what does sex mean under Title IX. We have


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presented the Court and will continue to do so the position

about sex being based on sex chromosomes which are then

reflected and anatomical differences and characteristics

unique to each sex, male and female, and the other side

disputes that. And we should have an opportunity to do

limited discovery to present the Court a full picture of that

now disputed issue because the intervener defendants entered

into the case and raised it.

THE COURT: Why don't you already have pretty much

what you want, as the intervener defendants say, with student

A's mother's declaration that student A was designated male at

birth and the DOE's statement in their findings that student A

was born male?

And you know what? What I don't have -- I read the

brief, but there is an ellipses. So could you get me the

declaration so I have it, the mom's declaration?

Why don't you essentially have enough to make the

argument you are making just with what's already in the

record?

MR. TEDESCO: Well, again, our position is that --

THE COURT: And since your first request to admit is,

Admit that student A's original birth certificate designated

student A's sex as male. So mom admits that, right?

MR. TEDESCO: I don't know that she's admitted that

in her declaration.


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THE COURT: What does "designated male at birth" to

you mean in just like real English?

MR. TEDESCO: Well, I'm assuming it means that that's

what's indicated on his birth certificate.

THE COURT: Me too. So your first request to admit

is, Admit that student A's original birth certificate

designated student A's sex as male. Joe is going to get me

the affidavit, so I will see it directly, but --

MR. TEDESCO: Well, your Honor, their discovery

requests are providing the evidence that you have that he is

not female.

THE COURT: Yeah.

MR. TEDESCO: So they're disputing that he is male.

I just don't -- obviously, the amount of evidence we have is

not sufficient for this to not be a disputed fact in the case

even though it should be. Disputed facts arise in a case

through a lot of different reasons. While plaintiffs may not

think an issue is disputed, and I can continue to believe

that, the defendants have entered the case voluntarily and

raised the issue.

THE COURT: I get that.

MR. TEDESCO: And so I -- I'm sorry, your Honor.

THE COURT: No, go ahead. I interrupted you, and

that was rude.

MR. TEDESCO: Oh, no, not at all.


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So I think under these circumstances, they asked

about whether we had any evidence that he is not female. They

asked whether he had any evidence related to his medical or

psychological records. We don't have those things. Now

they're citing that against us in briefing and saying it goes

to the issue of what does sex mean under Title IX.

We have a definition of sex that's longstanding and

accepted, has been -- always formed the basis of Title IX

for 40-plus years. They're coming to this court and saying,

no, sex means gender identity, and they're conflating those

terms and trying to convince the Court that gender identity

determines sex, not chromosomal and anatomical

characteristics, differences between the two sexes.

I think under the circumstances, we should have an

opportunity to limit the discovery. We're not doing this to

embarrass student A as they suggest. It's entirely in their

control whether we ask these questions, so the fact that

they're saying that we're doing this to embarrass him, they're

the one who raised his medical and psychological records as

relevant through their discovery requests.

Now, we're not asking for those right now, but as

this case persists, those probably will have to come into the

record because intervener defendants have raised them as

relevant to the core issue in the case, what does sex mean

under the statutory term in Title IX.


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THE COURT: You know, I can actually find this

document because it's cited -- you can tell Joe I don't need

this because I can get it on the record.

I just wanted to see what the declaration was.

Okay. In the nature of this bifurcated proceeding,

as of now, I'm doing a report and recommendation to Judge

Alonso on -- on plaintiff's motion for a preliminary

injunction. So this is not a trial on the merits. This is

a -- you know, although we are spending a lot of paper on

this, and it merits a lot of paper, I am not saying it

doesn't, but this is a preliminary issue in the case, and

there are certain things I have to decide, but I am not trying

the case on the merits. I am not deciding the ultimate merits

of the case.

So for purposes of the preliminary injunction, why

can't I essentially presume, you know, the things that you are

saying in your request for admission? In other words, there's

evidence in the record that at least student A's mother, who,

because she is a minor, can speak for her for these purposes,

I suppose, she's designated male at birth, that's not really a

disputed issue in this case. The question between the parties

and where you kind of are ships passing in the night is what

does that mean really. Plaintiff's position is biological sex

is determinative of the entire case. Defendants' position is

a little bit more nuanced with respect to gender identity and


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biology being, I think in the words of the expert that they

have proffered, gender identity has a strong biological basis,

but it also involves other things.

So, I mean, I get that that's being disputed here,

and I get that that's part of what I am going to have to

determine as to what that means here, but why can't I just

jump ahead of all of this and just say, you know, this is your

position and presume certain things about biology?

MR. TEDESCO: Because the intervener defendants have

raised it as a disputed fact and are going to present the

Court at the preliminary injunction stage evidence to prove

that he is actually female and not male.

So I am just -- I am concerned about one-sided

discovery on that topic, a topic that goes to one of the key

aspects of the case, both the APA claim and what does sex mean

and the Title IX comparable facilities and harassment claim.

THE COURT: So Mr. Knight or Ms. Miller, I didn't see

anything in your brief that was really disputing, you know,

that student A was assigned male sex at birth or even that --

and I am not asking to do anything you don't want to do on the

record, but I am just saying I didn't see anything in your

brief that was saying student A doesn't have male reproductive

organs and doesn't have male genitalia at this point in her

life.

Your opposition to this was more on whether it's


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relevant or not and also whether under Rule 26 the Court

should prevent this discovery at this stage because it's

embarrassing, annoying, harassing, and really has no good

purpose. Am I interpreting your response correctly?

MR. KNIGHT: Well, right. Your Honor, we certainly

don't -- we're not admitting anything about the facts other

than what plaintiffs have said was essential to their claim,

which is that plaintiff -- that student A was designated male

at birth. And so we don't believe that plaintiffs have

made -- have explained in any way why this additional

information is relevant to their claim or relevant to

responding to our expert testimony, which is -- which isn't

based on those issues that they are asking about. It's based

solely on the fact that gender identity for a transgender

young person like student A determines her sex.

THE COURT: And from your point of view, it's not

determinative of student A's sex what kind of genitalia she

has, what type of reproductive organs she has. It's a more I

want to say all-encompassing or involves a lot of other

factors other than those particular factors, right?

MR. KNIGHT: Well, the key factor is gender identity,

and that is -- and, obviously, the question is broader than

this, which is what does the law say with respect to this, and

we think that the law does not limit itself to saying sex is

based on biology, whatever that means.


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MS. MILLER: But your Honor has identified the exact

issue. The question -- what is in the record is the

declaration from student A's mother that she was assigned male

at birth. That is a factual question that is in the record

and answered by the material in the record. That's not where

the parties are at issue.

The parties are at issue as to what the law means

and, as a medical basis and the expert testimony we have

proffered in our declaration, what determines what is sex for

purposes of the law.

And so there is no need for this discovery, and your

Honor has in the record a statement from -- a signed sworn

declaration from student A's mother on the question of whether

or not student A was assigned male at birth. So no further

discovery is needed to join the issue of what does sex mean

for purposes of going forward.

THE COURT: Yeah. I mean, I don't want to go too far

down this road. My personal view and my professional view and

my judge view at this particular point in time is that this is

an unnecessary dispute to have at this point in time and that

the discovery that the plaintiffs are seeking or the requests

to admit which are hybrid from student A is not necessary at

this point in time, and it is -- falls within that box under

Rule 26 of where the judge is allowed to prevent

embarrassment, annoyance, suppression, whatever.


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The magistrate judge in Nevada dealt with a similar

issue, and I will tell the defendants that even though -- I

know you prepared this very quickly, but the cite in your

brief is wrong. The F.R.D. cite in your brief that you cited

doesn't get you to that case.

MR. KNIGHT: I apologize, your Honor.

THE COURT: But that's cool because I have people who

can actually find it. And so the correct -- it's 312 F.R.D.

594 rather than 494.

MR. KNIGHT: That's my fault, your Honor.

THE COURT: Roberts v. Park.

MR. KNIGHT: Yes.

THE COURT: But I think that judge had it right in

terms of what is likely to cause embarrassment in terms of

these kinds of questions.

Now, if the case proceeds as it proceeds and you are

going on the merits, I am not making any ruling as to whether

or not this kind of discovery or questions in depositions

would be relevant. I am just -- the only thing I am looking

at is what do I need to rule on this motion for preliminary

injunction at this point and how far down the discovery road I

want to go.

I disagree with you, Mr. Tedesco, that discovery that

the plaintiffs are looking for here is the same kind of

discovery that the intervener defendants were granted leave to


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have. Their discovery went to a basis for the plaintiff's

claims, so it essentially was, you know -- I mean, I have it

in front of me -- what have you investigated to make certain

allegations. And I read the responses to the extent they are

helpful. But request No. 1 was, Admit you have no factual

basis for disputing that student A is a girl, and you

objected, but you explained why. But that's what your basis

is for making a claim.

And the second one was, essentially, you have

conducted or have you conducted any medical or psychological

investigation. I don't think -- your objection to that when

they served it was not embarrassment, annoyance, whatever. It

was that it was unnecessary. And I disagreed. But I think

your discovery of student A is a little bit different going to

genitalia, reproductive organs, things like that, that if it

was necessary at the preliminary stage where we are at, the

preliminary injunction stage, then there is a balance as to

whether you need it versus the impact on the responding party.

I don't think on balance that you have met your

burden of showing I need these answers to requests to admit at

this juncture. I think it's in the record -- you've made

certain allegations in the verified complaint, I've got

plaintiff's -- student A's mother admitting, I think, for

purposes of the record, that she was designated as male on her

birth certificate, I've got the DOE making representations,


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and there are certain things -- the Federal Rules of Evidence

are not going to as closely govern what happens at a

preliminary injunction phase as they do at the trial.

I understand plaintiff's position that biological sex

is sex, and I have read the cases, or some of them, and I

understand the position that that governs where the outcome

is, and I understand the defendants' position that gender

identity is sex, among other things. There are other

arguments they are making, and I am understanding some of the

nuances, so I am not trying in two sentences to summarize

everybody's position because I understand that there are other

arguments that you are making as to what sex means under the

statute and things like that.

But the big picture from the defendants' point of

view, gender identity is what is sex determinative. From your

view, biological assignments and organs and things like that,

more objective -- I shouldn't say "objective." I know there

are nuances here that I can't possibly capture. But suffice

it to say as I've thought about your discovery and where we

are in the case, it didn't seem to me that the importance of

that discovery outweighed the objections that student A is

making with respect to very personal things to her.

So I am going to deny your motion for leave to file

the discovery. Obviously, that's an appealable issue if you

want to go up to Judge Alonso on it. My view is that you have


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enough to make the arguments that you need to make in order to

get your position across to the court and that this particular

discovery is not going to be outcome determinative.

After I put all of this through my own analysis and I

believe otherwise -- I could change my mind -- you know, it

would be totally unfair to you to say there's no admission in

the record with respect to reproductive organs or something

like that, and, therefore, plaintiffs can't prevail. You

know, if you get to that point at this preliminary stage, then

I would have to revisit my decision.

So I am not trying to be outcome determinative here.

I am just trying to deal with do you have enough information

to make the argument that you are making, do they have enough

information to make the arguments that they are making, do I

understand the arguments for purposes of a preliminary

injunction.

And so for all of these reasons, I am going to deny

your motion. This was a stream of consciousness ruling. I'm

sorry about that.

So then I would just -- we could just sit down.

Everybody -- when we -- I don't know that there's much more to

talk about really, or we could do it this way: I don't know

if there is much more to talk about in terms of discovery or

anything else. I mean, the reason I set this was because I

thought perhaps the briefs -- when I got the briefs from the


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defendants, plaintiffs would then see what's going on. You

did, and filed your motion for this discovery, I denied it,

and my guess is that's the only discovery you felt you needed,

right?

MR. TEDESCO: Correct, your Honor.

THE COURT: Okay. And you guys don't need any more

discovery on the defense side, right?

MR. WARNER: Your Honor, not at this point. However,

much like we scheduled this status hearing today, you know,

part of -- as you know, the district previously sought

discovery, you denied discovery based upon -- in part on the

plaintiff's representations that they were not going to rely

on the details of what happened in Fremd High School locker

rooms and whatnot.

Assuming that remains the case in reply, I think

we're all set, but it may make sense to set another status

hearing just in case there's something in the reply brief that

we feel the need to respond to by way of discovery otherwise.

THE COURT: So let's do this. Because this one was

mostly unnecessary on that -- in that regard because plaintiff

read the stuff and filed a motion. I don't think, given time,

I want to set another status hearing. What I want to do

instead is if somebody has an issue, they should file a

motion.

MR. WARNER: Very good, your Honor.


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THE COURT: Hold on for a second. And similarly, if

I have some questions as I digest what you are doing.

I will tell you right now, for example, that -- and I

am not going to ask you this now because I haven't gotten into

this enough, but when I was reading the various briefs, I had

some questions about whether there was a -- certain facts were

disputed or not. Okay? Because somebody says -- somebody,

for example, may say -- you know, plaintiff may say, this fact

is not disputed, see docket this. And then one of the three

defense briefs might say, this fact is not disputed, see

docket this. And those facts might at first blush look to me

to be disputed. Okay? Whether the facts are relevant or not

to my determination or not, whether I need to hear evidence on

that or not, I haven't really gotten to that point yet, but as

I read these things through, I may want some stuff. Okay?

But what I would say is if after you get plaintiff's

response, similar feelings percolate, you know, let me know in

writing. If you need to do it quickly to get -- I am not

going to rule the minute I get it. We have a hearing on

August 3rd, and I am not sure what the shape of that hearing

is yet. But if you see something, you know where to find me.

But I don't know that I want to have an unnecessary

status hearing where Mr. Tedesco and Ms. Lieber have to get up

early in the morning and fly in someplace to do that. So

that's really the way I would deal with that.


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The other thing is August 3rd. Your brief is coming

in like the 28th, right?

MR. TEDESCO: 22nd, I believe, your Honor.

THE COURT: I have a question about whether I am

going to be fully ready on August 3rd.

If I wanted to move it to August 10th or maybe -- who

is unavailable that date?

MS. LIEBER: I may be available, but we have a

hearing on some similar issues down in Texas on the 8th, and

it's just a question of coming back and getting here. But I

probably could do it.

THE COURT: Yeah, Texas is still U.S.

MS. LIEBER: I know.

THE COURT: The airlines still --

MS. LIEBER: But Wichita Falls is not like a hub.

THE COURT: Anybody else?

MR. TEDESCO: I'm not available the 9th, 10th, and

11th of that week.

THE COURT: Who else?

MS. SCOTT: We're available, your Honor.

MS. MILLER: We are as well, your Honor.

MR. KNIGHT: I think we are as well.

THE COURT: Again, I may not need to change it.

Let's keep on this schedule. Because you're all

here, let's just -- I am planning on doing the 3rd. Okay?


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Lots of stuff is coming in, lots of paper is coming in, so

there's a lot to get a hold of here.

If I needed some more time -- and I don't want to do

it on a day that Mr. Tedesco certainly is not available. I am

less concerned about getting here from Wichita Falls. You can

get here from Wichita Falls. I have done it in a prior life.

Except in February, and it's not February.

What about Monday the 15th? Who is not available

that day if I needed a rain delay date?

MS. SCOTT: We're fine, your Honor.

MR. KNIGHT: I think we're fine, your Honor.

THE COURT: I will try to give you some notice, but

let me think this through. I mean, I don't want to

shortchange myself or you.

Given that it's a report and recommendation, you're

delayed anyway because they are going to hold another round of

briefing in front of the district judge.

MS. MILLER: And, your Honor, if we go on the 15th,

what time would you like to see us?

THE COURT: It would be in the morning because I have

a settlement conference in the afternoon.

And so what I am envisioning, if we don't need

evidentiary presentations -- and I think if we do need

evidentiary presentations, I would have to talk to you

beforehand, obviously -- but I am envisioning the hearing as


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being more oral argument, okay, making sure I understand

everybody's arguments, making sure that you've answered the

questions that I have based on the briefs. That's what I am

thinking about. I am not thinking about a full trial on the

merits and I am not thinking about a full evidentiary hearing

unless we need one. Okay?

I will try and let you know -- I am out of town next

week, as I said, but as I continue to think this through, I am

not just leaving this stuff to look at after I get the reply

briefs; I am reading the stuff now. And if I am starting to

think like I need more time, I will let you know and move it

to the 15th.

Any questions, comments, concerns?

Have a good flight back to wherever you are going,

and I will see you in a few weeks.

MR. KNIGHT: Thank you, your Honor.

MS. MILLER: Thank you, your Honor.

MR. TEDESCO: Thank you, your Honor.

(Which were all the proceedings had in the above-entitled

cause on the day and date aforesaid.)

I certify that the foregoing is a correct transcript fromthe record of proceedings in the above-entitled matter.

Carolyn R. Cox DateOfficial Court ReporterNorthern District of Illinois

/s/Carolyn R. Cox, CSR, RPR, CRR, FCRR


1 in the united states district court northern district...

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