NEW YORK, NY – A federal magistrate judge in Manhattan has issued a mixed ruling on a motion for reconsideration filed by plaintiff Kalin Dimitrov, who is representing himself in a civil action against the United States and the City of New York.
In an order dated January 20, 2026, U.S. Magistrate Judge Sarah L. Cave granted in part and denied in part Dimitrov’s bid to revisit a December 22, 2025 decision that required him to sign and return a medical release form to the City but declined to compel him to execute a separate release for sealed criminal records.
The dispute stems from discovery in Dimitrov’s federal lawsuit, where the City sought authorizations allowing access to both sealed criminal records and medical information relevant to his claims. Dimitrov objected, arguing that the requests represented an improper effort by the defendants to “fabricate things” about him.
On December 19, 2025, the City moved to compel his compliance and to extend its deadline to respond to the complaint. Judge Cave’s December 22 order granted the motion in part, directing Dimitrov to sign the medical release by January 26, 2026, and extending the City’s response deadline to March 3, 2026.
Dimitrov then filed a motion for reconsideration on December 25, contending that the court’s order contained clear errors and risked “manifest injustice.” In Monday’s ruling, Judge Cave reaffirmed most of the earlier decision, citing the applicable standards under Federal Rule of Civil Procedure 60(b) and Local Civil Rule 6.3, which limit reconsideration to cases of mistake, new evidence, or other extraordinary circumstances.
The court maintained that Dimitrov must execute the HIPAA medical authorization but reiterated that the question of whether the City may obtain his sealed criminal records will be subject to additional briefing before any further order.
The City now has until early March to file its response to Dimitrov’s complaint while discovery disputes continue under the supervision of the magistrate judge.
Key Points: Judge partly grants motion to reconsider in federal case over release of records and medical authorization – New York
- Magistrate Judge Sarah L. Cave granted in part and denied in part plaintiff Kalin Dimitrov’s motion for reconsideration.
- The court reaffirmed its prior order requiring Dimitrov to sign a medical release while deferring a decision on access to sealed records.
- The City of New York’s deadline to respond to the complaint remains extended to March 3, 2026.
