*1 Plaintiff's Motion to Reconsider Court's Order Dated April 24, 2017 [79] is DENIED.

STATEMENT

On March 10, 2017, Plaintiff filed a motion for sanctions, arguing that Defendant's “willful destruction of essential evidence and failure to properly preserve records and documents” warranted an adverse inference instruction. (Dkt. 69). At the hearing, the Court noted that the Seventh Circuit and the civil rules “frown upon a negative inference.” (Dkt. 82 (Mar. 29, 2017 Hr'g Tr.) at 18). The Court suggested that if sanctions were warranted, an appropriate sanction could be making otherwise privileged information available and ordered Plaintiff to identify which items on Defendants' privilege log would be relevant to her spoliation argument. (Id. 19– 21; see Dkt. 73). On April 3, 2017, Plaintiff identified her requested documents through a motion to compel disclosure of certain email, requesting the disclosure of otherwise privileged information, as “a reasonable discovery sanction for defendant's failure to maintain and preserve verbatim audio recordings of all closed session meetings.” (Dkt. 74).

On April 24, 2017, the Court denied Plaintiff's motion for sanctions, finding no evidence that any information had been intentionally destroyed in bad faith. (Dkt. 75). “There is no testimony or evidence that any member of the School District knew that the recordings were inaudible or that any School Board member recklessly or intentionally altered or destroyed the recordings.” (Id.). Thus, the Court concluded that there is no evidence of spoliation by Defendants and no basis to sanction Defendants. (Id.). Because the Court found no basis to sanction Defendants, it declined “to determine whether ordering Defendants to produce otherwise privileged information would [ever] be an appropriate spoliation sanction.” (Id.).

Plaintiff now moves to reconsider the April 24 Order, arguing that the Court erred by failing to consider “whether any of the specifically identified and requested emails and documents identified [on] the untimely produced privileged log were, as a matter of law, exempt from disclosure as legally protected attorney privileged communications.” (Dkt. 79). For the reasons discussed below, the motion is denied.

A motion to reconsider is appropriate only in “limited circumstances.” Broaddus v. Shields, 665 F.3d 846, 860 (7th Cir. 2011). “It is well established that a motion to reconsider is only appropriate where a court has misunderstood a party, where the court has made a decision outside the adversarial issues presented to the court by the parties, where the court has made an error of apprehension (not of reasoning), where a significant change in the law has occurred, or where significant new facts have been discovered.” Id. (citation omitted). “[A]s a rule courts should be loathe to [revisit their prior decisions] in the absence of extraordinary circumstances such as where the initial decision was ‘clearly erroneous and would work a manifest injustice.’ ” Christianson v. Colt Indus. Operating Corp., 486 U.S. 800, 817, 108 S. Ct. 2166, 2178 (1988). “Reconsideration is not an appropriate forum for rehashing previously rejected arguments or arguing matters that could have been heard during the pendency of the previous motion.” Caisse Nationale de Credit Agricole v. CBI Industries, Inc., 90 F.3d 1264, 1270 (7th Cir. 1996).

*2 Plaintiff contends that the Court “advised in open court that it would review the specifically identified documents and emails in camera to determine whether the claimed attorney work-product privilege and/or attorney-client privilege applied to prevent disclosure.” (Dkt. 79 at 4). To the contrary, the Court found “[no] doubt that [the documents are] covered by the attorney/client privilege. They seem completely appropriate for the privilege log.” (Mar. 29 Hr'g Tr. 20).[1] Instead, the Court merely suggested that if it found a basis to sanction Defendants for spoliation, it would consider ordering disclosure of otherwise privileged documents as an alternative to Plaintiff's request for an adverse inference instruction. (Id. 18–20). But as noted above, the Court subsequently found no evidence of spoliation, declined to issue sanctions, and thus, found no reason to determine if ordering the disclosure of otherwise privileged information would be appropriate.

Plaintiff's argument, on a motion to reconsider, that this Court should determine whether the attorney-client privilege or work-product doctrine was properly invoked also fails because Plaintiff never developed her argument that defendants were improperly asserting either privilege. Plaintiff contends that she previously raised a waiver-of-privilege argument in her January 25, 2017 motion to compel. (Dkt. 79 at 6; see Dkt. 53). That motion argued that Defendants “placed the legal advice re-ceived from [counsel] at issue” and “that because Defendants have failed to produce the required privilege log, this court should order all responsive documents disclosed as a reasonable sanction.” (Dkt. 53 at 8–9). But Plaintiff did not cite any evidence to support her contention that Defendants had placed privileged communications at issue. “A skeletal ‘argument,’ really nothing more than an assertion, does not preserve a claim.” United States v. Dunkel, 927 F.2d 955, 956 (7th Cir. 1991) (“Judges are not like pigs, hunting for truffles buried in briefs.”). Further, at the February 7, 2017 hearing, Plaintiff acknowledged that she was merely requesting a complete privilege log and that she would file a motion to compel—which she did not—if she subsequently believed any items on the log were improperly withheld. The Court granted the motion, ordering Defendants “to provide a comprehensive privilege log of all relevant correspondence concerning Dawn Harris and/or Joyce Nelson to Plaintiff's counsel by 2/17/17.” (Dkt. 61).

Plaintiff also contends that she raised a waiver argument in her sanctions motion. (Dkt. 79 at 6). But there is no mention of waiver in the March 10 motion for sanctions (Dkt. 69), and the April 3 motion merely states, without elucidation, that “defendants have effectively waived any potential attorney-client privilege that had not been timely raised concerning these documents before the close of written discovery.” (Dkt. 74 at 5). “This argument is perfunctory and undeveloped, and is therefore waived.” Argyropoulos v. City of Alton, 539 F.3d 724, 738 (7th Cir. 2008). While Plaintiff's April 3, 2017 motion is titled “Motion to Compel Disclosure of Certain Emails,” the motion merely requests that “disclosure should be compelled as appropriate [sic] a reasonable discovery sanction for defendant's failure to maintain and preserve verbatim audio recordings of all closed session meetings as required by the Illinois Open Meeting Act.” (Dkt. 74 at 5).

For the reasons discussed above, the Court does not believe Defendants should be sanctioned for the lack of audio recordings. Plaintiff's motion to reconsider is denied.