Dowge International Development, LTD. v. Louise Paris, Ltd.
- John Cronan
- 1:22-cv-07880
- U.S. District Court · Southern District of New York
- 2
In Dowge International v. Louise Paris, Judge Cronan ordered more support before deciding Dowge’s default-judgment motion.
Dowge International Development, Ltd. must provide additional information and supporting materials before the court decides its request for a default judgment against Louise Paris, Ltd. d/b/a Me Jane.
What happened
In Dowge International Development, LTD. v. Louise Paris, Ltd., Dowge asked the court to enter a judgment because Louise Paris had not defended against its claims. Dowge said 52 invoices totaled $2,972,253.96 and that, after payments, Louise Paris still owed $2,906,698.40.
Dowge also requested interest beginning November 4, 2021. The court identified questions about whether the invoice total was accurate, whether invoices addressed to other entities could be charged to Louise Paris, whether additional payments should reduce the claimed damages, and whether the requested interest date complied with New York law. The court also questioned whether Dowge’s claim based on an unpaid account duplicated its breach-of-contract claim.
Judge John P. Cronan did not decide the default-judgment motion. He ordered Dowge to file a supplemental memorandum, with additional evidence if needed, addressing those questions by October 7, 2024.
The detailed version
- Dowge International Development, LTD. v. Louise Paris, Ltd. · No. 1:22-cv-07880
- John Cronan
- Oct. 3, 2024
Background
Dowge International Development, Ltd. moved for a default judgment against Louise Paris, Ltd. d/b/a Me Jane. A default judgment is a judgment requested when a defendant has not defended against the case. The opinion does not decide whether Dowge was entitled to that judgment.
Dowge stated that the total amount of 52 invoices was $2,972,253.96. It further stated that Louise Paris had made several payments totaling $65,555.56 and therefore owed $2,906,698.40. Dowge requested prejudgment interest under New York Civil Practice Law and Rules § 5004 beginning November 4, 2021.
Questions Identified by the Court
The court ordered Dowge to provide further support addressing five issues:
- Whether the stated invoice total of $2,972,253.96 accurately matched the listed line items and invoice amounts.
- Whether invoices addressed to entities other than Louise Paris, Ltd., including “TJX Australia Pty Limited” and “Winners Merchants International,” could be attributed to Louise Paris.
- Whether the claimed damages should be reduced by a $101,000.28 payment made on June 1, 2022, and a $110,000 payment mentioned in Dowge’s May 21, 2024 letter.
- Whether beginning prejudgment interest on November 4, 2021 complied with New York law, which generally requires interest to be calculated from when each item of damage was incurred or from a single reasonable intermediate date when damages arose at different times.
- Whether Dowge’s account-stated claim was duplicative of its breach-of-contract claim. An account-stated claim generally concerns an alleged agreement about the amount owed based on account statements.
Order
Judge John P. Cronan ordered Dowge to file a supplemental memorandum and any supporting affidavits or documents by October 7, 2024. The order did not grant or deny the default-judgment motion, determine the amount owed, rule on prejudgment interest, or decide whether the account-stated claim duplicated the breach-of-contract claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.