Oakley v. MSG Networks Inc.
- Richard Sullivan
- 1:17-cv-06903
- U.S. District Court · Southern District of New York
- 2
In Oakley v. MSG Networks Inc., Judge Sullivan denied Oakley’s request for a pre-motion conference without prejudice because his proposed sanctions motion was premature.
The ruling affects Charles Oakley and MSG Networks, Inc., Madison Square Garden Sports Corp., and Sphere Entertainment Group, LLC. It postpones consideration of Oakley’s proposed spoliation-sanctions motion until specified discovery is completed, while allowing him to renew the request.
What happened
In Oakley v. MSG Networks Inc., Charles Oakley sought a conference before filing a motion asking the court to punish MSG for allegedly losing relevant emails and failing to preserve a former security vice president’s corporate cell phone.
MSG Networks, Inc., Madison Square Garden Sports Corp., and Sphere Entertainment Group, LLC, argued that Oakley’s request was premature because related documents had not yet been produced and a scheduled organizational deposition had not yet occurred.
Judge Richard J. Sullivan denied Oakley’s request without prejudice to renewal after that discovery was completed. The court also said Oakley could submit a one-page letter by January 27, 2025, explaining whether he still believed there was a good-faith basis for seeking sanctions.
The detailed version
- Oakley v. MSG Networks Inc. · No. 1:17-cv-06903
- Richard Sullivan
- Jan. 14, 2025
Background
Charles Oakley asked for a pre-motion conference about his planned motion for spoliation sanctions under Federal Rule of Civil Procedure 37. Spoliation sanctions are penalties that may be imposed when relevant evidence is not preserved. Oakley alleged that MSG lost emails for certain custodians during the period relevant to the case and failed to preserve the corporate cell phone of former MSG Vice President for Security Frank Benedetto.
The defendants named in connection with the request were MSG Networks, Inc., Madison Square Garden Sports Corp., and Sphere Entertainment Group, LLC, which the opinion collectively calls “MSG.”
Parties’ Positions
MSG responded that Oakley’s request was “premature, unripe, and inaccurate.” MSG pointed out that Oakley had requested document discovery and a deposition under Rule 30(b)(6), which allows a party to question an organization through a designated witness, about the same subject. The opinion states that the documents had not yet been produced and that the deposition was scheduled for January 23, 2025.
Oakley also filed a supplemental letter on January 14, 2025. The court noted that its rules do not allow a party seeking a pre-motion conference to submit a reply letter, and stated that the supplemental letter did not change the court’s conclusion.
Ruling
The court agreed that Oakley’s contemplated sanctions motion was, at best, premature. It therefore denied without prejudice Oakley’s request for a pre-motion conference. The court permitted Oakley to renew the request after completion of the specified deposition and document discovery.
If Oakley chose to renew the request, the court ordered him to submit by January 27, 2025, a letter of no more than one single-spaced page stating whether, after completing the discovery, he continued to believe there was a good-faith basis to seek spoliation sanctions against MSG. The order did not decide whether MSG had lost or failed to preserve evidence or whether sanctions should be imposed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.