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S.D.N.Y.Procedural orderFiled Apr. 11, 2025

Dennis v. K&L Gates LLP

Judge
Vyskocil
Docket
1:20-cv-09393
Court
U.S. District Court · Southern District of New York
Pages
4
Civil ProcedurePreliminary InjunctionPro Se
In one sentence

Dennis v. K&L Gates, Judge Vyskocil denied Dennis’s requests to block possible criminal or civil actions as unrelated and speculative.

Who this affects

Willie E. Dennis’s requests for emergency and preliminary injunctive relief were denied; the order also affected the parties by moving their conference to May 1, 2025 and warning that violations of the court’s rules could lead to sanctions.

What happened

In Dennis v. K&L Gates LLP, Willie E. Dennis, representing himself, asked the court to stop Proskauer and K&L Gates personnel from making certain law-enforcement claims or bringing certain actions against him. His underlying case alleges race discrimination, retaliation, and state-law claims.

The court said the requested orders concerned issues unrelated to the allegations in Dennis’s complaint. It also found that Dennis’s concern that he might be arrested was speculative rather than a concrete and imminent injury. The court therefore denied his requests for temporary restraining orders and preliminary injunctions.

Judge Mary Kay Vyskocil also adjourned the scheduled conference to May 1, 2025, and reminded the parties that failing to follow the court’s rules could result in sanctions. The court directed the Clerk to terminate the motion at docket entry 83.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Dennis v. K&L Gates LLP · No. 1:20-cv-09393
Judge
Vyskocil
Date
Apr. 11, 2025

Background

Willie E. Dennis is proceeding without a lawyer and alleges race discrimination and retaliation under Section 1981 and Title VII, along with various state-law claims. The case had been stayed after a motion to compel arbitration was granted by the District of Columbia, pending an arbitration proceeding between the parties.

Dennis submitted letters asking the court for temporary restraining orders and preliminary injunctions. He sought an order preventing Mr. Mungovan or other Proskauer partners or employees from making claims to law-enforcement agencies that could lead to his arrest. He also sought an order preventing Proskauer or K&L Gates partners or employees from bringing criminal or civil actions against him based solely on what he described as unsupported harassment claims.

Court’s Analysis

A temporary restraining order or preliminary injunction is an extraordinary remedy. To obtain one, a party must show irreparable harm—an injury that is actual, imminent, and not adequately repairable later—and must also show either a likelihood of success on the merits or sufficiently serious legal questions combined with hardships strongly favoring the party seeking relief.

The court concluded that Dennis’s requests concerned issues entirely different from those alleged in his amended complaint. For that reason, the court held that it lacked jurisdiction to order the requested relief. The court also found that Dennis had not shown irreparable harm. His concern that he might be arrested was speculative and did not establish a concrete and imminent injury.

Disposition

The court DENIED Dennis’s letters requesting temporary restraining orders and/or preliminary injunctions. It did not decide the merits of his underlying discrimination, retaliation, or state-law claims in this order. The court adjourned the April 15, 2025 conference to May 1, 2025, reminded the parties that violations of its Individual Practice Rules could result in sanctions, and directed the Clerk to terminate the motion pending at docket entry 83.

The authoritative version

Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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