Applied Minds, LLC v. Guild Hall of East Hampton, Inc.

Background

Applied Minds, LLC provided design and project-supervision services to Guild Hall of East Hampton, Inc. under a July 2021 contract for renovation of the John Drew Theatre. Applied Minds alleged that Guild Hall owed more than $1.8 million in unpaid invoices after Guild Hall terminated the contract. Applied Minds asserted claims for breach of contract, quantum meruit, and unjust enrichment. Guild Hall asserted counterclaims for breach of contract, rescission, and negligent misrepresentation.

During discovery, Guild Hall served subpoenas on three Applied Minds customers: RTX Corporation, formerly Raytheon Technologies Corporation; The Boeing Company; and Dominion Energy, Inc. The subpoenas sought agreements between those companies and Applied Minds since January 1, 2021, invoices for Applied Minds’ work, and communications about that work or those invoices.

The Motion

Applied Minds moved to quash the subpoenas under Federal Rule of Civil Procedure 45. It argued that Guild Hall served them after the deadline for nonparty subpoenas and that they sought irrelevant and burdensome information. Guild Hall argued that the information was relevant, including to Applied Minds’ claim for quantum meruit, which seeks the fair value of services provided.

Court’s Analysis

The court rejected Applied Minds’ timeliness argument. Although the specific deadline for serving nonparty subpoenas had expired, the parties had paused discovery for settlement negotiations, the court later extended the overall fact-discovery deadline, and the subpoenas were served more than 30 days before that deadline. The court therefore found that the subpoenas were not untimely.

The court nevertheless found the subpoenas improper because they sought irrelevant and burdensome information. The court explained that the case concerned the value of Applied Minds’ services for Guild Hall’s theater project. Information about services Applied Minds may have provided to other customers, including defense contractors, did not show the value of the services provided to Guild Hall. For the quantum meruit claim, the relevant question was the fair and reasonable value of the work performed for Guild Hall, not the services provided to other customers.

The court also found that compliance would impose an undue burden on the subpoena recipients. Guild Hall could have sought information from Applied Minds through the ordinary discovery process or asked the court to address any dispute about Applied Minds’ responses. Instead, Guild Hall went directly to Applied Minds’ customers. The court stated that Guild Hall should have requested a discovery conference if it believed the information was relevant. The court did not impose sanctions, because Applied Minds did not request them.

Disposition

Judge Sarah L. Cave granted Applied Minds’ motion and quashed the subpoenas. Guild Hall was ordered to serve the opinion and order on the three recipients by Monday, April 21, 2025, and file proof of service.