Zero Carbon Holdings, LLC v. Aspiration Partners, Inc.
- Lewis Liman
- 1:23-cv-05262
- U.S. District Court · Southern District of New York
- 2
In Zero Carbon Holdings v. Aspiration Partners, Judge Liman ordered Four Thirteen to provide judgment-enforcement discovery and awarded Aspiration fees and costs.
Aspiration Partners, Inc., the judgment creditor, may obtain fees and costs and submit supporting records. Four Thirteen, LLC, the judgment debtor, must provide the ordered discovery by May 22, 2025. The opinion does not state that the ruling imposes a requirement on Zero Carbon Holdings, LLC.
What happened
Zero Carbon Holdings, LLC v. Aspiration Partners, Inc. concerns Aspiration’s effort to obtain information from Four Thirteen, LLC to collect a $522,110.12 judgment. Aspiration served interrogatories and document requests, but Four Thirteen did not respond by the deadline or to Aspiration’s motion.
The court found that the requests were properly aimed at helping Aspiration collect the judgment. It ordered Four Thirteen to respond fully by May 22, 2025, and awarded Aspiration its fees and costs for bringing and pursuing the motion.
Judge Lewis J. Liman issued the order on April 24, 2025. The clerk was directed to close the motion on the docket, and Aspiration may submit records supporting its fees and costs.
The detailed version
- Zero Carbon Holdings, LLC v. Aspiration Partners, Inc. · No. 1:23-cv-05262
- Lewis Liman
- Apr. 24, 2025
Background
On September 20, 2024, the court entered judgment for Aspiration against Four Thirteen, LLC, in the amount of $522,110.12. Aspiration then served Four Thirteen with interrogatories and requests for production of documents under Federal Rule of Civil Procedure 69(a), which allows a judgment creditor to obtain discovery to help enforce a judgment.
Four Thirteen was served on October 23, 2024, and its responses were due by November 22, 2024. Four Thirteen did not respond. It also did not respond to Aspiration’s letter-motion to compel, despite having an opportunity to do so.
Court’s Analysis
The court explained that post-judgment discovery must be calculated to assist in collecting the judgment. It found that Aspiration’s requests met that standard and were proper under Rule 69. The court also found that Four Thirteen’s failure to respond was not substantially justified and that no other circumstances would make an award of fees and costs unfair.
Ruling
The court ordered Four Thirteen to respond fully to Aspiration’s interrogatories and document requests by May 22, 2025. The court awarded Aspiration its fees and costs for filing and pursuing the motion, allowing Aspiration to submit records of those fees and costs to the court with notice to Four Thirteen. The clerk was directed to close the motion, Docket No. 87. The opinion also directs Aspiration to serve the order on Four Thirteen by May 1, 2024, a date that appears inconsistent with the order’s April 24, 2025 date.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.