Rappaport v. Guardian Life Insurance Company of America
- Rochon
- 1:22-cv-08100
- U.S. District Court · Southern District of New York
- 1
In Rappaport v. Guardian Life, Judge Rochon granted Rappaport’s motion to quash subpoenas and deposition notices.
Jason Rappaport and Guardian Life Insurance Company of America, particularly their discovery obligations and preparation of final-judgment proposals.
What happened
In Rappaport v. Guardian Life Insurance Company of America, Jason Rappaport asked the court to quash subpoenas and deposition notices during a discovery dispute. The opinion also refers to the court’s earlier ruling that K-1 earnings count as pre-disability insured earnings.
The court granted Rappaport’s motion. It directed the parties to file a status letter and proposed final judgment materials by June 25, 2025, addressing any benefits overpayment before January 22, 2021 and whether they agreed on a final judgment.
Judge Jennifer L. Rochon said the court would address attorneys’ fees as a separate matter if the parties did not agree about them. The order did not otherwise state the reasons given during the discovery conference.
The detailed version
- Rappaport v. Guardian Life Insurance Company of America · No. 1:22-cv-08100
- Rochon
- May 28, 2025
Background
Jason Rappaport moved to quash, meaning invalidate or set aside, subpoenas and deposition notices issued in the case. The order also refers to an earlier ruling that K-1 earnings are included in pre-disability insured earnings.
Ruling
For the reasons stated on the record at the discovery conference, the court granted Rappaport’s motion to quash the subpoenas and deposition notices. The opinion does not provide the conference’s reasons in written form.
Next steps
The court directed the parties to file, by June 25, 2025, a status letter addressing whether there was any overpayment of benefits before January 22, 2021, for purposes of a possible future setoff. The parties must also file a proposed final judgment if they agree, or individualized proposals if they do not agree.
Attorney’s fees
The court stated that it would address attorney’s fees as a collateral matter—an issue separate from the main dispute—if the parties did not otherwise agree on those fees.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.