Chelsea Hotel Owner LLC v. City Of New York
- Andrew Carter
- 1:21-cv-03982
- U.S. District Court · Southern District of New York
- 4
In Chelsea Hotel Owner LLC v. City Of New York, Judge Carter denied reconsideration of a discovery ruling concerning 2008–2010 emails.
The plaintiffs, including Chelsea Hotel Owner LLC, and the City of New York; the ruling concerned the plaintiffs’ request for 2008–2010 email communications.
What happened
Chelsea Hotel Owner LLC and other plaintiffs asked the court to reconsider its earlier decision affirming a magistrate judge’s ruling about emails from 2008 through 2010 concerning the Chelsea Hotel. The City argued that the request was untimely.
The plaintiffs argued that the magistrate judge had not addressed their request until after discovery closed and that the court had overlooked important facts. They also asked the court to reconsider its decision not to address the City’s other arguments and to order production for good cause.
Judge Andrew L. Carter, Jr. found no clear error or serious unfairness requiring reconsideration. The court denied the plaintiffs’ motion for reconsideration and directed the Clerk to terminate the motion.
The detailed version
- Chelsea Hotel Owner LLC v. City Of New York · No. 1:21-cv-03982
- Andrew Carter
- June 6, 2025
Background
The plaintiffs sought reconsideration of the court’s March 21, 2025 decision affirming three discovery orders issued by Magistrate Judge Robert W. Lehrburger. The pending motion focused on Judge Lehrburger’s July 19, 2024 order denying the plaintiffs’ request to compel production of email communications from 2008 through 2010 concerning the status of the Chelsea Hotel.
The plaintiffs had raised alleged deficiencies in the City’s document production in July 2024. The City responded that the request for the 2008–2010 communications was untimely. Judge Lehrburger ruled that the plaintiffs were not entitled to those communications for the reasons stated by the City. The plaintiffs objected, but this court overruled the objections and affirmed the July order on March 21, 2025.
Arguments on Reconsideration
The plaintiffs did not claim that controlling law had changed or that new evidence had become available. Instead, they argued that the court had overlooked key facts. In particular, they contended that they had made the request before discovery closed, had raised the City’s failure to produce the communications at February and April 2024 conferences, and that Judge Lehrburger had not addressed the request until the July order.
The court disagreed with the plaintiffs’ reading of the record. It relied on its earlier finding that, at the April 2024 conference, Judge Lehrburger had said he was not requiring a wholesale search going back to 2008 through 2010, but was requiring production of communications that came up during the City’s investigation. The court also noted that the plaintiffs did not object at that time or to the following April order.
The plaintiffs further asked the court to reconsider its decision to rely on timeliness without addressing the City’s alternative arguments. The court found that the plaintiffs had not explained why relying on timeliness was insufficient. The plaintiffs also suggested that the court should compel discovery for good cause, but the court found that they had not specifically shown why reconsideration of that issue was appropriate.
Ruling
Under Local Civil Rule 6.3, reconsideration is an extraordinary remedy generally limited to an intervening change in controlling law, new evidence, or the need to correct a clear error or prevent manifest injustice. Judge Andrew L. Carter, Jr. concluded that the plaintiffs had not shown any of those grounds. The court therefore denied the plaintiffs’ motion to reconsider its earlier order overruling their objections to Judge Lehrburger’s July order and directed the Clerk of Court to terminate the pending motion at ECF No. 190.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.