Ng v. Amguard Insurance Company
- Vernon Broderick
- 1:25-cv-00806
- U.S. District Court · Southern District of New York
- 11
In Brian Ng v. AmGUARD Insurance Company, Judge Stein denied Ng’s sanctions motion, finding North American Risk Services complied with the court’s disclosure order.
Brian Ng and North American Risk Services, Inc.; the ruling denied Ng’s requested sanctions and cautioned him about future filings.
What happened
Brian Ng, representing himself, asked the court to sanction North American Risk Services, Inc. (NARS) for allegedly failing to provide complete information about its ownership and related companies in a corporate disclosure. He sought monetary penalties, striking NARS’s answer, or a contempt finding.
The court denied the motion. It held that NARS complied with the court’s order and that its amended disclosure was sufficient. The court also said that an error in one member’s name and the use of a nickname for another were not sanctionable, and that Rule 7.1 did not require disclosure of NARS’s third-party affiliates.
Judge Stein also cautioned Ng against filings lacking a reasonable legal or factual basis or seeking plainly inappropriate relief, noting that sanctions could result from continued duplicative, vexatious, or clearly meritless filings.
The detailed version
- Ng v. Amguard Insurance Company · No. 1:25-cv-00806
- Vernon Broderick
- June 13, 2025
Background
Brian Ng, proceeding without a lawyer, filed a letter motion seeking sanctions against North American Risk Services, Inc. (NARS). Ng argued that NARS had not complied with an earlier order directing it to amend its corporate disclosure statement by identifying the citizenship of the members of Tricendent Risk Holdings, LLC, which the opinion describes as NARS’s owner. Ng challenged the names and completeness of the listed members and argued that NARS also should have disclosed related companies, including Global Risk Holdings and other affiliates.
Court’s analysis
The court explained that Federal Rule of Civil Procedure 7.1 requires disclosure of the citizenship of individuals or entities whose citizenship is attributed to a party in a diversity-jurisdiction case. The court stated, however, that it had directed NARS to disclose the citizenship of Tricendent’s members based on an incorrect understanding: NARS is a corporation, not a limited liability company, and the citizenship of a corporation’s owner generally is not attributed to the corporation for diversity-jurisdiction purposes unless the subsidiary is merely the parent’s alter ego or agent.
Despite that earlier error, the court found that NARS complied with the order and that its amended corporate disclosure statement was sufficient. The court concluded that the typographical error involving one member’s name and the use of a nickname for another were not sanctionable offenses. It also found no basis in Rule 7.1 or elsewhere for requiring NARS to disclose third-party affiliates.
Ruling
The court denied Ng’s motion for sanctions against NARS, finding the request wholly unwarranted. The court separately cautioned Ng that filings lacking a reasonable basis in law or fact, or seeking plainly inappropriate relief, could lead to sanctions if he continued filing duplicative, vexatious, or clearly meritless papers.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.