Laufer Group International, Ltd. v. Pinnacle Clothing Inc.
- Andrew Carter
- 1:24-cv-07855
- U.S. District Court · Southern District of New York
- 2
In Laufer Group v. Pinnacle Clothing, Judge Figueredo deemed admissions admitted, ordered discovery responses, and found an attorney-fee award inappropriate.
Laufer Group International, Ltd. and Pinnacle Clothing Inc.; Pinnacle was required to respond to the interrogatories and document requests, and the requests for admission were treated as admitted. Laufer Group did not receive the requested attorney-fee award under Rule 37(a).
What happened
In Laufer Group International, Ltd. v. Pinnacle Clothing Inc., Pinnacle did not respond to interrogatories, document requests, or requests for admission served by Laufer Group. The court addressed the dispute at a conference.
The court treated the requests for admission as admitted because Pinnacle did not respond within 30 days. It also directed Pinnacle to respond to the interrogatories and document requests by August 21, 2025, if it had not already done so.
Judge Valerie Figueredo found that Laufer Group could not obtain attorney fees under the discovery-fee rule because it had submitted a letter rather than formally moving to compel discovery. The court directed the Clerk to terminate the letter motion.
The detailed version
- Laufer Group International, Ltd. v. Pinnacle Clothing Inc. · No. 1:24-cv-07855
- Andrew Carter
- July 21, 2025
Background
Laufer Group reported that it had served Pinnacle with interrogatories, document requests, and requests for admission on April 15, 2025. Laufer Group stated that Pinnacle had not responded. The court held a conference on June 23, 2025, and Pinnacle did not dispute that it had failed to respond to the discovery.
Laufer Group also sought attorney fees for preparing its letter to the court and attending the conference.
Requests for Admission
The court ruled that Pinnacle’s failure to respond to the requests for admission within 30 days meant that the matters were admitted under Federal Rule of Civil Procedure 36(a)(3). After reviewing the requests, the court found them proper because they were factual in nature, including questions about whether Pinnacle entered into a Credit & Security Agreement with Laufer Group and whether Pinnacle disputed the correctness of invoices provided by Laufer Group.
The court also found that the two requests Pinnacle identified as improper were primarily factual or, at most, involved applying law to facts. The court stated that this type of request is permitted under Rule 36(a)(1).
Attorney Fees
Federal Rule of Civil Procedure 37(a)(5) allows reasonable expenses and attorney fees for a party that successfully moves to compel disclosure or discovery. The court ruled that Laufer Group had not filed the required motion to compel. Its two-page letter describing the discovery dispute, followed by resolution at a conference without formal motion practice, did not satisfy that requirement. The court therefore found an award of fees under Rule 37(a) inappropriate.
Order
The court directed Pinnacle to respond to Laufer Group’s interrogatories and document requests by August 21, 2025, if Pinnacle had not already done so. The Clerk of Court was directed to terminate the letter motion at ECF No. 17. Judge Valerie Figueredo signed the order on July 21, 2025.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.