Lewis v. Laz Parking Ltd., LLC
- Garnett
- 1:25-cv-02341
- U.S. District Court · Southern District of New York
- 2
In Lewis v. Laz Parking, Judge Garnett ordered Laz Parking to disclose all LLC members’ citizenship, warning the case may be dismissed if diversity cannot be assessed.
Laz Parking must provide additional ownership and citizenship information. The order also affects the continuation of the action because the court may dismiss it for lack of subject-matter jurisdiction if complete diversity cannot be assessed.
What happened
In Lewis v. Laz Parking Ltd., LLC, the court found that Laz Parking’s corporate disclosure statement did not identify the members or citizenship of two LLCs in its ownership chain: AIA Oscar Sidecar LLC and ALP Oscar Holdings LLC.
The court ordered Laz Parking to file an amended disclosure statement by August 22, 2025, identifying the citizenship of all its members. The court warned that the case may be dismissed if Laz Parking does not provide the information and the court cannot determine whether the parties are citizens of different states.
Judge Margaret M. Garnett issued the order on August 5, 2025. The order addressed whether the court could assess subject-matter jurisdiction based on diversity of citizenship; it did not decide the underlying claims.
The detailed version
- Lewis v. Laz Parking Ltd., LLC · No. 1:25-cv-02341
- Garnett
- Aug. 5, 2025
Background
On July 30, 2025, the court ordered Defendant Laz Parking, Ltd., LLC, to file a corporate disclosure statement under Rule 7.1 of the Federal Rules of Civil Procedure. Laz Parking filed the statement on August 4, 2025. It represented that its only member was LAZ Karp Associates, LLC, which was described as owned by New Laz Park Partners, Inc.; LAZ Investments, LLC; and AMF Oscar Investments, LLC. AMF Oscar Investments, LLC was described as having AIA Oscar Sidecar LLC and ALP Oscar Holdings LLC as its members.
Court’s Analysis
The court explained that citizenship must be clearly stated when a case relies on diversity of citizenship. For an LLC, the court must know the citizenship of all individual members and the incorporation and principal-place-of-business information for corporate members. If an LLC’s members are themselves LLCs, the citizenship of those LLCs’ members must also be identified, continuing through the ownership chain.
The court found Laz Parking’s disclosure statement deficient because it did not identify the members of AIA Oscar Sidecar LLC or ALP Oscar Holdings LLC, or the citizenship of those members.
Order
The court ordered Laz Parking to file an amended corporate disclosure statement by August 22, 2025, expressly identifying the citizenship of all its members, including the members of AIA Oscar Sidecar LLC and ALP Oscar Holdings LLC. The court stated that if Laz Parking failed to amend the statement and the court could not assess whether complete diversity existed, the action may be dismissed for lack of subject-matter jurisdiction without further notice. The order did not resolve the merits of the underlying dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.