Lewis v. Laz Parking Ltd., LLC

Background

Andre Lewis, proceeding without a lawyer, brought this action against Laz Parking Ltd., LLC, and Juan Irizarry. The opinion states that Irizarry was an employee of Lewis’s former employer, Laz Parking. Lewis alleged that statements by Irizarry were false and defamatory, harmed him in various ways, and breached a settlement agreement between Lewis and Laz Parking.

Lewis filed motions for a protective order under Federal Rule of Civil Procedure 26(c), expedited discovery, and a temporary restraining order and preliminary injunction. Defendants later moved to dismiss the complaint. Lewis opposed that motion and then filed an amended complaint. The court treated the amended complaint as timely and procedurally proper as a one-time courtesy because Lewis was representing himself. Defendants were directed to respond to the amended complaint by August 18, 2025. The court stated that, if Defendants filed a new or supplemental motion to dismiss, Lewis’s opposition would be due September 15, 2025, and Defendants’ reply would be due September 29, 2025.

Rulings

The court denied Defendants’ original motion to dismiss as moot, without prejudice to renewal. The court also directed the Clerk to terminate that motion and Lewis’s notice of a motion to strike or deny the dismissal motion.

The court stated that Lewis had filed numerous motions and other submissions that were premature or unwarranted and denied them for the reasons stated in Defendants’ August 8, 2025 letter-motion and in the order. Specifically:

- The court denied Lewis’s motion for sanctions and default judgment. It found that Lewis had not shown egregious or deliberate conduct concerning Defendants’ initially incomplete disclosure statement, found no evidence that Lewis was prejudiced, and noted that Defendants had actively defended the action and timely filed their dismissal motion. - The court denied Lewis’s discovery motions because the parties had not held the required conference under Rule 26(f). It also found no good cause for expedited discovery while Defendants’ response to the amended complaint was pending. - The court denied Lewis’s motion for a temporary restraining order and preliminary injunction. Lewis had not shown an actual and imminent injury that could not be remedied by waiting until the case’s disposition. The court explained that money damages could address the alleged contract breach or defamatory statements, meaning the alleged harm was not irreparable. The court also stated that Lewis had not shown that Defendants would make, or intended to make, the alleged statements to third parties at that time or in the future. Because Lewis had not established irreparable harm, the court did not consider other requirements, such as the likelihood of success on the merits.

The court warned Lewis to stop filing frivolous motions or other frivolous or premature submissions and stated that continued conduct of that kind could result in financial sanctions. The Clerk was directed to terminate Docket Nos. 5–7, 40–41, 43, 47, and 53, and to mail the order to Lewis. The parties were ordered to appear for a conference on August 25, 2025, at 11:00 a.m. The court also certified that any appeal would not be taken in good faith and denied Lewis permission to proceed without paying the appeal filing fee.