Oneflight International, Inc. v. Stallion Aviation, LLC
- John Koeltl
- 1:24-cv-08381
- U.S. District Court · Southern District of New York
- 3
In Oneflight International v. Stallion Aviation, Magistrate Judge Ricardo ordered more evidence on damages after default judgment.
Oneflight International, Inc. must provide additional information and proof of service. Stallion Aviation, LLC may respond to the supplemental submission.
What happened
In Oneflight International, Inc. v. Stallion Aviation, LLC, the court reviewed Oneflight’s proposed findings and supporting declaration about damages after an entry of default judgment. The court explained that damages are not automatically accepted when a defendant defaults and must be supported by admissible evidence.
The court found that Oneflight’s submission did not provide enough information to establish the damages with reasonable certainty. The declaration did not explain David Stefanski’s relationship to Oneflight or the basis for his personal knowledge, and it did not identify the dates or covered periods for Oneflight’s $182,000 monthly payments to Stallion Aviation and the lender.
Magistrate Judge Henry J. Ricardo ordered Oneflight to file supplemental information by October 6, 2025, and proof of service by October 8. Stallion Aviation may respond by October 22, 2025; the order did not finally determine the damages amount.
The detailed version
- Oneflight International, Inc. v. Stallion Aviation, LLC · No. 1:24-cv-08381
- John Koeltl
- Sept. 22, 2025
Background
On March 11, 2025, the Court entered a scheduling order for an inquest into damages. The order required Oneflight International, Inc. to submit proposed findings of fact and conclusions of law concerning injunctive relief, damages, and any other monetary relief permitted under the entry of default judgment, or to state that it would rely on earlier submissions.
On May 12, 2025, Oneflight filed proposed findings concerning damages and a declaration from David Stefanski with exhibits. The court explained that, even when a defendant defaults and does not appear to object, damages must be based on admissible evidence. Allegations about damages in a pleading are not automatically treated as admitted. Instead, the plaintiff must provide enough detailed affidavits and other documents for the court to establish damages with reasonable certainty.
Court’s Analysis
The court reviewed Oneflight’s submissions and concluded that additional information was needed. Stefanski stated that his declaration was based on personal knowledge and a review of Oneflight’s corporate records, but the declaration did not describe his relationship to Oneflight or explain how he had personal knowledge of the facts, including Oneflight’s alleged payments.
The declaration also did not identify the dates on which Oneflight made its $182,000 monthly payments to Stallion Aviation and to the lender, respectively, or the months to which those payments applied.
Order
Magistrate Judge Henry J. Ricardo directed Oneflight to file a supplemental written submission by October 6, 2025, providing: (1) Stefanski’s relationship to Oneflight and the basis for his personal knowledge; (2) the date and covered period of Oneflight’s $182,000 payment to Stallion Aviation; and (3) the date and covered period of Oneflight’s $182,000 payment to the lender.
The court also directed Oneflight to file proof of service on Stallion Aviation by October 8, 2025. Stallion Aviation’s response, if any, was due by October 22, 2025. The order required additional evidence but did not state a final damages award.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.