Regisford v. Lockamy
Timothy Ricardo Regisford v. Lynn Lockamy; Lynn Lockamy v. Universal Music Group, Inc., Polygram Publishing, Inc., Universal Music Operations Limited, Universal Music Publishing Limited, Polydor Limited, Polydor Records a/k/a Universal Polydor, and Belters Only Productions Limited
- Alvin Hellerstein
- 1:23-cv-05928
- U.S. District Court · Southern District of New York
- 3
Regisford v. Lockamy; Lockamy v. Universal Music: Judge Hellerstein denied Lockamy’s motion to reconsider dismissal of her third-party complaint.
Lynn Lockamy, the third-party defendants, and the previously dismissed third-party copyright claims.
What happened
In Timothy Ricardo Regisford v. Lynn Lockamy and Lynn Lockamy v. Universal Music Group, Inc., Lynn Lockamy asked the court to reconsider its August 25, 2025 order dismissing her third-party complaint against the music-related defendants.
The court said Lockamy filed that complaint 299 days after answering the original complaint and without permission, although the rules allow only 14 days without permission. The court also said her copyright claims were too late because she knew about the ownership dispute more than a decade earlier.
Judge Alvin K. Hellerstein denied Lockamy’s motion for reconsideration and directed the Clerk to terminate the motion from the docket. The court did not change its earlier dismissal.
The detailed version
- Regisford v. Lockamy · No. 1:23-cv-05928
- Alvin Hellerstein
- Sept. 30, 2025
Background
Lynn Lockamy filed a third-party complaint against Universal Music Group, Inc., Polygram Publishing, Inc., Universal Music Operations Limited, Universal Music Publishing Limited, Polydor Limited, Polydor Records a/k/a Universal Polydor, and Belters Only Productions Limited. In an August 25, 2025 opinion and order, the court granted the third-party defendants’ motion to dismiss Lockamy’s third-party complaint. Lockamy then moved for reconsideration of that decision.
Court’s analysis
The court explained that reconsideration is not an opportunity to reargue issues that the court already considered. It said reconsideration generally requires the moving party to identify a controlling decision or important information that the court overlooked. The court found that Lockamy instead repeated arguments that she had raised and the court had rejected in connection with the earlier dismissal motion.
The court identified an independent procedural ground for dismissal: Lockamy filed her third-party complaint 299 days after filing her answer and did so without leave of court. Under Federal Rule of Civil Procedure 14(a)(1), a defendant may not file a third-party complaint more than 14 days after serving an answer without the court’s permission.
The court also reaffirmed its earlier merits analysis. It stated that a copyright-ownership claim accrues once, when a reasonably diligent plaintiff would have been put on notice to investigate whether a right existed. Copyright claims generally have a three-year limitations period after accrual. According to the court, Lockamy admitted that she first learned of the ownership dispute more than a decade earlier, when she discovered that Regisford had infringed the copyright in the underlying composition without her permission and took steps demanding that he stop. Because the ownership dispute arose about a decade before Belters Only’s later infringement in 2021, the court concluded that Lockamy’s copyright claims against the third-party defendants were time-barred and could not be pursued.
Disposition
Judge Alvin K. Hellerstein denied Lockamy’s motion for reconsideration. The Clerk was directed to terminate ECF No. 176. The order did not alter the August 25, 2025 order granting the third-party defendants’ motion to dismiss Lockamy’s third-party complaint.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.