Ravazzani v. Po
- Analisa Torres
- 1:24-cv-09673
- U.S. District Court · Southern District of New York
- 4
In Ravazzani v. Shop Po, Judge Willis denied Kal Rieman’s motion to compel discovery of licenses and settlement agreements.
The ruling affected Defendant Kal Rieman’s effort to obtain discovery from Plaintiff Pablo Ravazzani. It denied the requested discovery and did not compel immediate production of Ravazzani’s settlement agreements with co-defendants.
What happened
Pablo Ravazzani v. Shop Po, LLC involved Defendant Kal Rieman’s request for documents from Ravazzani, including licenses for photography services and settlement agreements involving his copyrighted photographs. Rieman argued the documents could help measure damages.
Ravazzani opposed the request, arguing that it was irrelevant, overly broad, and unnecessary because an invoice already showed the fees charged for the photographs at issue. The court also considered the timing of producing settlement agreements with co-defendants, which Ravazzani had agreed to provide but only after judgment.
Judge Jennifer E. Willis denied Rieman’s motion to compel in full. The court found the requested licenses and settlement agreements irrelevant to the claims and defenses, overly broad in time and scope, and disproportionate to the case. It also denied immediate production of the co-defendant settlement agreements and directed the Clerk of Court to close the motion.
The detailed version
- Ravazzani v. Po · No. 1:24-cv-09673
- Analisa Torres
- Oct. 7, 2025
Background
Defendant Kal Rieman filed a letter motion to compel Ravazzani to produce two categories of documents: licenses Ravazzani had obtained while providing photography services, and settlement agreements involving Ravazzani’s copyrighted photographs, including agreements with co-defendants in the case. Rieman argued that the documents were relevant to measuring damages.
Ravazzani opposed the request. He argued that the documents were not relevant to the damages issues in the case and that the request for all prior licenses and settlement agreements was too broad in scope and time. Ravazzani also pointed to an invoice that directly reflected the fees he charged for using the photographs involved in the case.
The parties did not dispute that Ravazzani had agreed to produce settlement agreements with co-defendants. They disagreed about timing. Rieman sought immediate production so that he could evaluate and challenge Ravazzani’s damages theory during discovery and expert analysis. Ravazzani argued that production should occur only after judgment because the agreements might matter if any damages award against Rieman were joint and several with other defendants.
Legal standard
The court applied Federal Rule of Civil Procedure 26. That rule generally permits discovery of nonprivileged information relevant to a party’s claim or defense. The court explained that relevance is interpreted broadly, but discovery must have objective support and must be proportional to the needs of the case; it cannot be based on mere speculation or become a fishing expedition.
Ruling
The court denied Rieman’s motion to compel in full. It found that the requested licenses and settlement agreements were not relevant to liability and did not need to be used to approximate licensing fees because the parties already had a direct licensing history reflected by the invoice. The court also found the requests virtually unlimited in time and scope and not proportional to the needs of the case.
The court separately denied Rieman’s request to compel immediate production of the settlement agreements with co-defendants. Because the court did not find those agreements relevant even to damages calculations, it rejected Rieman’s arguments for immediate production. The Clerk of Court was respectfully requested to close Dkt. No. 146.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.