Secure Source Claims Company v. Edward F. Miller

Background

Secure Source Claims Company, LLC moved under Federal Rule of Civil Procedure 54(b) for entry of a $2 million judgment against Edward F. Miller, USDG LLC, Michael Piumelli, Giovanna Battaglia, Margaret Miller, Segovia Construction LLC, Jose Segovia, Samantha Bustamante, Kevin Roe, and Roe Site Management LLC. The opinion refers to these defendants collectively as the “Settling Miller Defendants.” The alleged settlement agreement appeared to have been signed in January 2024, but the court first received a copy when Secure Source filed its motion on March 27, 2025. A status report first mentioned the alleged settlement on May 31, 2024.

Romo Machine, LLC was allegedly involved in settlement discussions but did not sign the agreement. Fine Craftsman Group, LLC, Krzysztof Pogorzelski, and Eric Scott were not parties to the alleged settlement agreement.

Procedural History

The Settling Miller Defendants did not initially respond to Secure Source’s motion. On April 29, 2025, the court issued an order requiring them to explain why it should not recommend that the district judge grant the requested relief. Their former lawyer, Samidh Jalem Guha, requested more time and later responded that the settlement was allegedly conditioned on certain obligations, including dismissal of claims against the defendants who were parties to the agreement.

The defendants opposed the motion after their lawyer withdrew. They wrote that they had not known about the motion or the order requiring a response because those filings occurred while Mr. Guha represented them. Jose Segovia and Samantha Bustamante separately described hardships connected with the case. The opinion states that the Settling Miller Defendants had been without representation since July 1, 2025. It also notes that business entities cannot appear in court without a lawyer.

Analysis

Rule 54(b) allows a court in a case involving multiple claims or parties to enter a final judgment on fewer than all claims or parties for purposes of an immediate appeal. The court explained that this procedure is an exception to the general policy against piecemeal appeals and should be used sparingly. Courts consider both sound case management and fairness, including whether delaying an appeal would cause hardship or injustice.

The court found that Secure Source had not properly supported applying Rule 54(b) in these circumstances. In particular, Secure Source had stated that the parties would not appeal the entry of the final judgment. The court also found that the defendants’ responses, although limited, suggested they might have defenses to Secure Source’s claims. The parties further disputed the terms of the alleged settlement agreement.

Ruling

The court determined that the defendants had shown cause why it should not recommend entry of judgment against them based on Secure Source’s motion. The opinion does not expressly state that the motion was “denied”; it states only that the requested judgment was not recommended on the motion’s basis. Judge Ona T. Wang signed the order.