Chelder v. General Conference Corporation
- Ronnie Abrams
- 1:25-cv-04313
- U.S. District Court · Southern District of New York
- 6
In Chelder v. General Conference Corporation, Judge Willis denied Plaintiffs’ request to reconsider an earlier discovery-protection ruling.
Plaintiffs’ ability to seek immediate protection for sensitive third-party information was affected; the court left them able to renew the request when the issue became appropriate.
What happened
In Jacques Chelder, et al. v. General Conference Corporation, et al., Plaintiffs asked the court to reconsider its decision denying their request for a protective order, which would govern sensitive information from a separate case.
The court had previously denied that request without prejudice after Plaintiffs and Corporate Defendants jointly requested a 60-day pause in discovery while the court considered a motion to dismiss. Plaintiffs argued that the pause should not cover coordination with a third-party receiver and would delay time-sensitive evidence.
Judge Jennifer E. Willis denied the reconsideration motion. She ruled that Plaintiffs had not shown a change in controlling law, new evidence, a clear error, or a serious unfairness requiring reconsideration. The court also stated that the earlier denial was without prejudice, so Plaintiffs could raise the protective-order issue again when it became appropriate.
The detailed version
- Chelder v. General Conference Corporation · No. 1:25-cv-04313
- Ronnie Abrams
- Oct. 24, 2025
Background
Plaintiffs filed a class action complaint on May 29, 2025. They later asked for a protective order—a court order governing the production, handling, and use of sensitive information that might be obtained from a receiver in a separate case, Commodity Futures Trading Commission v. Eddy Alexandre, No. 1:22-cv-03822-VEC (S.D.N.Y.).
The Corporate Defendants—General Conference Corporation of Seventh-day Adventists, North American Division Corporation of Seventh-day Adventists, and Theodore Norman Clair Wilson—filed a motion to dismiss. Plaintiffs and the Corporate Defendants then jointly requested a 60-day stay, or pause, of discovery and the submission of initial disclosures while the motion to dismiss was pending. The court granted that request and denied Plaintiffs’ protective-order motion without prejudice because it was premature.
Plaintiffs moved for reconsideration and argued that the stay applied only to discovery between the parties, not to coordination with the third-party receiver. They also argued that delaying the protective order could push the collection of third-party evidence close to or beyond important case deadlines. The Corporate Defendants opposed reconsideration, arguing that Plaintiffs could seek the same relief after the stay ended.
Legal standard
The court described reconsideration as an extraordinary remedy used sparingly. Under the applicable local rule, reconsideration generally requires the moving party to identify controlling decisions or facts the court overlooked, an intervening change in controlling law, new evidence, a clear error, or a manifest injustice. Reconsideration is not an opportunity to repeat arguments already rejected or raise arguments that could have been made earlier.
Court’s reasoning
The court found that Plaintiffs had not shown manifest injustice. Their concerns about delayed third-party evidence were not yet ready for decision because the court had not set a case-management plan or discovery deadlines. The court stated that Plaintiffs could raise the issue with Defendants and, if necessary, with the court after discovery dates were set. It also found that any limited prejudice was reduced because the earlier denial of the protective-order motion was without prejudice.
The court also found no clear error. It concluded that the parties’ joint letter requested a 60-day stay of discovery while the court considered the Corporate Defendants’ motion to dismiss, and that the court had intended the stay to cover all discovery. Because discovery had not begun and no case-management dates had been set, the protective-order motion remained premature. The court stated that Plaintiffs could raise the issue again once it became ripe.
Disposition
The court denied Plaintiffs’ motion for reconsideration and directed the Clerk of Court to close Docket Nos. 145 and 146. The order did not alter the earlier ruling’s treatment of the protective-order motion as denied without prejudice.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.