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S.D.N.Y.Procedural orderFiled Apr. 2, 2020

Indemnity Insurance Company of North America v. Expeditors International of…

Full caption

Indemnity Insurance Company of North America v. Expeditors International of Washington, Inc.

Judge
James Oetken
Docket
1:17-cv-02575
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureSummary Judgment
In one sentence

In Indemnity Insurance v. Expeditors, Judge Oetken denied reconsideration because the plaintiff had waived its argument about indirect carriers.

Who this affects

The ruling affected Indemnity Insurance Company of North America and the defendants, including Expeditors International of Washington, Inc., by denying reconsideration of the earlier order.

What happened

Indemnity Insurance Company of North America v. Expeditors International of Washington, Inc. concerned the plaintiff’s request to revisit an earlier order resolving the parties’ cross-motions.

The plaintiff argued that the court had erred by deciding that it waived its argument that indirect carriers qualified as carriers under China Air’s waybill.

Judge J. Paul Oetken found that the court had overlooked neither controlling law nor a crucial fact, and denied the motion for reconsideration.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Indemnity Insurance Company of North America v. Expeditors International of… · No. 1:17-cv-02575
Judge
James Oetken
Date
Apr. 2, 2020

Background

Indemnity Insurance Company of North America, acting as subrogor of GE Aviation Materials, L.P., moved for reconsideration of the court’s earlier Opinion and Order resolving the parties’ cross-motions. The motion concerned the court’s conclusion that Indemnity had waived an argument that indirect carriers qualified as carriers under China Air’s waybill.

Legal standard

The court explained that reconsideration is an extraordinary remedy used sparingly. A party seeking it must show an intervening change in controlling law, newly available evidence, or a need to correct clear error or prevent manifest injustice.

Ruling

The court reviewed the record and the parties’ memorandums of law and concluded that it had overlooked neither a controlling legal issue nor a crucial fact. The court noted that Indemnity had not made the indirect-carrier argument in its briefing, so the argument was waived. Judge J. Paul Oetken therefore denied Indemnity’s motion for reconsideration and directed the Clerk of Court to close the motion at Docket Number 89.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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