Byrne v. Yeats Construction Management, Inc.
- Lisa Smith
- 7:12-cv-05355
- U.S. District Court · Southern District of New York
- 2
In Byrne v. Yeats Construction, Judge Smith required Robert Byrne to authenticate medical documents before considering them in the damages hearing.
Robert Byrne, whose medical records and orthopedic assessment could not be considered for the damages award unless properly authenticated.
What happened
In Byrne v. Yeats Construction Management, Inc., Robert Byrne submitted medical records and an orthopedic surgeon’s assessment while the court considered the amount of damages after Yeats Construction Management, Inc. defaulted.
The court found that the documents were not properly authenticated, meaning the submission did not adequately establish that the records were genuine. Because of that, the court could not consider them when deciding the damages award.
Judge Lisa Margaret Smith ordered that, if Byrne wanted the court to consider the documents, he had to submit proper authentication by September 1, 2020.
The detailed version
- Byrne v. Yeats Construction Management, Inc. · No. 7:12-cv-05355
- Lisa Smith
- Aug. 4, 2020
Background
The court was conducting an inquest on damages resulting from the default of Defendant Yeats Construction Management, Inc. Robert Byrne submitted copies of medical records and a July 15, 2013, assessment report from his orthopedic surgeon. The opinion identifies these materials as exhibits to Byrne’s affidavit, Docket No. 29.
Court’s Analysis
The court ruled that the medical records and assessment report were not properly authenticated. Authentication is evidence establishing that a document is what its proponent claims it is. Because the documents were not authenticated, the court stated that it could not consider them in deciding the appropriate damages award.
Order
The court ordered that, if Byrne wanted the court to consider the documents, he had to submit proper authentication by September 1, 2020. The opinion does not state the amount of damages awarded or resolve any other issue involving Defendant Monomoy Farm LLC.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.