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S.D.N.Y.Procedural orderFiled Jan. 13, 2021

Komatsu v. The City of New York

Judge
Lorna Schofield
Docket
1:18-cv-03698
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureDiscoveryPro Se
In one sentence

In Komatsu v. The City of New York, Judge Schofield denied reconsideration motions and overruled discovery objections.

Who this affects

The plaintiff, Towaki Komatsu, was affected by the denial of reconsideration and the overruling of objections to the discovery order. The defendants’ discovery requests were also addressed, but the opinion does not state the defendants’ individual names.

What happened

In Komatsu v. The City of New York, the plaintiff challenged several earlier court orders, including an order resolving discovery disputes about requested answers and documents.

The plaintiff asked the court to reconsider several older orders and objected to a magistrate judge’s December 18, 2020, discovery order. The reconsideration requests were filed after the fourteen-day deadline.

Judge Schofield denied the reconsideration motions as untimely and overruled the objections because the discovery order was not clearly mistaken or contrary to law. The clerk was directed to mail the order to the plaintiff, who was representing himself.

The detailed version

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

Case
Komatsu v. The City of New York · No. 1:18-cv-03698
Judge
Lorna Schofield
Date
Jan. 13, 2021

Background

On December 18, 2020, Magistrate Judge Gorenstein issued an order resolving several discovery disputes involving the defendants’ requests for answers to interrogatories and production of documents. The plaintiff filed letters objecting to that order on December 19 and 30, 2020, and January 5, 2021.

The plaintiff also filed letters seeking reconsideration of earlier orders dated January 9, February 5, and March 1, 2019; September 30, 2019; and August 10, 2020. The opinion does not describe the underlying subjects of those earlier orders.

Legal standard

For objections to a magistrate judge’s ruling on a nondispositive matter, the district court may change or set aside the ruling only if it is clearly erroneous or contrary to law. A finding is clearly erroneous when, after reviewing the evidence, the court is firmly convinced that a mistake was made. A ruling is contrary to law when it fails to apply, or misapplies, relevant statutes, case law, or procedural rules. The opinion also states that discovery decisions resolving requests to compel responses are nondispositive and receive substantial deference.

Local Civil Rule 6.3 requires a motion for reconsideration to be filed within fourteen days after the court’s determination of the original motion.

Ruling

Judge Schofield denied the motions for reconsideration, as outlined in the order, because they were untimely. The court also overruled the plaintiff’s objections to Judge Gorenstein’s December 18, 2020, order because that order was not clearly erroneous or contrary to law.

The clerk was directed to mail a copy of the order to the pro se plaintiff, meaning the plaintiff was representing himself without a lawyer.

The authoritative version

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

Open opinion PDF →
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