Edelman Arts, Inc. v. Spoelstra
- John Koeltl
- 1:17-cv-04789
- U.S. District Court · Southern District of New York
- 2
In Edelman Arts v. Spoelstra, Judge Koeltl entered a $5.7 million default judgment, adjusted prejudgment interest, and closed the case.
The plaintiff and the defendants were affected. The plaintiff received a $5,700,000 judgment, subject to $1,000,000 being retained in escrow until the stated condition was met; the defendants were subject to the judgment and nine-percent annual prejudgment interest through entry of judgment.
What happened
Edelman Arts, Inc. v. Spoelstra concerned a magistrate judge’s recommendation that the defendants be held liable for $5,700,000, with $1,000,000 retained in escrow and prejudgment interest added. No party objected before the deadline.
The court agreed with the recommendation on damages but found that the interest period had been calculated incorrectly. Interest had to run from December 15, 2016, through the date the final judgment was entered, rather than ending on April 24, 2019.
Judge Koeltl directed the Clerk to enter judgment for the plaintiff and against the defendants for $5,700,000, retain $1,000,000 in escrow until the plaintiff showed it had satisfied a separate $1,000,000 judgment, calculate nine-percent annual prejudgment interest through entry of judgment, and close the case and pending motions.
The detailed version
- Edelman Arts, Inc. v. Spoelstra · No. 1:17-cv-04789
- John Koeltl
- Mar. 7, 2021
Background
The court reviewed Magistrate Judge Netburn’s January 11, 2021 Report and Recommendation. The recommendation found the defendants liable to the plaintiffs for $5,700,000, with $1,000,000 retained in escrow by the court, plus prejudgment interest. The opinion states that no objections were filed and that the objection period had expired.
Prejudgment Interest
The court adopted the recommendation as to damages but rejected its calculation of prejudgment interest. The recommendation used a prejudgment period ending on April 24, 2019, the date the court had determined that a default judgment should be entered. Relying on the stated rule that prejudgment interest continues until judgment is entered, the court directed that interest be calculated from December 15, 2016, through the date the final judgment was entered, at an annual rate of nine percent.
Disposition
Judge Koeltl adopted the Report and Recommendation in all respects except the prejudgment-interest calculation. The Clerk was directed to enter judgment for the plaintiff and against the defendants for $5,700,000, retain $1,000,000 in escrow until the plaintiff presented evidence that it had satisfied a separate $1,000,000 judgment entered against it in a New York state-court matter, calculate the specified prejudgment interest, close all pending motions, and close the case. Because the order entered a default judgment rather than deciding the underlying claims after an adversarial merits proceeding, this is classified as a procedural order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.