Advanced Analytics, Inc. v. Citigroup Global Markets, Inc.

Background

Advanced Analytics, Inc. filed a letter motion seeking reconsideration and relief from the court’s July 7, 2022, order. That earlier order had denied an earlier motion for reconsideration and a motion asking the court to take official notice of certain documents and facts. Those earlier motions had sought relief from the court’s November 5, 2021, judgment and related orders.

The court construed the new motion as invoking Federal Rules of Civil Procedure 59(e) and 60(b)(1), (3), and (6). Rule 59(e) concerns changing or reconsidering a judgment, while Rule 60(b) provides grounds for relief from a judgment or order.

Arguments and Analysis

Advanced Analytics argued that the court’s July 7 order was deficient because it did not discuss each argument or evidentiary citation that Advanced Analytics had presented. The court noted that Advanced Analytics cited no authority requiring a court to address every argument or evidentiary citation in that manner.

The court also held that the motion was improperly filed as a letter, contrary to Southern District of New York Local Civil Rules 6.3 and 7.1. Although that defect alone supported denial, the court considered the motion’s substance and concluded that refiling it in a compliant format would not cure its deficiencies.

The court explained that Rules 59(e) and 60(b) are not vehicles for relitigating the merits of earlier decisions. It concluded that Advanced Analytics’s submission showed disagreement with the court’s prior decisions but did not establish a basis for the requested relief.

Disposition

The court denied Advanced Analytics’s motion for reconsideration. The order resolved docket entry 499. Judge Laura Taylor Swain stated that the motion did not warrant relief under Rule 59(e) or Rule 60(b), and she incorporated the reasons given in the July 7, 2022, order.