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S.D.N.Y.Procedural orderFiled Oct. 26, 2022

Citigroup Inc. v. Seade

Judge
John Cronan
Docket
1:21-cv-10413
Court
U.S. District Court · Southern District of New York
Pages
2
Fee PetitionCivil Procedure
In one sentence

In Citigroup Inc. v. Seade, Judge Cronan ordered more briefing before deciding Citigroup’s request for fees and costs.

Who this affects

Citigroup and Luis Sebastian Sayeg Seade, because the court required additional briefing before evaluating Citigroup’s request for attorneys’ fees and costs.

What happened

In Citigroup Inc. v. Seade, Citigroup asked for attorneys’ fees and costs connected to a contempt-sanctions motion and to defending certain claims in a case brought by Luis Sebastian Sayeg Seade in Mexico.

The court requested more information about whether a rule concerning the location of legal work should limit the fees, whether the fees related only to the enjoined claims, the defending attorneys’ qualifications, and whether their rates were reasonable. The order did not decide whether to award the requested fees.

Judge John P. Cronan ordered Citigroup to file its additional briefing by November 18, 2022, allowed Seade to respond by November 30, 2022, and required Citigroup to serve the order on Seade.

The detailed version

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

Case
Citigroup Inc. v. Seade · No. 1:21-cv-10413
Judge
John Cronan
Date
Oct. 26, 2022

Background

Citigroup filed a letter and declaration seeking and documenting attorneys’ fees and costs. The request concerned Citigroup’s litigation of an April 21, 2022 motion for contempt sanctions, which resulted in a May 23, 2022 contempt order, and Citigroup’s defense of certain enjoined claims in an action that Luis Sebastian Sayeg Seade brought in Mexico.

Additional briefing ordered

The court ordered Citigroup to provide more briefing on five subjects:

  1. Whether the “forum rule”—a rule discussed in the cited Second Circuit decision concerning the location of legal work—should apply to fees connected with the Mexican action.
  2. Whether all documented fees from the Mexican action concerned the defense of the enjoined claims rather than other claims.
  3. The qualifications and credentials of the attorneys who defended the Mexican action.
  4. Whether the rates charged for defending the enjoined claims were reasonable in Mexico and in the Southern District of New York.
  5. Any other information that would help the court evaluate the reasonableness of the fees incurred in the Mexican action.

Order and deadlines

The court ordered Citigroup to submit the additional briefing by November 18,

  1. Seade could file a response by November 30,
  2. Citigroup also had to immediately serve Seade with a copy of the order and file proof of service by October 31,
  3. The opinion does not state a final ruling granting or denying Citigroup’s fee request.
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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