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S.D.N.Y.Procedural orderFiled Mar. 31, 2023

Wells Fargo Bank v. 5615 Northern LLC

Full caption

Wells Fargo Bank, National Association, as Trustee, for the benefit of the holders of COMM 2015-LC19 Mortgage Trust Commerical Mortgage Pass-Through Certificates v. 5615 Northern LLC

Judge
Vernon Broderick
Docket
1:20-cv-02048
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureEvidence
In one sentence

In Wells Fargo v. 5615 Northern, Judge Parker scheduled an evidentiary hearing because the submitted proof did not adequately establish foreclosure damages.

Who this affects

Wells Fargo must present testimony and documentary evidence at the scheduled hearing. 5615 Northern LLC and Spyro E. Avdoulos may attend, cross-examine witnesses, and present evidence.

What happened

Wells Fargo Bank, National Association, as Trustee, for the benefit of the holders of COMM 2015-LC19 Mortgage Trust Commercial Mortgage Pass-Through Certificates, sued 5615 Northern LLC and Spyro E. Avdoulos. The parties had previously told the court that foreclosure damages could be decided from written submissions without a hearing.

The court found the submissions inadequate. They did not show payments toward loan principal and interest, stated different principal amounts, provided no evidence of expense payments, and did not explain how interest was calculated under the loan documents.

Judge Katharine H. Parker ordered an evidentiary hearing for April 11, 2023, at 2:00 p.m. The plaintiff must be prepared to present testimony and documents; the defendants may attend, question witnesses, and present evidence.

The detailed version

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

Case
Wells Fargo Bank v. 5615 Northern LLC · No. 1:20-cv-02048
Judge
Vernon Broderick
Date
Mar. 31, 2023

Background

The parties previously informed the court that foreclosure damages could be determined from written submissions and that an evidentiary hearing was unnecessary. The order concerns the proof needed to determine the amount of damages; it does not state a final damages amount.

Court’s Analysis

Judge Parker found the submissions inadequate to determine the damages and lacking sufficient evidentiary support. As examples, the submissions did not include documents showing payments toward loan principal and interest to establish how the principal amount was calculated. The papers also stated slightly different principal amounts, provided no evidence that claimed expenses had been paid, and did not explain the method used to calculate interest under the applicable loan documents. Because the court could not verify the proposed damages calculations, it determined that testimony and documentary evidence were necessary.

Order

The court ordered an evidentiary hearing on April 11, 2023, at 2:00 p.m. in Courtroom 17D. Wells Fargo was required to be prepared to present testimony and documentary evidence. 5615 Northern LLC and Spyro E. Avdoulos could attend, cross-examine witnesses, and present evidence. The opinion does not state the ultimate amount of foreclosure damages or resolve the parties’ underlying claims.

The authoritative version

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

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