Mango Labs, LLC v. Eisenberg

Background

Mango Labs, LLC brought this civil case against Avraham Eisenberg. The United States, acting through the United States Attorney for the Southern District of New York, moved to intervene under Federal Rule of Civil Procedure 24 and requested a full stay of the civil case, including discovery, until the related criminal case, United States v. Avraham Eisenberg, No. 23 Cr. 10 (RMB), concluded. The parties told the Government that they did not oppose a stay.

Court’s analysis

Rule 24 allows intervention as of right when a proposed intervenor has an interest connected to the case and resolving the case could impair the intervenor’s ability to protect that interest. It also allows permissive intervention when the proposed intervenor has a claim or defense sharing a common legal or factual question with the main case, provided intervention would not cause undue delay or prejudice.

The court explained that a civil case may be paused when related criminal proceedings are pending or imminent. The relevant considerations include the overlap between the civil and criminal issues, the status of the criminal case, the parties’ interests in proceeding or avoiding burdens from delay, the courts’ interests, and the public interest. The court found that the Government was entitled to intervene under Rule 24(a), would be permitted to intervene under Rule 24(b) for purposes of seeking a stay, and had shown that these considerations supported a stay.

Ruling

Judge Lewis J. Liman granted the requested relief. The case is stayed pending the criminal proceedings against the defendant. The Government must provide a status update in 12 months and every six months afterward concerning the criminal case and whether the stay should be lifted. The clerk was directed to close the docket entry for the Government’s motion. The opinion does not decide the underlying civil claims.