Manbro Energy Corporation v. Chatterjee Advisors, LLC

Background

In an earlier order dated March 17, 2023, the court granted Manbro’s motions in limine Nos. 5 and 6. A motion in limine asks the court to decide before trial whether particular evidence or arguments may be presented. Motion No. 5 excluded evidence and argument about how investors other than Manbro responded to the Final Distribution. Motion No. 6 excluded evidence and argument about Manbro’s class allegations and press outreach.

Defendants moved for reconsideration of those rulings. Reconsideration is an exceptional request asking the court to revisit an earlier decision based on an intervening change in controlling law, newly available evidence, or a need to correct a clear error or prevent serious unfairness. The court stated that reconsideration is not an opportunity to reargue issues, introduce theories that could have been raised earlier, or obtain another hearing on the merits.

Motion in Limine No. 5

Defendants argued that the record contained evidence about the circumstances surrounding other investors’ decisions to accept the Final Distribution and sign releases. The court found that this evidence did not explain why those investors accepted the distribution. The court remained concerned that the evidence would invite the jury to speculate and could be confusing and unfairly prejudicial. The possibility of offering different evidence at trial did not show that the court had overlooked existing information or that new evidence was available.

Motion in Limine No. 6

Defendants argued that Manbro’s withdrawn class allegations and limited press outreach were relevant to Manbro’s motives, the bias and credibility of Manbro and its witnesses, and other issues. The court stated that the claims to be tried concern Defendants’ alleged conduct benefiting themselves at Manbro’s expense, including alleged breach of the duty of good faith and fair dealing, breach of fiduciary duty, and unjust enrichment. It concluded that Manbro’s motives, as allegedly shown by the excluded evidence, were not relevant to those claims.

The court also rejected Defendants’ reliance on a prior decision that the earlier order had already found inapplicable. It declined to consider a new argument based on Federal Rule of Evidence 404(b)(2), because Defendants could have raised it before the earlier decision. The court further found that explaining the history and propriety of Manbro’s class allegations and withdrawal would confuse the jury and waste time, and that the evidence’s prejudicial effect outweighed its probative value.

Disposition

The court ordered that Defendants’ motion for reconsideration of the rulings on Manbro’s motions in limine Nos. 5 and 6 is DENIED. The clerk was directed to close the motion at Docket No. 318. This was a ruling on a reconsideration request concerning trial evidence, not a decision resolving the underlying claims.