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S.D.N.Y.Procedural orderFiled June 12, 2023

Krohnengold v. New York Life Insurance Company

Judge
Jesse Furman
Docket
1:21-cv-01778
Court
U.S. District Court · Southern District of New York
Pages
1
DiscoveryCivil Procedure
In one sentence

In Krohnengold v. New York Life, Judge Furman denied Plaintiffs’ request for discovery about other Fixed Dollar Account contracts.

Who this affects

The plaintiffs’ ability to obtain discovery about New York Life Insurance Company’s relationships with other Fixed Dollar Account contractholders was affected; the parties also had to address remaining meet-and-confer matters in a joint letter.

What happened

In Krohnengold v. New York Life Insurance Company, the plaintiffs asked the court to require New York Life to provide information about its relationships with other Fixed Dollar Account contractholders. The court had already addressed most of the parties’ discovery disputes during a June 9, 2023, conference.

The court decided that the requested information was not relevant or proportionate because a “most favored nation” status did not apply to the plaintiffs’ claims involving the Fixed Dollar Account. It therefore denied the plaintiffs’ motion to compel as to that discovery request. The parties were also ordered to file a joint letter about matters requiring further discussion by June 16, 2023.

Judge Jesse M. Furman issued the order on June 12, 2023. The order addresses discovery only and does not describe a decision on the underlying claims.

The detailed version

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

Case
Krohnengold v. New York Life Insurance Company · No. 1:21-cv-01778
Judge
Jesse Furman
Date
June 12, 2023

Background

The plaintiffs filed a motion to compel, asking the court to require discovery from the defendants. The court stated that its decisions on the other discovery disputes had been given during a June 9, 2023, telephone conference. It reserved one issue for decision: whether the plaintiffs could obtain discovery about the terms of New York Life Insurance Company’s relationships with other Fixed Dollar Account contractholders.

Ruling

The court agreed with the defendants after reviewing Henry v. Champlain Enterprises, Inc. and Chao v. Hall Holding Co. It held that the requested discovery was neither relevant nor proportionate because “most favored nation” status did not apply to the plaintiffs’ claims concerning the Fixed Dollar Account. The court therefore denied the plaintiffs’ motion to compel on that issue. The order does not state that the entire motion to compel was denied; it addresses the one issue on which the court had reserved judgment.

Additional Direction and Effect

The parties were ordered to file a joint letter by June 16, 2023, concerning the items on which they were required to meet and confer. Judge Jesse M. Furman’s order concerns discovery procedure and does not decide the underlying claims against New York Life Insurance Company or the other defendants.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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