Polska Fundacja Narodowa v. Athlete Benefits Group, LLC
- Lorna Schofield
- 1:22-cv-05725
- U.S. District Court · Southern District of New York
- 2
In Polska Fundacja Narodowa v. Athlete Benefits Group, Judge Schofield entered a $289,451.83 judgment reflecting the confirmed arbitration award, interest, costs, and attorneys’ fees.
Polska Fundacja Narodowa received a judgment against Athlete Benefits Group, LLC, and Lamar D. Williams for $289,451.83 under the confirmed arbitration award.
What happened
In Polska Fundacja Narodowa v. Athlete Benefits Group, Polska Fundacja Narodowa asked the court to specify the amounts to include in the final judgment after the court had confirmed an arbitration award. The respondents, Athlete Benefits Group, LLC, and Lamar D. Williams, responded without lawyers.
The arbitration award required the respondents to pay $150,000 for reimbursement of a deposit, $26,000 in costs, and $52,431.77 in attorneys’ fees. It also awarded interest under rates set under the Polish Civil Code. The respondents objected that the interest lacked statutory authorization, that it was outside the rules governing interest on judgments, that LIBOR was improperly used, and that the interest would provide unfair or duplicative compensation.
The court rejected those objections and, in an order by Judge Lorna G. Schofield, granted judgment to the petitioner for $289,451.83. The judgment included $150,000 for the deposit, $45,470.97 in interest on the deposit, $78,431.77 in costs and attorneys’ fees, and $15,549.09 in interest on those costs and fees. The Clerk was directed to enter the judgment and close the motion.
The detailed version
- Polska Fundacja Narodowa v. Athlete Benefits Group, LLC · No. 1:22-cv-05725
- Lorna Schofield
- Aug. 8, 2023
Background
An April 21, 2023 Opinion and Order granted Polska Fundacja Narodowa’s petition to confirm an arbitration award. On August 2, 2023, the petitioner filed a letter motion asking the court to determine the amounts of the award, interest, and fees to include in the final judgment. Athlete Benefits Group, LLC, and Lamar D. Williams filed a response on August 4, 2023. Because the respondents were proceeding without lawyers, the court interpreted their response liberally.
Amounts Awarded
The confirmed arbitration award stated that the respondents were liable for $150,000, representing reimbursement of the deposit. It also awarded $26,000 in costs and $52,431.77 in attorneys’ fees. The award provided for interest under rates established under the Polish Civil Code: interest on the deposit accrued from December 17, 2019, and interest on the costs and fees accrued from October 21, 2021.
Respondents’ Objections
The respondents objected to the interest award on several grounds. They argued that no international statute authorized the interest, that prejudgment interest was outside the relevant New York judgment-interest provisions, and that LIBOR or other rates were improperly used. They also argued that the interest would result in unfair compensation and duplicate recovery.
The court rejected those objections. It explained that the interest was awarded under the already-confirmed arbitration award, not under a statute. The court also stated that the interest rate was calculated using announcements by the Polish Minister of Justice, rather than LIBOR. Finally, the court noted that the arbitration award had determined that Polish law authorized interest to compensate for delayed payment and that the petitioner’s request for interest was reasonable.
Disposition
The court ordered that judgment be granted to the petitioner in the amount of $289,451.83, consisting of $150,000 for return of the deposit, $45,470.97 in interest on the deposit, $78,431.77 in costs and attorneys’ fees awarded by the arbitrator, and $15,549.09 in interest on the costs and attorneys’ fees. Judge Lorna G. Schofield directed the Clerk of Court to enter judgment and close the motion at Docket Number 51.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.