McCaffrey v. Gatekeeper USA, Inc
- Vernon Broderick
- 1:14-cv-00493-VSB
- U.S. District Court · Southern District of New York
- 2
In McCaffrey v. Gatekeeper USA, Inc., Judge Broderick granted attorneys’ fees but denied prejudgment interest when amending the judgment.
Timothy Andrew McCaffrey received an amended judgment recognizing his entitlement to reasonable fees and costs of enforcing the judgment, including attorneys’ fees, but did not receive an award of prejudgment interest. Gatekeeper USA, Inc. and the other Defendants remain subject to the amended judgment’s fees-and-costs term.
What happened
In McCaffrey v. Gatekeeper USA, Inc., Timothy Andrew McCaffrey asked the court to amend a September 19, 2023 judgment to include attorneys’ fees and prejudgment interest. The parties’ settlement terms provided for reasonable fees and costs of enforcing the judgment.
The court granted the request to add attorneys’ fees and denied the request to add prejudgment interest. It found that the settlement did not provide for prejudgment interest and that the parties had not discussed that term during their settlement conference. The court noted that the judgment already included post-judgment interest because federal law requires it.
Judge Vernon S. Broderick ordered the Clerk to amend the judgment to include reasonable fees and costs of enforcing it, including attorneys’ fees. The court did not decide whether the case should be sealed; it stated that any sealing request must follow the judge’s applicable rules.
The detailed version
- McCaffrey v. Gatekeeper USA, Inc · No. 1:14-cv-00493-VSB
- Vernon Broderick
- Oct. 24, 2023
Background
Plaintiff Timothy Andrew McCaffrey, proceeding without a lawyer, filed a letter asking the court to amend the judgment entered on September 19, 2023. He requested that the judgment include attorneys’ fees and prejudgment interest. The request relied on the parties’ August 25, 2022 Terms of Settlement.
Attorneys’ Fees
The court granted Plaintiff’s request to amend the judgment to provide for attorneys’ fees. The settlement terms stated that Plaintiff was entitled to reasonable fees and costs of enforcing the judgment against Defendants. The court directed the Clerk to add that term to the judgment, including attorneys’ fees.
Prejudgment Interest
The court denied Plaintiff’s request to add prejudgment interest. It explained that settlement agreements are interpreted under general contract-law principles. The August 25, 2022 settlement terms did not include an agreement for prejudgment interest, and the court found no indication that the parties discussed such a term during their settlement conference. The court therefore did not add prejudgment interest. It noted that the judgment included post-judgment interest because federal law requires it.
Sealing Issue and Disposition
Plaintiff also raised sealing the case. The court did not rule on sealing; it stated that any motion to seal must comply with Rule 5B of the judge’s Individual Rules and Practices in Civil Cases.
Judge Vernon S. Broderick ordered the Clerk to amend the judgment. Plaintiff’s requests were granted in part and denied in part: the request concerning attorneys’ fees was granted, and the request concerning prejudgment interest was denied.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.