Holguin v. Quality Furniture NY LLC

Background

On January 30, 2024, Judge Analisa Torres entered a default judgment for Camilo Holguin, Astrid Coello, and Tomaz Laskawski against Quality Furniture NY LLC, Bargain House by Quality Furniture Inc., Bargain House by Quality Furniture NY Inc., and Issa Nasrallah as to liability. By a separate order entered the same day, Judge Torres referred the case to Magistrate Judge Robyn F. Tarnofsky for an inquest—a process for determining the amount of damages and other relief after a default judgment.

Requirements for Plaintiffs

The order required the plaintiffs to file proposed findings of fact and conclusions of law by February 23, 2024. Their filing had to state the exact amount of damages or other monetary relief requested and the precise terms of any nonmonetary relief.

For actual damages, the plaintiffs had to provide admissible evidence sufficient to allow the Court to determine the amount with reasonable certainty. Declarations or affidavits could authenticate supporting documents. Each proposed factual finding had to cite the supporting declaration or document, explain how the requested amount was calculated, and connect the damages to the relevant legal claims.

Any request for attorney fees had to include authenticated, contemporaneous time records identifying the date of service, hours worked, hourly rate when applicable, and work performed. The plaintiffs also had to provide evidence about each timekeeper’s identity, background, and qualifications, as well as evidence of costs and expenses.

Jurisdiction and Liability

Before entering a damages judgment, the Court stated that it had to be satisfied that it had personal jurisdiction over the defendants and subject-matter jurisdiction over the action. The order warned that inadequate proof that the defendants were properly served could lead to denial of the plaintiffs’ request for a damages judgment.

The Court also stated that it had to determine whether the complaint’s well-pleaded allegations, treated as true after default, were legally sufficient to establish liability on each asserted cause of action. The plaintiffs therefore had to cite specific allegations supporting each conclusion of liability.

Service, Responses, and Possible Hearing

Before filing their proposed findings and supporting materials, the plaintiffs had to mail them, along with a copy of the order, to the defendants’ last known addresses. The plaintiffs had to file proof of that mailing. The defendants could serve and file responses by March 8, 2024.

The Court notified the parties that it might conduct the damages inquest solely from written submissions. A party seeking an evidentiary hearing had to explain why written submissions would not be sufficient, identify the proposed witnesses, and describe the evidence the witnesses would present.

Disposition

Judge Tarnofsky entered a scheduling order governing the damages inquest. The order did not award or determine damages, attorney fees, or other relief.