George Steinmetz v. Bridge Path Property Group, LLC

Background

On February 15, 2024, Judge Jessica G. L. Clarke entered a default judgment in favor of George Steinmetz and against Bridge Path Property Group, LLC as to liability. Judge Clarke referred the case to Magistrate Judge Robyn F. Tarnofsky to conduct an inquest—a proceeding to determine the amount of damages, if any, and recommend other relief.

Requirements for Steinmetz

The order required Steinmetz to file proposed findings of fact and conclusions of law by March 8, 2024. The submission had to address all damages and other monetary relief sought, state the exact dollar amount requested, and specify any nonmonetary relief.

For actual damages, Steinmetz had to provide admissible evidence, such as declarations or affidavits with authenticated supporting documents. Each proposed factual finding had to cite the supporting declaration or document, and the submission had to explain how the requested amount was calculated and how it related to the legal claims.

Any request for attorney’s fees had to include contemporaneous time records showing the date of service, time spent, hourly rate when applicable, and work performed by each timekeeper. Steinmetz also had to provide evidence about the attorneys’ qualifications and documentation of costs and expenses.

Before filing, Steinmetz had to mail the proposed findings, supporting materials, and the order to Bridge Path at its last known address, then file proof of mailing with the court.

Issues the court would still examine

The court stated that, even after a default, it had to be satisfied that it had personal jurisdiction over Bridge Path. It also had to confirm subject-matter jurisdiction, meaning the court’s legal authority to hear the case. The order warned that inadequate proof of service could result in denial of Steinmetz’s request for a damages judgment.

The court also stated that it had to determine whether the complaint’s well-pleaded factual allegations, treated as true after default, were legally sufficient to establish liability for each claim. The proposed legal conclusions therefore had to connect each asserted claim to specific allegations in the complaint.

Response and possible hearing

Bridge Path could serve and file responses to Steinmetz’s proposed findings and supporting materials by March 22, 2024. The court stated that it might conduct the damages inquest based solely on written submissions. A party seeking an evidentiary hearing had to explain why written submissions were insufficient, identify the witnesses who would testify, and describe the evidence to be presented.

Disposition

This order set procedures and deadlines for the damages inquest. It did not determine the amount of damages, award attorney’s fees, enter a damages judgment, or otherwise state the final amount of relief.