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S.D.N.Y.Procedural orderFiled Mar. 20, 2024

Dynamic Enjoy Corporation v. Piccolo by Gambrinus, LLC

Judge
Vernon Broderick
Docket
1:22-cv-09909
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Dynamic Enjoy v. Piccolo, Judge Broderick denied Vanderbilt’s request for pro bono counsel without prejudice.

Who this affects

Defendant Alexander Cesaria Vanderbilt, whose application for the court to request pro bono counsel was denied without prejudice.

What happened

In Dynamic Enjoy Corporation v. Piccolo by Gambrinus, LLC, Defendant Alexander Cesaria Vanderbilt asked the court to request a volunteer lawyer for him. He submitted the application on March 12, 2024.

The court said it needed a more developed record before deciding whether Vanderbilt’s chances of success justified appointing counsel. It therefore denied the application without prejudice, allowing him to renew it if he can show a potentially meritorious claim.

Judge Vernon S. Broderick also directed the Clerk of Court to close the motion at Document 65 and mail the order to Vanderbilt, whom the order identifies as proceeding without a lawyer.

The detailed version

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

Case
Dynamic Enjoy Corporation v. Piccolo by Gambrinus, LLC · No. 1:22-cv-09909
Judge
Vernon Broderick
Date
Mar. 20, 2024

Request for Counsel

On March 12, 2024, Defendant Alexander Cesaria Vanderbilt applied for the court to request pro bono counsel, meaning a lawyer who would volunteer to represent him. The order identifies Vanderbilt as a pro se defendant, meaning he was proceeding without a lawyer.

Court’s Analysis

The court explained that, before requesting counsel, it must consider the merits of the litigant’s case, the litigant’s ability to pay for private counsel, efforts to obtain a lawyer, whether counsel is available, and the litigant’s ability to gather facts and address the issues without assistance. As a threshold matter, the litigant must show that the claim has substance or a likelihood of success. The court also noted that volunteer attorney time is limited and that counsel should not be appointed indiscriminately.

The court determined that a more fully developed record was necessary before it could decide whether Vanderbilt’s chances of success warranted appointment of counsel.

Disposition

The court denied Vanderbilt’s application for the court to request pro bono counsel without prejudice to renewal when the existence of a potentially meritorious claim may be demonstrated. The Clerk of Court was directed to close the open motion at Document 65 and mail a copy of the order to Vanderbilt.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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