Chelsea Hotel Owner LLC v. City Of New York
1:21-cv-03982
S.D.N.Y.Jun 6, 2025Background
- Plaintiffs (Chelsea Hotel Owner LLC, et al.) sought reconsideration of a previous order relating to the production of 2008-2010 email communications by Defendant (City of New York).
- Magistrate Judge Lehrburger previously denied Plaintiffs’ motion to compel the email communications, citing the request’s untimeliness.
- Plaintiffs objected to this denial, but the District Court overruled their objections and affirmed Judge Lehrburger’s order.
- Plaintiffs then filed a motion for reconsideration, arguing that critical facts were overlooked and that their request for production was timely and not properly addressed.
- Defendant countered that the motion for reconsideration was improper as there was no change in law, new evidence, or clear error.
- The District Court reviewed all arguments and denied Plaintiffs' motion for reconsideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to reconsider denial of motion to compel 2008–2010 emails | Request was timely; denial overlooked key facts; ruling was in error | Request was untimely; no new facts | No reconsideration; motion denied |
| Whether Magistrate improperly delayed ruling on request | Judge failed to address request until July order | Magistrate ruled previously | No oversight; delay justified |
| Whether prior ruling caused manifest injustice | Failure to compel is manifest injustice | No manifest injustice; process fair | No manifest injustice found |
| Sufficiency of Court’s reliance on timeliness for affirming | Timeliness alone insufficient reason | Timeliness is a valid basis | Reliance on timeliness affirmed |
Key Cases Cited
- Kolel Beth Yechiel Mechil of Tartikov, Inc. v. YLL Irrevocable Trust, 729 F.3d 99 (2d Cir. 2013) (sets standard for when reconsideration is appropriate)
- Virgin Atl. Airways, Ltd. v. Nat’l Mediation Bd., 956 F.2d 1245 (2d Cir. 1992) (describes grounds for reconsideration)
- Analytical Surveys, Inc. v. Tonga Partners, L.P., 684 F.3d 36 (2d Cir. 2012) (motion for reconsideration is not for new or previously rejected arguments)