508 Operations, LLC v. Artistic Holiday Designs, LLC

2025 NY Slip Op 30405(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 31, 2025
DocketIndex No. 652355/2023
StatusUnpublished

This text of 2025 NY Slip Op 30405(U) (508 Operations, LLC v. Artistic Holiday Designs, LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
508 Operations, LLC v. Artistic Holiday Designs, LLC, 2025 NY Slip Op 30405(U) (N.Y. Super. Ct. 2025).

Opinion

508 Operations, LLC v Artistic Holiday Designs, LLC 2025 NY Slip Op 30405(U) January 31, 2025 Supreme Court, New York County Docket Number: Index No. 652355/2023 Judge: Joel M. Cohen Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. FILED: NEW YORK COUNTY CLERK 01/31/2025 01:01 PM INDEX NO. 652355/2023 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 01/31/2025

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: COMMERCIAL DIVISION PART 03M -----------------------------------------------------------------------------------X

508 OPERATIONS, LLC, INDEX NO. 652355/2023

Plaintiff, MOTION DATE 04/08/2024 -v- MOTION SEQ. NO. 001 ARTISTIC HOLIDAY DESIGNS, LLC, AMAZE LIGHT FESTIVAL CHICAGO, LLC, AMAZE LIGHT FESTIVAL MANAGEMENT, LLC, AMAZE LIGHT FESTIVAL NEW SUPPLEMENTAL YORK CITY, LLC, DEREK NORWOOD, SAMANTHA DECISION/ORDER AFTER BARKUS INQUEST Defendants. -----------------------------------------------------------------------------------X

HON. JOEL M. COHEN:

The following e-filed documents, listed by NYSCEF document number (Motion 001) 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 90, 92, 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 118, 119, 120, 121 were read on this application for INQUEST .

In its inquest application, Plaintiff 508 Operations, LLC (“Plaintiff”) seeks a damages

award of $1,536,509.35, comprised of $978,458.62 for services rendered by Plaintiff,

$410,331.42 in late fees under the relevant agreements, and prejudgment interest (NYSCEF 92

[“Londrico Supp. Aff.”] ¶ 7, 9). Plaintiff also seeks an award of attorneys’ fees and costs in the

amount of $76,700.52 (NYSCEF 120). Finally, plaintiff seeks an award of punitive damages in

the amount of at least $1,000,000 (Londrico Supp. Aff. ¶ 11). Upon consideration of the

foregoing documents and for the reasons discussed below, the requested relief is granted in

part.

652355/2023 508 OPERATIONS, LLC vs. ARTISTIC HOLIDAY DESIGNS, LLC ET AL Page 1 of 6 Motion No. 001

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BACKGROUND

On July 15, 2024, this Court granted Plaintiff’s motion to strike Defendants’ Answer and

for a default judgment on the issue of liability for claims related to Defendants’ failure to pay for

labor and related services provided in connection with the Amaze Light Festival at Citi Field

from 2022-2023 (NYSCEF 90). In its decision and order on that motion, the Court directed the

parties to submit a proposed briefing schedule for an inquest on damages (id.). Despite the

adjournment of that schedule granted by the Court at Defendants’ request, Defendants have not

submitted any opposition to Plaintiff’s inquest application (NYSCEF 115).

DISCUSSION

I. Actual Damages

Plaintiff has submitted contemporaneous invoices and work orders reflecting the amounts

owed by Defendants for services rendered by Plaintiff (NYSCEF 45, 47-49, 51-72), as well as a

balance statement reflecting the total amount of $978,458.62 owed as of February 6, 2023

(NYSCEF 73). The entries on the balance statement correspond with and do not exceed the

amounts billed in the invoices.1 Further, Defendants received the invoices and did not object to

them within 24 hours of receipt as required by the relevant agreements (NSYCEF 44 [“Londrico

Moving Aff.”] ¶ 25).

The agreements provide for a late fee of 1.5% of any balance left unpaid as of 14 days

after receipt of each invoice “compounded daily and consecutively” (see e.g. NYSCEF 51

1 One invoice (NYSCEF 62) reflects a larger amount owed than the corresponding entry on the balance sheet, but Plaintiff relies on the lesser figure in its total damages calculation.

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[“Terms and Conditions”] § 2). Plaintiff has capped the amount of late fees it seeks at 25% per

annum (NYSCEF 93). While Plaintiff additionally seeks statutory prejudgment interest in the

amount of 9% per annum, contractual late fees are “in lieu of—not in addition to—statutory 9%

interest” (Schiffmann Assoc., Inc. v Baker & Daniels LLP, 147 AD3d 482, 483 [1st Dept 2017]).

Plaintiff calculates the amount of late fees on an invoice-by-invoice basis from the date 14 days

after each invoice was due to be paid, i.e. the date that late fees began to accrue for each invoice

under the agreements (NYSCEF 93).

II. Punitive Damages

In its complaint, Plaintiff sought an award of punitive damages in the amount of

$1,000,000.00 in connection with its fourth cause of action for fraudulent concealment against all

Defendants (NYSCEF 2 [“Complaint”] ¶ 68, 69). While determining entitlement to punitive

damages is not proper on a motion for default judgment, plaintiff may demonstrate its

entitlement thereto at the inquest stage by presenting proof “including…the circumstances

surrounding the transactions tending to exhibit or explain the motive of defendants” (Dwight W.

Winkelman Found., Inc. v Winkelman, 219 AD2d 816, 816 [4th Dept 1995]). “Punitive damages

are available in a tort action where the wrongdoing is intentional or deliberate, has circumstances

of aggravation or outrage, has a fraudulent or evil motive, or is in such conscious disregard of the

rights of another that it is deemed willful and wanton” (Swersky v Dreyer and Traub, 219 AD2d

321, 328 [1st Dept 1996]). In a nutshell, punitive damages are reserved for extraordinary

circumstances.

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Based on its review of the record the Court finds that Defendants’ alleged conduct, while

obviously not laudable, does not rise to the level of “gross and high moral culpability” such that

punitive damages are appropriate (Walker v Sheldon, 10 NY2d 401, 405 [1961]).

III. Attorneys’ Fees and Costs

Plaintiff seeks an award of all its attorneys’ fees and costs incurred in bringing this action

pursuant to the indemnification clauses in the relevant agreements (NYSCEF 45, 47, 48, 66).

“Inasmuch as a promise by one party to a contract to indemnify the other for attorney's fees

incurred in litigation between them is contrary to the well-understood rule that parties are

responsible for their own attorney's fees, the court should not infer a party's intention to waive

the benefit of the rule unless the intention to do so is unmistakably clear from the language of the

promise” (Hooper Assocs., Ltd. v AGS Computers, Inc., 74 NY2d 487, 492 [1989]). The relevant

part of the indemnification provisions indemnifies Plaintiff for claims “that may be asserted

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Related

R.F. Schiffmann Associates, Inc. v. Baker & Daniels LLP
2017 NY Slip Op 1134 (Appellate Division of the Supreme Court of New York, 2017)
Walker v. Sheldon
179 N.E.2d 497 (New York Court of Appeals, 1961)
Hooper Associates Ltd. v. AGS Computers, Inc.
548 N.E.2d 903 (New York Court of Appeals, 1989)
Swersky v. Dreyer & Traub
219 A.D.2d 321 (Appellate Division of the Supreme Court of New York, 1996)
Dwight W. Winkelman Foundation, Inc. v. Winkelman
219 A.D.2d 816 (Appellate Division of the Supreme Court of New York, 1995)

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2025 NY Slip Op 30405(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/508-operations-llc-v-artistic-holiday-designs-llc-nysupctnewyork-2025.