Accent Delight International Ltd. v. Sotheby's

CourtDistrict Court, S.D. New York
DecidedJanuary 2, 2024
Docket1:18-cv-09011
StatusUnknown

This text of Accent Delight International Ltd. v. Sotheby's (Accent Delight International Ltd. v. Sotheby's) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Accent Delight International Ltd. v. Sotheby's, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- X : ACCENT DELIGHT INTERNATIONAL LTD., : : Plaintiff, : : 18-CV-9011 (JMF) -v- : : MEMORANDUM OPINION SOTHEBY’S et al., : AND ORDER : Defendants. : : ---------------------------------------------------------------------- X JESSE M. FURMAN, United States District Judge: The Court issues this Memorandum Opinion and Order to resolve several outstanding issues that are now fully submitted: Defendants’ motion to preclude Accent Delight’s purportedly new damages theory as to the Tête auction, ECF Nos. 591, 595, 605; lingering disputes as to the admissibility of resale price evidence and other resale-related evidence, ECF Nos. 584, 594, 606; and Accent Delight’s motion to preclude certain testimony of Defendants’ expert witness, Harry Smith, ECF Nos. 602, 607; see also ECF Nos. 595, 606. The Court rules on these matters as follows: • Accent Delight’s Tête Auction Damages Theory: Defendants’ motion to preclude Accent Delight’s purportedly new damages theory as to the Tête auction, ECF No. 591, is DENIED. To be sure, “[w]hen a party . . . fails to raise a new theory of damages until after the close of discovery, the prejudice that results to the adversary can be sufficient to preclude that theory from presentation at trial.” Summit Props. Int’l, LLC v. Ladies Pro. Golf Ass’n, 7-CV-10407 (LBS), 2010 WL 4983179, at *3 (S.D.N.Y. Dec. 6, 2010). Moreover, it is a close call whether Accent Delight’s revised theory is best characterized as a new theory of damages that could and should have been included in its disclosures pursuant to Rule 26 of the Federal Rules of Civil Procedure, see, e.g., King v. Wang, 14- CV-7694 (LJL), 2021 WL 5299917, at *2-4 (S.D.N.Y. Nov. 15, 2021) (precluding a late- added alternative theory of damages where earlier “[a] dramatically different damages theory was pursued” and “having to defend against the [new] damages theory . . . would risk significant prejudice to Defendants”), or as an appropriate — and indeed necessary — corrective disclosure pursuant to Rule 26, see Agence France Presse v. Morel, 293 F.R.D. 682, 684-85 (S.D.N.Y. 2013) (noting that Rule 26 imposes a duty on parties “that extends to supplementing and amending [their damages] computation if it changes materially”).

Regardless, preclusion is not warranted because Accent Delight has provided sufficient justification for its amendment — namely, new stipulations of fact and the Court’s recent rulings on the parties’ motions in limine, see ECF No. 595, at 1-2 — and, more importantly, because Defendants are not prejudiced by permitting Accent Delight to proceed. Defendants correctly note that Accent Delight, in its motions in limine, sought to exclude evidence regarding ownership of the Rothko, see ECF No. 591, at 3, based on its then-understanding of the appropriate measure of damages for the Tête auction. But the Court denied Accent Delight’s motion, finding that, “[c]ontrary to Accent Delight’s assertion, it is not ‘clear’ from the Court’s summary judgment ruling that evidence pertaining to ownership of the Rothko is wholly irrelevant to the question of damages.” ECF No. 577, at 4. And more to the point, Accent Delight’s “new” theory of damages regarding the Tête auction parallels the theory of damages that Defendants themselves have been urging is the appropriate measure. See, e.g., ECF 568, at 13 (“Although the Court found that a jury could decide that the auction proximately caused Plaintiff’s injuries because Bouvier kept the proceeds, that does not decide what amount of damages would compensate Plaintiff. Plaintiff still must prove the consideration paid (i.e., the value of the Tête, which Plaintiff traded in) and the amount it received (i.e., the value of its interest in the Rothko).”); ECF No. 553, at 31; ECF No. 561, at 27-28. Because Accent Delight now presses the very same theory of damages that Defendants have been arguing for, and because that theory results in a reduction to Defendants’ potential exposure, Defendants cannot claim prejudice that “warrants the ‘drastic remedy’ of preclusion.” King, 2021 WL 5299917, at *2; see also ECF No. 595, at 1-4. Accordingly, Accent Delight may proceed with the theory of damages regarding the Tête auction set forth in the latest proposed joint pretrial order, see ECF No. 592.

Defendants’ alternative request for leave “to move for summary judgment on the new claim,” ECF No. 591, at 6 n.3, is also DENIED. Their motion for summary judgment with respect to the Tête auction was previously denied. See ECF No. 510 (“SJ and Daubert Op.”), at 46-48. The only basis for their request to seek summary judgment again is “that there is no evidence supporting the elements of either actual knowledge or substantial assistance with respect to the new claim,” ECF No. 591, at 6 n.3, but (1) Accent Delight has set forth a revised calculation for damages on an existing claim, not a new claim; and (2) Defendants fail to explain how the revised calculation in any way affects the record with respect to the elements of actual knowledge or substantial assistance. Permitting a renewed motion would run afoul of the well-established principle “that ‘it is improper for a party to file a successive motion for summary judgment which is not based upon new facts and which seeks to raise arguments it could have raised in its original motion.’” Purchase Partners, LLC v. Carver Fed. Savings Bank, 9-CV-9687 (JMF), 2013 WL 1499417, at *7 (S.D.N.Y. Apr. 10, 2013) (quoting Campers’ World Int’l, Inc v. Perry Ellis Int’l, Inc., 221 F.R.D. 409, 409 (S.D.N.Y. 2004)). Finally, as both Defendants and Accent Delight recognize, the question of whether any jury award should be offset by the value of the settlement recently obtained by Accent Delight is not yet ripe for determination. See ECF No. 591, at 7; ECF No. 595, at 4. Accordingly, the Court does not address it here.

• Admissibility of Resale Evidence: The parties raise two issues, addressing first the more substantial issue of the admissibility of evidence of resale prices in aid of damages calculations and turning later to address non-price resale evidence to be offered for various non-damages purposes. See ECF Nos. 585, 594, 606.1 The Court addresses each issue in turn.

With respect to evidence of resale prices, the Court finds that Defendants have failed to present adequate “foundation or evidence . . . indicating whether or how those prices relate to or are reflective of the value at the relevant time — namely, the time of Plaintiff’s purchase.” ECF No. 581 (“Nov. 28, 2023 Conf. Tr.”), at 28:6-12. Defendants’ attempts to argue otherwise by piecing together snippets of Smith’s report and testimony are unavailing. Put simply, Smith’s reports do not address the values of the works at the time of their purchases, but rather focus on the reasonableness of the 2015 insurance valuation of the Salvator Mundi and the Valette emails regarding the Tête. See ECF No. 397-2 (“Smith Rep.”); ECF No. 397-10 (“Smith Rebuttal Rep.”). Nothing in his proffered testimony goes to showing whether market conditions remained consistent across the relevant stretches of time or how the resale prices should be used in calculating actual value at the time of the purchases. To allow him to testify now about these matters would violate Rule 26(a)(2) of the Federal Rules of Civil Procedure as well as Rules 403 and 702 of the Federal Rules of Evidence.

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Related

Agence France Presse v. Morel
293 F.R.D. 682 (S.D. New York, 2013)

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Bluebook (online)
Accent Delight International Ltd. v. Sotheby's, Counsel Stack Legal Research, https://law.counselstack.com/opinion/accent-delight-international-ltd-v-sothebys-nysd-2024.