American Empire Surplus Lines Insurance Company v. J.R. Contracting & Environmental Consulting, Inc.

CourtDistrict Court, S.D. New York
DecidedOctober 21, 2024
Docket1:23-cv-04942
StatusUnknown

This text of American Empire Surplus Lines Insurance Company v. J.R. Contracting & Environmental Consulting, Inc. (American Empire Surplus Lines Insurance Company v. J.R. Contracting & Environmental Consulting, Inc.) 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
American Empire Surplus Lines Insurance Company v. J.R. Contracting & Environmental Consulting, Inc., (S.D.N.Y. 2024).

Opinion

USL SUNT DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOCH DATE FILED: 10/21/2024 American Empire Surplus Lines Insurance Company, Plaintiff, 1:23-cv-04942 (AT) (SDA) -against- OPINION AND ORDER J.R. Contracting & Environmental Consulting, Inc., Defendant.

STEWART D. AARON, UNITED STATES MAGISTRATE JUDGE: Pending before the Court is a motion by Defendant J.R. Contracting & Environmental Consulting, Inc. (“J.R.” or “Defendant”), pursuant to Rule 702 of the Federal Rules of Evidence and Daubert v. Merrell Dow Pharmaceuticals Inc., 509 U.S. 579 (1993), to exclude the proposed opinions of Plaintiff’s expert, Thomas M. Trezise (“Trezise”), which are offered in rebuttal of the opinions of Defendant’s expert, Arthur R. Nelson (“Nelson”) (hereinafter, the “Daubert Motion”). (Def.’s 8/16/24 Not. of Daubert Mot., ECF No. 75.)* For the reasons set forth below, Defendant’s Daubert Motion is GRANTED IN PART and DENIED IN PART.

* The Honorable Analisa Torres referred the Daubert Motion to the undersigned as a non-dispositive motion. (Am. Order of Reference, ECF No. 54.) “Because Daubert motions are ‘nondispositive of the litigation,’ they are routinely determined by magistrate judges, subject to ‘clear error’ review by the district judge.” DoubleLine Cap. LP v. Odebrecht Fin., Ltd., No. 17-CV-04576 (DEH) (BCM), 2024 WL 1115944, at *3 n.4 (S.D.N.Y. Mar. 14, 2024) (quoting /srael v. Springs Indus., Inc., No. 98-CV-05106 (ENV) (RML), 2007 WL 9724896, at *2 (E.D.N.Y. July 30, 2007)) (cleaned up).

BACKGROUND2 I. Factual Overview Plaintiff American Empire Surplus Lines Insurance Company (“AESLIC” or “Plaintiff”)

issued to J.R. a commercial excess liability policy (the “Policy”), which included a premium charge to be computed as a percentage of J.R.’s gross receipts during the policy period. Am. Empire, 2024 WL 3638329, at *1. Plaintiff assigned an advanced premium to the Policy based on J.R.’s estimate of its gross receipts during the policy period, which was subject to adjustment if a post-policy audit reflected that J.R.’s actual gross receipts exceeded its initial estimate. Id.

The post-policy audit concluded that J.R.’s actual gross receipts exceeded its initial estimate, and thus J.R. owed an additional premium in the amount of $487,386.00. Am. Empire, 2024 WL 3638329, at *2. Following non-payment of this additional premium, AESLIC brought this action on June 13, 2023, seeking to recover payment of said additional premium. Id. On March 29, 2024, Nelson issued his expert report in support of J.R. Id. II. Trezise Report

After Nelson issued his expert report in support of J.R. on March 29, 2024, Am. Empire, 2024 WL 3638329, at *2, on May 29, 2024, Trezise issued his rebuttal report in support of AESLIC (the “Trezise Report”). (Trezise Rpt., ECF No. 76-2.) Based on his review of the audit and the Nelson Report, Trezise offered the following four opinions: 1. The Policy was a surplus lines policy and, as such, not regulated by the State of New Jersey. [AESLIC] had full discretion to establish the forms 2 The Court assumes familiarity with its prior Opinion and Order regarding a Daubert motion filed by Plaintiff. See Am. Empire Surplus Lines Ins. Co. v. J.R. Contracting & Env’t Consulting, Inc., No. 1:23-CV- 04942 (AT) (SDA), 2024 WL 3638329, at *1-3. (S.D.N.Y. Aug. 2, 2024). and terms of the Policy as well as the rules and rates by which the premium was determined. . . . 2. The terms of the Policy solely define the relationship between [AESLIC] and J.R. . . .. Standards and practices, whether of admitted or surplus lines insurers, have no application. . . . 3. The Policy provided coverage for significant risks. The coverage was not illusory. . . . 4. J.R. . . . and . . . Nelson cannot challenge the underwriting process of [AESLIC]. . . . (Trezise Rpt. at 4-10 (emphases omitted).) While addressing a number of Nelson’s premises and assumptions, Trezise maintains that “rate [at issue] was unmistakably and clearly stated and anyone familiar with basic arithmetic can understand how it determined the premium. The Policy has no flaw as to the definition of the [r]ates and is, therefore, enforceable.” (Id. at 7.) On July 17, 2024, Defendant deposed Trezise regarding the opinions expressed in the Trezise Report. (Trezise Dep., ECF No. 76-3.) III. J.R.’s Daubert Motion And Relevant Procedural History On July 26, 2024, J.R. moved for leave to file a Daubert Motion to exclude Trezise’s proposed expert opinions. (Def.’s 7/26/24 Letter, ECF No. 72, at PDF p. 1.) Because there was a Daubert motion to exclude the expert opinions of Nelson (the “Nelson Daubert Motion”) pending before the Court at that time, on July 29, 2024, the Court ordered J.R. to refrain from filing the motion until after the Court’s decision on the Nelson Daubert Motion. (7/29/24 Order, ECF No. 73 (“Because the Court’s decision on such motion may affect the scope of Nelson’s testimony, and by extension the scope of any rebuttal, Defendant shall

refrain from filing its motion until after the Court’s decision on [the Nelson Daubert Motion.”).) On August 2, 2024, the Court granted in part and denied in part the Nelson Daubert Motion. Am. Empire, 2024 WL 3638329 at *1. Specifically, the Court found: In sum, although Nelson shall not be permitted to testify about his interpretation of the Policy, and any other legal conclusions, the Court finds that it is more likely than not that Nelson is qualified to serve as an expert, that his opinions are based on sufficient facts, that he applied reliable principles and methods and that his opinions will help Judge Torres to understand the evidence. Thus, Nelson may provide testimony about the insurance industry and audits, and may provide his opinion regarding premiums due under the Policy based upon a hypothetical set of facts.

2024 WL 3638329 at *10. On August 16, 2024, J.R. filed its Daubert Motion (and supporting papers) to exclude Trezise’s expert opinion. (Def.’s 8/16/24 Not. of Daubert Mot.; Palatucci Decl.; Def.’s Mem., ECF No. 77.) On August 29, 2024, AESLIC filed its opposition papers. (O’Connor Decl., ECF No. 79; Pl.’s Opp’n Mem., ECF No. 80.) On September 6, 2024, J.R. filed its reply memorandum. (Def.’s Reply, ECF No. 81.) LEGAL STANDARDS Rule 26 of the Federal Rules of Civil Procedure provides that parties can submit expert testimony that is “intended solely to contradict or rebut evidence on the same subject matter identified by another party.” Fed. R. Civ. P. 26(a)(2)(D)(ii). “Rebuttal [expert] evidence is properly admissible when it will explain, repel, counteract or disprove the evidence of the adverse party.” Scott v. Chipotle Mexican Grill, Inc., 315 F.R.D. 33, 44 (S.D.N.Y. 2016) (citation omitted). Rule 702 of the Federal Rules of Evidence, which governs the admissibility of

testimony by expert witnesses, including rebuttal experts, provides: A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if the proponent demonstrates to the court that it is more likely than not that:

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Bluebook (online)
American Empire Surplus Lines Insurance Company v. J.R. Contracting & Environmental Consulting, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-empire-surplus-lines-insurance-company-v-jr-contracting-nysd-2024.