BAT LLC v. TD Bank N.A.

CourtDistrict Court, E.D. New York
DecidedSeptember 26, 2024
Docket1:15-cv-05839
StatusUnknown

This text of BAT LLC v. TD Bank N.A. (BAT LLC v. TD Bank N.A.) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BAT LLC v. TD Bank N.A., (E.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

BAT LLC,

Plaintiff, 15-cv-5839 (NRM) (CLP) v. ORDER ADOPTING REPORT TD BANK, N.A., HALIFAX SECURITY, AND RECOMMENDATION INC., d/b/a NORTH AMERICAN VIDEO, HALIFAX SECURITY, INC., LYDIA SECURITY MONITORING, INC., d/b/a COPS MONITORING and INTEGRATED SECURITY SYSTEMS, Defendants.

NINA R. MORRISON, United States District Judge: In this action, Plaintiff asserts violations of New York Banking Law § 338 as well as gross negligence, breach of bailment contract, and breach of contract. The underlying dispute arises from losses asserted by Plaintiff from the theft of certain high-value items that were stored in a safe deposit box at a TD Bank branch in Brooklyn, New York, and which were seized by intruders in 2012. This Court referred a series of interrelated motions to the Hon. Cheryl L. Pollak, United States Magistrate Judge, for a Report and Recommendation. As described below, the Court adopts Magistrate Judge Pollak’s detailed and well- reasoned Report and Recommendation in full. BACKGROUND On August 3, 2015, Plaintiff BAT LLC (“BAT”) commenced the instant action, asserting violations of New York Banking Law § 338 as well as gross negligence, breach of bailment contract, and breach of contract. Plaintiff alleges that it is owed damages arising from the theft of certain high-value items — including what Plaintiff contends were millions of dollars’ worth of diamonds — that were stored in

a safe deposit box at a TD Bank branch in Brooklyn, New York, and which were seized by still-unidentified intruders who breached the Bank’s security systems in August 2012. Plaintiff originally brought this suit against Defendant TD Bank (“TD Bank” or “the Bank”) and a second Defendant (ADT LLC) who has since been voluntarily dismissed from the case. In the nine years since the lawsuit was commenced, the

parties — who now include a total of four Defendants — have engaged in extensive discovery, and Plaintiff has amended its complaint three times. The present record entails hotly disputed claims between the remaining parties regarding, inter alia, which persons, estates, or other entities have a lawful ownership interest in the stolen contents of the safe deposit box. In particular, the parties dispute whether Plaintiff BAT — which alleges that it is a limited liability company with the right to sue to recover certain losses arising from the August 2012 break-in at the Bank —

has standing to assert the state law claims at issue in this action. On December 20, 2022, this Court referred a series of interrelated motions to the Hon. Cheryl L. Pollak, United States Magistrate Judge, for a Report and Recommendation (“R&R”). These included: (1) four motions for summary judgment filed by Defendants Lydia Security, Halifax, TD Bank, and Integrated Security Systems1 (ECF Nos. 304, 305, 306, 309); (2) Plaintiff’s cross motion for summary judgment and spoliation against Defendants TD Bank and Halifax (ECF No. 322); (3) TD Bank’s motion to preclude Plaintiff’s expert Donald Palmieri (ECF No. 307);

(4) Plaintiff’s motion to preclude Defendants’ various experts (ECF No. 321); and (5) Plaintiff’s motion to amend the Complaint (ECF No. 354). On March 30, 2024, Judge Pollak issued a seventy-eight-page R&R recommending dismissal of the entire action due to lack of subject matter jurisdiction. Specifically, Judge Pollak concluded that, even viewing the record in the light most favorable to Plaintiff, Plaintiff lacked Article III standing to assert

the claims in the Fourth Amended Complaint because BAT did not have valid “title or ownership” in the underlying subject of the claims asserted (i.e., the contents of the safe deposit box at issue). Judge Pollak therefore recommended that this Court grant Defendants’ motion for summary judgment based on lack of subject matter jurisdiction. Judge Pollak also recommended that the Court deny Plaintiff’s motion for leave to amend its complaint under Fed. R. Civ. P. 15(a)(2), 17, and 21 to add four new individual plaintiffs (“the New Plaintiffs”) whom BAT contended had

suffered the requisite injury-in-fact to confer standing to sue under Article III. Finally, Judge Pollak recommended that the Court dismiss the parties’ cross- motions to preclude experts as moot; that the Court deny Defendant Integrated Security Systems’ motion for sanctions under Fed. R. Civ. P. 11(c); and that the

1 Defendant Integrated Security Systems’ motion includes a request for sanctions against BAT. (ECF No. 294). Court deny Plaintiff’s motion for sanctions against TD Bank and Defendant Halifax Security Holdings, Inc., for alleged spoliation of evidence concerning TD Bank’s alarm system.

On April 15, 2024, Plaintiff timely filed objections to the R&R, insofar as the R&R recommended (1) summary judgment and dismissal of the action based on BAT’s lack of standing, and (2) denial of leave to file a Fourth Amended Complaint. Each of the four Defendants filed its own memorandum in response to Plaintiff’s objections, in which Defendants urged this Court to adopt Judge Pollak’s R&R in full.

DISCUSSION A district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate [judge].” 28 U.S.C. § 636(b)(1); see also Fed. R. Civ. P. 72(b)(3). Following the issuance of a R&R, the parties are given an opportunity to file written objections to the R&R. See 28 U.S.C. § 636(b)(1). The district judge must evaluate de novo “any part of the magistrate judge’s disposition that has been properly objected to.” Fed. R. Civ. P. 72(b)(3); 28

U.S.C. § 636(b)(1) (“A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.”); United States v. Drago, No. 18-CR-0394 (SJF) (AYS), 2019 WL 3072288, *1 (E.D.N.Y. July 15, 2019) (“Any portion of such a report and recommendation to which a timely objection has been made is reviewed de novo.”). However, where a party files an objection that is “conclusory or general . . . or simply reiterates [the] original arguments,” that portion of the R&R is reviewed “only for clear error.” Pall Corp. v. Entegris, Inc., 249 F.R.D. 48, 51 (E.D.N.Y. 2008) (quoting Barratt v. Joie, No. 96-cv-324, 2002 WL 335014, at *1 (S.D.N.Y. Mar. 4,

2002)). See generally Fed. R. Civ. P. 72(b)(3). While substantial portions of Plaintiff’s objections to the R&R merely restate its unsuccessful arguments before Magistrate Judge Pollak, out of an abundance of caution, this Court has conducted a de novo review of each of the two principal recommendations in the R&R to which Plaintiff objects: (1) Judge Pollak’s conclusion that BAT lacks standing to bring this suit, and (2) her recommendation

that leave to amend the complaint a fourth time be denied. Upon de novo review, the Court agrees with Judge Pollak’s well-reasoned and thorough recommendations on both fronts. The Court has also reviewed the remainder of the R&R for clear error and finds none.

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Bluebook (online)
BAT LLC v. TD Bank N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bat-llc-v-td-bank-na-nyed-2024.