Brown v. Amarante

CourtDistrict Court, S.D. New York
DecidedMarch 27, 2025
Docket1:23-cv-03514
StatusUnknown

This text of Brown v. Amarante (Brown v. Amarante) 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
Brown v. Amarante, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK EDWARD BROWN Plaintiff, -against- JOSE AMARANTE, LUIS DATIZ, THE NEW YORK CITY TRANSIT AUTHORITY 23-CV-3514 (JGLC) ADJUDICATION BUREAU and “JOHN DOE” and “JANE DOE”, the last two names ORDER ADOPTING REPORT being fictitious, said parties intended being AND RECOMMENDATION tenants or occupants, if any, having or claiming an interest in, or lien upon, the premises described in the complaint, Defendants.

JESSICA G. L. CLARKE, United States District Judge: This case was referred to Magistrate Judge Lehrburger for general pretrial purposes and all dispositive motions. See ECF No. 8. Plaintiff moved for an order (1) granting summary judgment on his foreclosure claim against Defendants Jose Amarante and Luis Datiz; (2) striking Defendants’ Answer and Counterclaims; and (3) granting default judgment against the non- answering Defendants. ECF No. 28. On November 8, 2024, Judge Lehrburger issued a Report and Recommendation recommending that summary judgment on Plaintiff’s foreclosure claim be denied, that summary judgment be granted to Plaintiff on Defendants’ First through Third and Fifth through Eleventh affirmative defenses and Defendants’ first counterclaim, but denied as to Defendants’ Fourth and Twelfth affirmative defenses and second counterclaim for attorney’s fees, and that default judgment be denied against the non-answering defendants. ECF No. 35 (“R&R”). On November 21, 2024, Plaintiff filed a timely Objection. ECF No. 36 (“Obj.”). Defendants do not object, filing timely responses to Plaintiff’s Objection. ECF No. 38. In reviewing a report and recommendation, 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)(C). A district court “must determine de novo any part of the magistrate judge’s disposition that has been properly objected to.” Fed. R. Civ. P. 72(b)(3); see also United States v.

Male Juvenile, 121 F.3d 34, 38 (2d Cir. 1997). To accept those portions of the report to which no timely objection has been made, however, a district court need only satisfy itself that there is no clear error on the face of the record. See, e.g., Wilds v. United Parcel Serv., 262 F. Supp. 2d 163, 169 (S.D.N.Y. 2003). This clearly erroneous standard also applies when a party makes only conclusory or general objections, or simply reiterates his original arguments. See, e.g., Ortiz v. Barkley, 558 F. Supp. 2d 444, 451 (S.D.N.Y. 2008). Finally, “new arguments and factual assertions cannot properly be raised for the first time in objections to the report and recommendation, and indeed may not be deemed objections at all.” Piligian v. Icahn Sch. of Med. at Mount Sinai, 490 F. Supp. 3d 707, 716 (S.D.N.Y 2020) (internal citation omitted). The Court has reviewed the motion papers, the R&R, the Objection, and Defendants’

response, and finds the R&R to be well-reasoned and grounded in fact and law. Plaintiff’s arguments in the Objection lack merit. First, Plaintiff contends that he submitted sufficient evidence of default through the attachment of the Demand Loan Payoff exhibit. Obj. at 5. Plaintiff argues that the R&R should not have recommended ignoring the Demand Loan Payoff based on Plaintiff’s inadvertent mistake referencing the document as the payoff statement of a 2021 Note. Id. at 5–6. Given Plaintiff’s assertions in the Objection that the reference to a 2021 Note was indeed an inadvertent typographical error, the Court is inclined to overlook the error and consider the Demand Loan Payoff as evidence. But even so, the Demand Loan Payoff is insufficient evidence of default for

the other reasons stated in the R&R. See R&R at 14–18. Specifically, given the number of times that the Note has changed owners through reassignments, as well as the temporal gaps of specific recordkeeping evidenced by the first exhibit attached to Plaintiff’s affidavit, see ECF No. 28-12 at 7–69, the Court is not convinced that the Demand Loan Payoff is an accurate record of payment history rather than a statement of what Plaintiff claims is owed. Indeed, while Plaintiff’s

affidavit calls the first exhibit with temporal gaps the “Payment History,” this same affidavit only references the Demand Loan Payoff in the context of a paragraph detailing the total amount he believes is due. Id. at ¶¶ 13, 15. With “questions regarding what the [Demand Loan Payoff] show[s],” the Court cannot find summary judgment in favor of Plaintiff based on this document. FTS Cap., LLC v. Stuyvesant Constr. Corp., No. 19-CV-7275 (TAM), 2024 WL 1014120, at *5 (E.D.N.Y. Mar. 8, 2024). Second, Plaintiff argues that the R&R was in error to consider defenses that were raised for the first time in Defendants’ opposition to Plaintiff’s motion for summary judgment. Obj. at 7–10. Plaintiff challenges the R&R’s reliance on federal law for waiver of defenses and urges the Court to instead adopt the rule of New York law as stated in U.S. Bank National Association v.

Nelson, 169 A.D.3d 110 (2d Dep’t N.Y. 2019), aff’d, 163 N.E.3d 49 (N.Y. 2020). Obj. at 7–10. To the contrary, federal law governs when an affirmative defense is waived in a federal court proceeding. See Fed. R. Civ. P. 8(c); see, e.g., Legal Aid Soc’y v. City of New York, 114 F. Supp. 2d 204, 222 (S.D.N.Y. 2000) (applying federal procedural law on the forfeiture of an affirmative defense supplied by state law); Santos v. Dist. Council of N.Y.C. & Vicinity of United Bhd. of Carpenters & Joiners of Am., AFL-CIO, 619 F.2d 963, 967 (2d Cir. 1980) (directing district courts to follow federal procedural rules when determining whether untimely assertions of state- law-based affirmative defenses were waived). But even applying state law waiver rules under Nelson, the outcome would be the same.

That is because Nelson only requires that “where the answering party wishes to interpose new matter in defense to the cause of action that goes beyond the essential elements of the cause of action . . . the party must plead, as an affirmative defense, ‘all matters which if not pleaded would be likely to take the adverse party by surprise or would raise issues of fact not appearing on the face of a prior pleading.’” Nelson,169 A.D.3d at 113. (citing N.Y. C.P.L.R. 3018(b)). The

Nelson Court found that certain issues of standing were such a defense that must be pled affirmatively. Id. But the defenses raised under RPAPL § 1302(1)(b) and RPL § 421 are both issues that Plaintiff should have been previously aware of as statutory requirements and are apparent from the face of the prior pleadings. Moreover, Plaintiff’s arguments concerning prejudice are untimely. See Obj. at 9–10. As the R&R notes, Plaintiff failed to assert any such arguments in the original briefing, though given opportunity to do so. R&R at 21. The Court declines to consider those arguments now, because “new arguments and factual assertions cannot properly be raised for the first time in objections to the report and recommendation[.]” Piligian v. Icahn Sch. of Med. at Mount Sinai, 490 F. Supp. 3d 707, 716 (S.D.N.Y 2020) (internal citation omitted).

Third, Plaintiff contends that the defense under RPL § 421 is unfounded on the merits. Obj. at 10.

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Related

United States v. Male Juvenile (95-Cr-1074)
121 F.3d 34 (Second Circuit, 1997)
Ortiz v. Barkley
558 F. Supp. 2d 444 (S.D. New York, 2008)
Legal Aid Society v. City of New York
114 F. Supp. 2d 204 (S.D. New York, 2000)
Wilds v. United Parcel Service, Inc.
262 F. Supp. 2d 163 (S.D. New York, 2003)

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Bluebook (online)
Brown v. Amarante, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-amarante-nysd-2025.