CIT Bank N.A. v. Schiffman

CourtCourt of Appeals for the Second Circuit
DecidedMarch 18, 2026
Docket23-487
StatusUnpublished

This text of CIT Bank N.A. v. Schiffman (CIT Bank N.A. v. Schiffman) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CIT Bank N.A. v. Schiffman, (2d Cir. 2026).

Opinion

23-487-cv CIT Bank N.A. v. Schiffman

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER“). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 18th day of March, two thousand twenty-six.

PRESENT: JOSÉ A. CABRANES, GERARD E. LYNCH, RAYMOND J. LOHIER, JR., Circuit Judges. ------------------------------------------------------------------ CIT BANK N.A.,

Plaintiff-Counter-Defendant-Appellee,

v. No. 23-487-cv

PAMELA SCHIFFMAN, JERRY SCHIFFMAN,

Defendants-Counter-Claimants-Appellants,

JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, NEW YORK CITY PARKING VIOLATIONS BUREAU,

Defendants. ------------------------------------------------------------------ FOR APPELLANTS: Samuel Katz, Law Office of Samuel Katz, PLLC, Brooklyn, NY

FOR APPELLEE: Steven Rosenfeld, Gross Polowy, LLC, Williamsville, NY

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Dora L. Irizarry, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the District Court is AFFIRMED.

Defendants-Appellants Pamela Schiffman and Jerry Schiffman appeal from

a March 7, 2023 judgment of foreclosure and sale entered by the United States

District Court for the Eastern District of New York (Irizarry, J.), which awarded

Plaintiff-Appellee CIT Bank, N.A. $445,096.55 in damages. The judgment

followed an earlier grant of summary judgment in favor of CIT, which this Court

affirmed. See CIT Bank N.A. v. Schiffman, 999 F.3d 113 (2d Cir. 2021). On

appeal, the Schiffmans raise a number of evidentiary challenges to the District

Court’s damages calculation. We assume the parties’ familiarity with the

underlying facts and the record of prior proceedings, to which we refer only as

necessary to explain our decision to affirm.

2 “We review a district court’s evidentiary rulings for abuse of discretion.”

Carroll v. Trump, 124 F.4th 140, 157 (2d Cir. 2024). As a threshold matter, we

conclude that the Schiffmans did not waive their evidentiary objections. They

do not appear to have been directed to respond to CIT’s supplemental filing in

November 2018 or warned that failure to do so would constitute a waiver of any

objections. Waiver applies “[w]here parties receive clear notice of the

consequences” of failing to object. See Smith v. Campbell, 782 F.3d 93, 102 (2d Cir.

2015) (quotation marks omitted). The Schiffmans timely exercised their right

under 28 U.S.C. § 636(b)(1) to object to the Magistrate Judge’s Report and

Recommendation within 14 days, which was their first clear invitation to

challenge the admissibility of CIT’s evidence. 1

1 We note, however, that had the Schiffmans been invited to provide any objections to CIT’s proffered documents at any point in the three years between when CIT filed those documents and when the magistrate judge issued the Report & Recommendation, their evidentiary arguments would clearly have been waived. See Pan Am. World Airways, Inc. v. Int’l Bhd. of Teamsters, 894 F.2d 36, 40 (2d Cir. 1990) (holding a waiver had occurred when a party sought to present evidence to the district court that it had failed to present to the magistrate judge); Walker v. Stinson, 205 F.3d 1327 (2d Cir. 2000) (summary order) (holding the district court did not abuse its discretion when it declined to address an argument not raised before the magistrate judge). Other circuits have drawn an even stricter line, holding that any “[i]ssues raised for the first time in objections to the magistrate judge's recommendation are deemed waived.” See Marshall v. Chater, 75 F.3d 1421, 1426 (10th Cir. 1996); see also Paterson-Leitch Co. v. Massachusetts Mun. Wholesale Elec. Co., 840 F.2d 985, 990–91 (1st Cir. 1988) (holding that

3 We nevertheless reject the Schiffmans’ evidentiary challenges on the

merits. They first contend that the affirmation submitted by CIT’s counsel,

Steven Rosenfeld, and the documents attached to it were inadmissible hearsay

because Rosenfeld lacked the personal knowledge of the facts necessary to

support the factual assertions made in the affirmation or authenticate the

documents. We disagree. The District Court did not rely on Rosenfeld’s

affirmation for the truth of the matters asserted therein. Instead, the affirmation

served primarily to organize and submit the underlying documentary evidence,

including the Loan Modification Agreement and the Account Records. While

an attorney’s affirmation alone may be insufficient to establish damages, see

Credit Lyonnais Sec. (USA), Inc. v. Alcantara, 183 F.3d 151, 154–55 (2d Cir. 1999),

the District Court did not treat the Rosenfeld affirmation as substantive evidence.

Instead, the District Court properly considered whether the underlying

documents annexed to the affirmation had been sufficiently authenticated. The

Loan Modification Agreement was admissible as a self-authenticating public

“an unsuccessful party is not entitled as of right to de novo review by the judge of an argument never seasonably raised before the magistrate”). However, to date, our precedents have not clearly gone so far, and we decline to do so for the first time here.

4 document under Federal Rule of Evidence 902(1). The Account Records were

sufficiently authenticated under Federal Rule of Evidence 901(b)(4), as they bore

sufficient indicia that they were what CIT Bank claimed them to be. See United

States v. Vayner, 769 F.3d 125, 129–30 (2d Cir. 2014). Thus, the Schiffmans’

argument that the documents were inadmissible because they were “not

authenticated and therefore hearsay” is unavailing. Appellants’ Br. at 5. 2

The Schiffmans next argue that the affidavit submitted by Michelle Nicole

Ray, an assistant secretary for CIT, was not relevant because it failed to annex the

business records upon which it was based. Assuming without deciding that

2 The Schiffmans have not clearly raised – and have therefore abandoned – the separate issue of whether those documents were hearsay even setting aside the question of authentication.

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