Karen Price v. David Widaski, Sr., et al.

CourtDistrict Court, N.D. Georgia
DecidedNovember 18, 2025
Docket1:25-cv-02852
StatusUnknown

This text of Karen Price v. David Widaski, Sr., et al. (Karen Price v. David Widaski, Sr., et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Karen Price v. David Widaski, Sr., et al., (N.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

KAREN PRICE, Plaintiff, Civil Action No. v. 1:25-cv-02852-SDG DAVID WIDASKI, SR., et al., Defendants.

OPINION AND ORDER This case is before the Court on various motions filed by pro se Plaintiff Karen Price. The Court orders as follows: 1. Price’s motion to reopen this case [ECF 26] is GRANTED. 2. Price’s emergency motion for reconsideration of the Court’s August 22, 2025 Order and for entry of declaratory judgment [ECF 27] is DENIED. 3. Price’s motion to correct docket irregularities and for clarification [ECF 28] is DENIED. 4. Price’s application to appeal in forma pauperis [ECF 30] is DENIED. 5. Price’s emergency motion to reopen case and expedite ruling [ECF 35] is DENIED as moot. 6. Price’s fourth and fifth motions for a temporary restraining order (TRO) [ECFs 36, 57] are DENIED. 7. Price’s emergency motion for declaratory judgment on writ of possession [ECF 41] is DENIED. 8. Price’s emergency motion to appoint a receiver [ECF 42] is DENIED. 9. Price’s motion to waive PACER fees [ECF 43] is DENIED. 10. Price’s emergency motion to correct procedural violations and authorize service [ECF 48] is DENIED. 11. Price’s emergency motion for administrative stay and to file in camera [ECF 50] is DENIED. 12. Price’s motion to seal her emergency motion for administrative stay [ECF 51] is DENIED. 13. Price’s motion for leave to file exhibits under seal [ECF 54] is DENIED. 14. Price’s motion for contempt and referral to the Chief Judge [ECF 58] is DENIED. 15. Price’s motion for recusal [ECF 59] is DENIED. 16. Price’s emergency motion for civil contempt against Chief Judge May [ECF 60] is DENIED. 17. Price’s emergency motion for U.S. Marshal service of criminal and regulatory referrals [ECF 61] is DENIED. 18. Price’s motion for certificate of necessity [ECF 62] is DENIED. 19. Price’s motion to compel Chief Judge May to exercise administrative authority [ECF 63] is DENIED. I. Motion to Reopen The Court previously granted Price’s motion to stay this case during the pendency of her medical incapacity.1 However, while the stay was in place, Price filed an emergency motion seeking a limited reopening of the case solely to obtain injunctive and declaratory relief related to the potential sale of the real property at

1 ECF 23. issue in this litigation (the Buckhead Property).2 By Order dated August 22, 2025, the Court denied the motion and advised Price that she would need to seek the

full lifting of the stay in this case to obtain any other relief.3 Price has now filed a motion to reopen this case, representing that she has recovered sufficiently to pursue this litigation.4 Accordingly, Price’s motion to

reopen is granted, and the stay in this case is hereby lifted. Price’s emergency second motion to reopen this case is denied as moot. II. Motion for Recusal and Motion for Contempt Before turning to the substantive issues in this case, the Court will first

consider Price’s motion for recusal, brought pursuant to 28 U.S.C. § 455(a).5 See In re BellSouth Corp., 334 F.3d 941, 949 (11th Cir. 2003) (explaining that, after triggering 28 U.S.C. § 455(b), the judge was prohibited from making further substantive rulings); United States v. Moody, 977 F.2d 1420, 1423 (11th Cir. 1992)

(a district court judge who has recused may “perform ministerial acts” that do not have “any implication concerning the merits of the case”).

2 ECF 24. 3 ECF 25. 4 ECF 26. 5 ECF 59. Under § 455(a), a federal judge “shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.” “[T]he standard of

review for a § 455(a) motion ‘is whether an objective, disinterested, lay observer fully informed of the facts underlying the grounds on which recusal was sought would entertain a significant doubt about the judge’s impartiality.’” United States

v. Patti, 337 F.3d 1317, 1321 (11th Cir. 2003) (quoting Parker v. Connors Steel Co., 855 F.2d 1510, 1524 (11th Cir. 1988)). Price seeks the recusal of undersigned based on prior rulings against her, as well as the fact that undersigned has not ruled on her motions as quickly as she

demands. While Price may disagree with undersigned’s decisions, or the speed with which they can be made, “judicial rulings alone almost never constitute a valid basis for a bias or partiality motion.” United States v. Amedeo, 487 F.3d 823,

828 (11th Cir. 2007) (quoting Liteky v. United States, 510 U.S. 540, 555 (1994)). The proper method of seeking relief from those decisions is an appeal—which Price is seeking—not a motion for recusal. Therefore, undersigned concludes that an

objective observer would not doubt his impartiality, and Price’s motion for recusal is denied. For these same reasons, Price’s motion to find undersigned in contempt6 is denied as well.

6 ECF 58. III. Motion for Reconsideration Price moves for reconsideration of the Court’s August 22 Order, which

denied her emergency motion for declaratory or injunctive relief related to the potential sale of the Buckhead Property.7 Under the Local Rules of this Court, “[m]otions for reconsideration shall not be filed as a matter of routine practice.” LR 7.2(E), NDGa. Such motions should be filed only when “a party believes it is

absolutely necessary.” Id. To demonstrate necessity, the movant must show that there is: “(1) newly discovered evidence; (2) an intervening development or change in controlling law; or (3) a need to correct a clear error of law or fact.” Bryan

v. Murphy, 246 F. Supp. 2d 1256, 1258–59 (N.D. Ga. 2003). A motion for reconsideration cannot be used to relitigate old matters, raise arguments, or present evidence that could have been raised prior to the entry of judgment. Smith v. Ocwen Fin., 488 F. App’x 426, 428 (11th Cir. 2012). Parties may

not use motions for reconsideration to show the Court how it “could have done better.” Bryan, 246 F. Supp. 2d at 1259 (citing Pres. Endangered Areas of Cobb’s Hist., Inc. v. U.S. Army Corps of Eng’rs, 916 F. Supp. 1557, 1560 (N.D. Ga. 1995), aff’d, 87

F.3d 1242 (11th Cir. 1996)). Price contends that reconsideration is appropriate because the Court committed a clear factual error in the August 22 Order, where it reasoned that a

7 ECF 27. TRO was not appropriate because no sale of the Buckhead Property had been scheduled.8 Price also argues that she should have been granted a declaratory

judgment, even if a TRO was not warranted.9 As to the first argument, Price has not shown that the Court erred in finding that no sale of the Buckhead Property had been scheduled. While Price presented

evidence that the Buckhead Property was being marketed for sale,10 that is not the same thing as the property being under contract for sale to a specific buyer—the latter situation might present a substantial likelihood of irreparable harm, but the former situation is simply too speculative to warrant the extraordinary remedy of

a TRO. See Ne. Fla. Chapter of Ass’n of Gen. Contractors of Am. v. City of Jacksonville, 896 F.2d 1283, 1285 (11th Cir.

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