Letts v. Avidien Technologies, Inc.

CourtDistrict Court, E.D. North Carolina
DecidedMarch 13, 2025
Docket5:24-cv-00402
StatusUnknown

This text of Letts v. Avidien Technologies, Inc. (Letts v. Avidien Technologies, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Letts v. Avidien Technologies, Inc., (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION Case No. 5:24-CV-00402-M-BM PAMELA LETTS, ) . . ) Plaintiff, ) ) V. ) ORDER ) AVIDIEN TECHNOLOGIES, INC., ) et al., ) ) Defendants. ) a) This matter comes before the court on the memorandum and recommendation (the “Recommendation”’) entered by Magistrate Judge Brian S. Meyers in this case on January 30, 2025 [DE 35].' In the Recommendation, Judge Meyers recommends that the court deny Plaintiffs motion to remand and grant Defendants’ motion to dismiss. DE 35 at 2, 6-7, 18. The Recommendation, along with instructions and a deadline for filing objections, was served on the parties on January 30. See id. at 18-19. Plaintiff filed a timely objection to the Recommendation, and Defendants responded. DE 36; DE 37.”

' This is the second Recommendation entered by Judge Meyers in this matter. Previously, Judge Meyers recommended that the court grant Plaintiff's motion to remand and deny as moot Defendants’ motion to dismiss. See DE 30 at 2. Judge Meyers recommended as such after concluding that Defendants had failed to identify evidence supporting that the amount in controversy in this matter excceds $75,000, which would deprive the court of diversity subject-matter jurisdiction. /d at 16. In objecting to Judge Meyers’ first Recommendation, Defendants submitted an affidavit addressing the amount in controversy. DE 32 at 1-2. Accordingly, this court recommitted the “matter to Judge Meyers with instructions to consider whether the exhibit included with Defendants’ objection, DE 32, alter[ed] his analysis with regard to the amount in controversy in this action.” DE 34 at 2. > Plaintiff's objection significantly excecds the page and word limits permitted by this court’s local rules. See DE 36 at 1-20. Using the word count generated by word processing software, the court calculates the word count in Plaintiff's objection as at least 6,475 words, more than double the word limit of 2,800 words. Local Civil Rule 72.4(b)(2); Local Civil Rule 7.2()(3)(B). Accordingly, Defendants have requested that the court strike Plaintiff's objection or disregard its contents that exceed the word limit. DE 37 at 3-4. Defendant’s request is entirely appropriate. However, given the dispositive nature of the Recommendation, and out of an abundance of caution, the court declines to do so, and has fully considered Plaintiff's objection.

A magistrate judge’s recommendation carries no presumptive weight. See United States ex rel. Wheeler v. Acadia Healthcare Co., Inc., 127 F.4th 472, 486 (4th Cir. 2025). The court “may accept, reject, or modify, in whole or in part, the . . . recommendation[ ] . . . receive further evidence or recommit the matter to the magistrate judge with instructions.” 28 U.S.C. § 636(b)(1). “The Federal Magistrates Act only requires district courts to ‘make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.’” Osmon v. United States, 66 F.4th 144, 146 (4th Cir. 2023) (quoting 28 U.S.C. § 636(b)(1)). And “a party’s objection to a magistrate judge’s report [must] be specific and particularized.” United States v. Midgette, 478 F.3d 616, 621 (4th Cir. 2007). This is a low bar, particularly when the plaintiff is pro sc. Elijah v. Dunbar, 66 F.4th 454, 460 (4th Cir. 2023); Erickson v. Pardus, 551 U.S. 89, 94 (2007). But absent a specific and timely objection, the court reviews only for “clear error” and nced not give any explanation for adopting the recommendation. Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005). I. Plaintiff's Motion to Remand Plaintiff s motion concerns the amount in controversy, which she did not specifically allege in her Complaint. See DE 21; DE 23; DE 1-3. However, Plaintiff did allege that Defendant Avidien Technologies (‘““Avidien’”) agreed to provide her with 20% equity in the company “in exchange for reduced pay,” and then breached that agreement. DE 1-3 at 2, 16, 19, 41. The year after Plaintiff was discharged from Avidien, Defendant Mettler-Toledo “purchased all of the equity of Avidien,” and “the purchase price for the acquisition of Avidien was in excess of $375,000,” DE 32 at 1, meaning that Plaintiffs alleged 20% ownership in Avidicn would be valued in excess of $75,000.3

In addition to the ownership share, the amount in controversy in this matter also consists of withheld commissions, vacation pay, healthcare reimbursement, and a demo instrument. DE 35 at 6.

Judge Meyers concluded that Defendants’ affidavit (from the General Counsel of Mettler- Toledo) regarding the acquisition price of Avidien demonstrated, by a preponderance of the evidence, that the amount in controversy is greater than $75,000. DE 35 at 6-7; see also Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 88 (2014). The court agrees. Plaintiff objects to Defendants’ affidavit as “self-serving” and “conclusory,” DL 36 at 4, but those are inapt characterizations for statements of fact made in a document under penalty of perjury. Plaintiff further objects that Judge Meyers accepted the statements in the affidavit even though Defendants did not “provid{e] supporting financial documentation,” id. at 5, but “{e]stimating the amount in controversy is not nuclear science” and this exercise may “rely to some extent on reasonable .. . inferences, and deductions,” Scott v. Cricket Commce’ns, LLC, 865 F.3d 189, 196 (4th Cir. 2017). Mere, Defendants provided a sworn statement from a Mettler-Toledo executive that the purchase price of Avidien exceeded $375,000. DE 32 at 1-2. Based on that statement, it is reasonable to deduce that Plaintiffs alleged 20% share in Avidien, which she placed in controversy, excceds $75,000. 28 U.S.C. § 1332(a). Plaintiff also argues that Defendants’ affiant “has a clear conflict of interest in advocating for removal and dismissal” and the court should consider his sworn statement “with heightened scrutiny.” DLE 36 at 10. Plaintiff provides no support for this proposition, and it is without merit. Plaintiff has “offered nothing” beyond her own speculation “to suggest that the [] figure” in Defendants’ affidavit “is not an accurate number.” Strawn v. AT & T Mobility LLC, 530 F.3d 293, 299 (4th Cir. 2008) (finding amount in controversy met based on defendant’s affidavit). Lastly, Plaintiff contends that the affidavit was procedurally improper, because Defendants filed it with the court after removal, and “the question of whether the federal court has jurisdiction is decided based on the information available at the time of removal.” DE 36 at 1]. This is an

inaccurate statement of law for multiple reasons. See Dart, 574 U.S.

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Related

Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Lawrence v. Florida
549 U.S. 327 (Supreme Court, 2007)
United States v. Nicholas Omar Midgette
478 F.3d 616 (Fourth Circuit, 2007)
Strawn v. AT & T MOBILITY LLC
530 F.3d 293 (Fourth Circuit, 2008)
Michael Scott v. Cricket Communications, LLC
865 F.3d 189 (Fourth Circuit, 2017)
Erin Osmon v. United States
66 F.4th 144 (Fourth Circuit, 2023)
Larone Elijah v. Richard Dunbar
66 F.4th 454 (Fourth Circuit, 2023)

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Bluebook (online)
Letts v. Avidien Technologies, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/letts-v-avidien-technologies-inc-nced-2025.