Lhotan v. Cahill

CourtDistrict Court, S.D. New York
DecidedJuly 22, 2025
Docket7:22-cv-07681
StatusUnknown

This text of Lhotan v. Cahill (Lhotan v. Cahill) 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
Lhotan v. Cahill, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------------x JOSEPH F. LHOTAN, : Plaintiff, : v. : OPINION AND ORDER : MICHAEL J. CAHILL and : 22 CV 7681 (VB) ELITE LIMOUSINE SERVICE, INC., : Defendants. : -------------------------------------------------------------x

Briccetti, J.: Plaintiff Joseph F. Lhotan brings negligence claims against defendants Michael J. Cahill and Elite Limousine Service, Inc. (“Elite”), in this diversity action seeking damages for personal injuries arising from a December 19, 2018, automobile accident. Now pending are the parties’ cross-motions for summary judgment. (Docs. ##76, 80). For the reasons set forth below, plaintiff’s motion is DENIED, and defendants’ motion is GRANTED IN PART and DENIED IN PART. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332. BACKGROUND I. The Parties’ Submissions The Court must address several procedural defects in the parties’ filings before discussing the record of the case and reaching the substance of this ruling.1 0F First, plaintiff urges the Court to disregard defendants’ motion as untimely, but this argument is unavailing.

1 “[C]ounsel should be cognizant that these deficiencies have required the Court to parse through the record . . . . In the future, a failure to adhere to the applicable procedural rules may not be treated with the same leniency.” Dejana Industries, Inc. v. Village of Manorhaven, 2015 WL 1275474, at *3 (E.D.N.Y. Mar. 18, 2015). On July 25, 2024, the Court granted the parties leave to file cross-motions for summary judgment and ordered all briefs, oppositions, and replies to be filed on October 17, 2024. Although the Court ordered the parties to serve their moving papers by September 3, 2024, defendants served their motion ten days late, on September 13, 2024. Plaintiff thus asks the

Court to disregard defendants’ motion. However, even though defendants’ motion was served after the deadline, it was filed on time. Moreover, plaintiff neither sought an extension of time to reply nor alleges any prejudice arising from the delay. Instead, plaintiff served a lengthy opposition two days before the Court’s deadline to do so. And when, as here, cross-motions present coextensive issues, “[t]he opposing party suffers little prejudice” from an untimely motion “as it cannot claim to have been unaware of or surprised by the court’s consideration of those issues.” Camacho v. City of Buffalo, 2021 WL 9079983, at *8 (W.D.N.Y. Oct. 14, 2021).2 1F Therefore, “the Court declines [plaintiff’s] invitation to disregard [defendants’] cross- motion as untimely.” Hahnel v. United States, 782 F. Supp. 2d 20, 30 (W.D.N.Y. 2011). Second, although both motions were accompanied by statements of undisputed material facts pursuant to Local Civil Rule 56.1, plaintiff did not file a counterstatement. Local Rule 56.1 requires a counterstatement with “correspondingly numbered paragraph[s] admitting or denying” each purportedly undisputed fact in a 56.1 statement, with citations to admissible evidence. Local R. 56.1(b); see also Fed. R. Civ. P. 56(c)(1); Risco v. McHugh, 868 F.Supp.2d 75, 85 n.2 (S.D.N.Y. 2012). Defendants properly filed a counterstatement. (Doc. #81-5).

2 Unless otherwise indicated, case quotations omit all internal citations, quotations, footnotes, and alterations. In lieu of a counterstatement, plaintiff improperly filed an affidavit “disagree[ing] with many points” in defendants’ 56.1 statement. (Doc. #82-10 ¶ 2). The affidavit does not address each paragraph in defendants’ 56.1 statement, and certain of the denials are either unsupported by record evidence or “improperly interject arguments and/or immaterial facts.” Baity v. Kralik,

51 F. Supp. 3d 414, 418 (S.D.N.Y. 2014). However, because the Court has discretion to construe other submissions as a counterstatement, points made in plaintiff’s 56.1 statement and affidavit will be construed as counterstatements to the extent they both (i) directly address facts set forth in defendants’ 56.1 statement, and (ii) are supported by admissible evidence in the record. See Little v. City of New York, 487 F. Supp. 2d 426, 432 (S.D.N.Y. 2007) (construing attorney affirmation and exhibits as a 56.1 counterstatement). Purportedly undisputed facts that are supported by the record and uncontested by plaintiff will be deemed admitted for purposes of this motion. Finally, neither party filed memoranda of law. Instead, the parties improperly submitted attorney affirmations in support of, and in opposition to, the pending motions. Dejana Industries,

Inc. v. Village of Manorhaven, 2015 WL 1275474, at *3 (“[U]nder Local Civil Rule 7.1, legal argument must be set forth in a memorandum of law, not in an attorney affirmation.”). “[A]n attorney’s affirmation that is not based on personal knowledge of the relevant facts is to be accorded no weight.” Little v. City of New York, 487 F. Supp. 2d at 438. Thus, affirmations that “consist[] entirely of factual assertions and legal arguments” are “improper and inadmissible.” Dejana Industries, Inc. v. Village of Manorhaven, 2015 WL 1275474, at *2–3. Although the Court may strike portions of the affirmations which improperly raise legal argument or assert facts, it is within the Court’s “broad discretion to determine whether to overlook a party’s failure to comply with local court rules.” Hughes v. Lebron, 2016 WL 5107030, at *5 n.5 (S.D.N.Y. Sept. 19, 2016). Because “the Court strongly prefers to resolve parties’ claims on the merits,” and because both plaintiff and defendants have erred in the same way, the Court will construe the legal arguments in the parties’ attorney affirmations as memoranda of law. Id. Factual assertions contained therein which are not premised on personal

knowledge will be disregarded. II. Factual Background Together, the parties’ submissions reflect the following background. A. The Collision On December 19, 2018, defendant Cahill was driving plaintiff home from the airport in a vehicle owned by defendant Elite. Cahill was rear-ended by a vehicle driven by third-party Dana LaPorta, shortly after exiting Interstate 684 at Exit 6 onto a service road, in Katonah, New York. LaPorta did not see Cahill’s car in front of her until moments before the collision, which, according to LaPorta, occurred after Cahill came to a stop on the service road. The collision between Cahill and LaPorta caused minimal damage to their cars.

Immediately after striking Cahill’s vehicle, LaPorta was also rear-ended. LaPorta’s vehicle sustained further damage in the second collision. The parties dispute the cause of the collision. Plaintiff contends Cahill fell asleep at the wheel while exiting Interstate 684 because, according to plaintiff, Cahill was sick and under the influence of cold and flu medication. (Doc. #76 ¶¶ 3, 5–8). Plaintiff avers he had to scream at Cahill to wake him, which caused Cahill to startle awake and suddenly slam on his breaks. (Id. ¶¶ 5–8). It is undisputed that Elite’s policies prohibit drivers from transporting passengers while ill. Plaintiff suggests Cahill drove anyway because he would not get paid if he called in sick. Defendants dispute plaintiff’s contentions that Cahill was sick, under the influence of medication, asleep at the wheel, or that he suddenly slammed on his brakes. (Doc. #81-5 ¶¶ 3,

5–8).

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Lhotan v. Cahill, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lhotan-v-cahill-nysd-2025.