Londry v. Stream Realty Partners, L.P.

2026 NCBC 19
CourtNorth Carolina Business Court
DecidedMarch 9, 2026
Docket23-CVS-12833
StatusPublished
AuthorJulianna Theall Earp

This text of 2026 NCBC 19 (Londry v. Stream Realty Partners, L.P.) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Londry v. Stream Realty Partners, L.P., 2026 NCBC 19 (N.C. Super. Ct. 2026).

Opinion

Londry v. Stream Realty Partners, L.P., 2026 NCBC 19.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION MECKLENBURG COUNTY 23CVS012833-590

JARED RAYMOND LONDRY and POINTBLANK VENTURES, LLC,

Plaintiffs, ORDER AND OPINION ON v. DEFENDANTS’ MOTION FOR LIMITED RECONSIDERATION STREAM REALTY PARTNERS, L.P., STREAM REALTY PARTNERS-CHARLOTTE, L.P., and DANIEL FARRAR,

Defendants.

1. THIS MATTER is before the Court upon Defendants’ Motion for Limited

Reconsideration pursuant to North Carolina Rule of Civil Procedure 54(b) (Motion),

(ECF No. 54).

TLG Law, by David G. Redding and Tyler A. Rhoades, for Plaintiffs Jared Raymond Londry and Pointblank Ventures, LLC.

Jackson Lewis P.C., by Daniel Leake II and Kathleen K. Lucchesi, and Moore & Van Allen PLLC, by Scott M. Tyler and Katherine McDiarmid, for Defendants Stream Realty Partners, L.P., Stream Realty Partners- Charlotte, L.P., and Daniel Farrar.

Earp, Judge.

I. PROCEDURAL AND FACTUAL BACKGROUND

2. Plaintiff Jared Raymond Londry (Londry) alleges that, based on an oral

agreement with Defendant Daniel Farrar (Farrar), Londry became a partner in

Defendant Stream Realty Partners-Charlotte, L.P. (Stream Charlotte). 3. After resigning from his position with Stream Charlotte, Londry initiated

this action by filing the Complaint on 25 July 2023. (Compl., ECF No. 3.) Londry

asserted claims for breach of contract against Stream Charlotte and its parent

Stream Realty Partners, L.P. (Stream); breach of the alleged partnership agreement,

breach of fiduciary duty, and fraud against Farrar; and unfair and deceptive trade

practices against all Defendants. (See generally Compl.)

4. On 4 March 2024, Londry filed an Amended Complaint adding Plaintiff

Pointblank Ventures, LLC (Pointblank) as a party and adding a claim for wrongful

interference with contract against all Defendants. (First Am. Compl. [Am. Compl.],

ECF No. 32.)

5. Defendants filed their Motion for Summary Judgment on 29 November

2024, seeking a judgment on all claims Plaintiffs asserted against them. (ECF No.

42.) On 2 December 2024, Plaintiffs filed a Motion for Partial Summary Judgment

requesting offensive summary judgment on their wrongful interference with contract

claim. (ECF No. 44.)

6. The Court issued its Order and Opinion on the Motions for Summary

Judgment on 7 July 2025. Londry v. Stream Realty Partners, L.P., 2025 NCBC LEXIS

80 (N.C. Super. Ct. July 7, 2025) (the Summary Judgment Order). Among its rulings,

the Court denied Defendants’ motion on Plaintiffs’ breach of partnership agreement

and breach of fiduciary duty claims, holding that “absent Stream Charlotte’s

partnership agreement, and given the mix of evidence presented, the Court cannot conclude, as a matter of law, whether Londry and Farrar reached an enforceable

agreement to divide Farrar’s interest in Stream Charlotte.” Id. at *31, 33.

7. On 17 July 2025, Defendants filed the present Motion seeking

reconsideration of this ruling. After full briefing, the Motion is now ripe for

disposition. 1

II. LEGAL STANDARD

8. “Rule 54(b) is the source of authority for what litigants typically refer to as

motions to reconsider.” Pender Farm Dev., LLC v. NDCO, LLC, 2020 NCBC LEXIS

110, at *4 (N.C. Super. Ct. Sep. 25, 2020) (citation and internal quotations omitted).

It provides that an interlocutory ruling “is subject to revision at any time before the

entry of judgment adjudicating all the claims and the rights and liabilities of all the

parties.” N.C. R. Civ. P. 54(b).

9. Absent guidance from North Carolina’s appellate courts on the standard to

apply when considering a motion to reconsider an interlocutory ruling under Rule

54(b), the Court turns to federal case law addressing similarly worded portions of

Federal Rule 54(b). See Ehmann v. Medflow, Inc., 2019 NCBC LEXIS 10, at *9 (N.C.

Super. Ct. Feb. 6, 2019) (“Without the benefit of North Carolina appellate precedent,

in considering a motion for reconsideration the Business Court has previously relied

on case law addressing Federal Rule of Civil Procedure 54(b).” (citations omitted)).

10. “Courts will reconsider an interlocutory order in the following situations:

(1) there has been an intervening change in controlling law; (2) there is additional

1 The Court determines, in its discretion, that oral argument will not aid in its decision and

issues this ruling without a hearing pursuant to BCR 7.4. evidence that was not previously available; or (3) the prior decision was based on clear

error or would work manifest injustice.” Akeva L.L.C. v. Adidas Am., Inc., 385 F.

Supp. 2d 559, 566 (M.D.N.C. 2005) (citations omitted). As this Court has observed,

however, “[s]uch problems rarely arise and the motion to reconsider should be equally

rare.” W4 Farms, Inc. v. Tyson Farms, Inc., 2017 NCBC LEXIS 99, at *5 (N.C. Super.

Ct. Oct. 19, 2017) (citing DirecTV, Inc. v. Hart, 366 F. Supp. 2d 315, 317 (E.D.N.C.

2004)). “A motion for reconsideration under Rule 54(b) is within the trial court’s

discretion.” Id. (citing Akeva, 385 F. Supp. 2d at 565); Ward v. FSC I, LLC, 2017

NCBC LEXIS 19, at *6 (N.C. Super. Ct. Mar. 7, 2017) (citations omitted).

11. In addition to Rule 54(b), Rule 60(a) permits a judge to correct, upon his or

her own initiative, “[c]lerical mistakes in judgments, orders or other parts of the

record and errors therein arising from oversight or omission[.]” N.C. R. Civ. P. 60(a).

Further, “[a]n order denying summary judgment is not res judicata and a judge is

clearly within his rights in vacating such denial.” Miller v. Miller, 34 N.C. App. 209,

212 (1977).

III. ANALYSIS

12. Defendants present the Stream Charlotte Partnership Agreement

(Partnership Agreement) and argue that it constitutes additional evidence that was

not previously available to the Court, and that it is therefore appropriate for the

Court to consider it now under Rule 54(b). (Mem. L. Supp. Defs.’ Mot. Limited

Recons. [Defs.’ Mem.] 4, ECF No. 55.) They argue that the Partnership Agreement

did not vest Farrar with the authority to transfer a portion of his ownership interest in Stream Charlotte to Londry and therefore Londry could not have become a partner

by virtue of any communication with Farrar alone. Consequently, they maintain, no

fiduciary duty based on a partnership existed. (Defs.’ Mem. 4–6.)

13. Plaintiffs respond that the Partnership Agreement is not newly discovered

evidence because it has always been available to Defendants. (Mem. L. Opp’n Defs.’

Mot. Limited Recons. [Pls.’ Opp’n] 2, ECF No. 59.) Plaintiffs conclude that it is

“improper to use [the Motion] to ‘ask the Court to rethink what the Court has already

thought through—rightly or wrongly.’ ” (Pls.’ Opp’n 2 (quoting Potter v. Potter, 199

F.R.D. 550, 552 (D. Md. 2001) (cleaned up))).

14. On this point, the Court agrees with Plaintiffs. The Partnership Agreement

was indisputably available to Defendants and could have been presented with their

Motion for Summary Judgment. See South Carolina v. United States, 232 F. Supp.

3d 785, 793 (D.S.C. 2017) (“[A] motion to reconsider an interlocutory order should not

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Related

Lowe v. Bradford
289 S.E.2d 363 (Supreme Court of North Carolina, 1982)
Miller v. Miller
237 S.E.2d 552 (Court of Appeals of North Carolina, 1977)
Dalton v. Camp
548 S.E.2d 704 (Supreme Court of North Carolina, 2001)
Akeva L.L.C. v. Adidas America, Inc.
385 F. Supp. 2d 559 (M.D. North Carolina, 2005)
DirecTV, Inc. v. Hart
366 F. Supp. 2d 315 (E.D. North Carolina, 2004)
South Carolina v. United States
232 F. Supp. 3d 785 (D. South Carolina, 2017)
Potter v. Potter
199 F.R.D. 550 (D. Maryland, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
2026 NCBC 19, Counsel Stack Legal Research, https://law.counselstack.com/opinion/londry-v-stream-realty-partners-lp-ncbizct-2026.